The Supreme Court of India has quashed an FIR filed against Lalu Yadav, accused of rape under Section 376 of the Indian Penal Code (IPC), citing that the complainant and the appellant were involved in a long-term consensual relationship. The court emphasized that the complainant’s allegations do not prima facie establish that she gave her consent for sexual relations under a misconception of fact, but rather indicate a consensual relationship that spanned several years.
The ruling was delivered by a bench comprising Justice C.T. Ravikumar and Justice Rajesh Bindal in Lalu Yadav v. The State of Uttar Pradesh & Ors. (Criminal Appeal No. ____ of 2024, arising out of SLP (Crl.) No. 9371 of 2018), overturning a July 2018 decision by the Allahabad High Court, which had refused to quash the FIR.
Background of the Case
The case stems from an FIR filed on February 21, 2018, at the Nandganj Police Station in Ghazipur District, Uttar Pradesh, by the complainant, alleging that Lalu Yadav had deceived her with a false promise of marriage, leading to a physical relationship. The complainant claimed that they had been in a relationship since 2013, during which Yadav repeatedly assured her that he would marry her. Over this period, the complainant alleged that she became pregnant twice, and Yadav forced her to abort both times.
The complainant’s narrative also revealed that she and Yadav lived together as husband and wife for an extended period, with the full knowledge of her family. However, after Yadav secured a job in the army, he allegedly refused to marry her, prompting the filing of the complaint.
Key Legal Issues
1. False Promise of Marriage and Consent: The primary issue before the court was whether the complainant’s consent to the sexual relationship was based on a false promise of marriage, which would render the consent invalid under Section 375 of the IPC, constituting rape.
2. Delay in Filing the FIR: Another critical issue was the significant time lag between the alleged start of the relationship in 2013 and the registration of the FIR in 2018. The court examined whether this delay undermined the credibility of the complainant’s allegations.
3. Section 313 IPC Allegation: The FIR also included a charge under Section 313 of the IPC (causing miscarriage without a woman’s consent). However, after further investigation, the charge was dropped due to a lack of evidence.
Supreme Court’s Observations
Justice C.T. Ravikumar, delivering the judgment, underscored several inconsistencies in the complainant’s allegations. While the complainant accused Yadav of establishing physical relations without her consent, the FIR itself indicated that the couple had lived together as husband and wife for over five years. This contradiction raised serious doubts about the complainant’s claim that her consent was obtained under a false promise of marriage.
The court cited its earlier rulings, particularly in Shivashankar alias Shiva v. State of Karnataka (2019) and Naim Ahamed v. State (NCT of Delhi) (2023), where it had held that prolonged consensual relationships could not be retrospectively categorized as rape merely because the man later refused to marry. In this context, the court stated:
“It is difficult to hold sexual intercourse in the course of a relationship which has continued for five years as ‘rape,’ especially when the complainant herself alleges that they lived together as husband and wife.”
The court also noted that the substantial delay in filing the FIR, more than five years after the alleged start of the relationship, raised further questions about the veracity of the complainant’s claims. The court found no prima facie evidence to suggest that the complainant’s consent for the sexual relationship was obtained through deception.
Decision and Conclusion
The Supreme Court concluded that the allegations did not make out a prima facie case of rape or any other cognizable offense under the IPC. It emphasized that the relationship between Yadav and the complainant was long-term and consensual, and the subsequent refusal to marry could not be construed as evidence of a false promise made at the inception of the relationship.
“The subsequent refusal to marry the complainant would not be sufficient, by any stretch of imagination, to draw the existence of a prima facie case that the complainant had given her consent for the sexual relationship under misconception of fact, so as to accuse the appellant of having committed rape within the meaning of Section 375, IPC,” the court observed.
As a result, the court set aside the Allahabad High Court’s order and quashed the FIR filed against Yadav. The appeal was allowed, and all further proceedings based on the FIR were dismissed.
Case Details:
– Case Title: Lalu Yadav v. The State of Uttar Pradesh & Ors.
– Case Number: Criminal Appeal No. ____ of 2024 (arising out of SLP (Crl.) No. 9371 of 2018)
– Bench: Justice C.T. Ravikumar and Justice Rajesh Bindal
– Legal Representation: The appellant, Lalu Yadav, was represented by senior counsel, while the State of Uttar Pradesh and the complainant were represented by their respective legal teams.
