The Allahabad High Court has quashed criminal proceedings against a man accused of rape on the alleged false promise of marriage, holding that the material on record indicated a long-term consensual relationship between two adults rather than a case attracting criminal prosecution.
Justice Vivek Kumar Singh observed that the relationship between the parties continued for nearly five years and that the facts suggested “a love relationship turned sour.”
Background of the Case
The case goes back to August 2019, when a woman lodged an FIR at Colonelganj police station in Prayagraj against Sanjay Saroj, accusing him of rape, assault, and criminal intimidation. According to her complaint, she had come to Prayagraj in 2014 to prepare for competitive exams, and Saroj, a distant relative, had helped her settle in. The two stayed in touch, and she alleged that he established a physical relationship with her on the promise of marriage - a promise she said he never kept.
She told police that whenever she pushed him to marry her, he turned violent. The final straw, she said, came on August 10, 2019, when another such argument ended in assault and threats.
What followed was unusual. Her statement changed across different stages of the investigation. In her FIR, she spoke of a false promise of marriage. Later, before a magistrate, she claimed an obscene video had been used to blackmail her, and that a "sham" marriage had even been staged in front of relatives. Meanwhile, medical examination found no injuries on her body.
Then came another twist - on August 27, 2019, just over a fortnight after the FIR, Saroj and the woman actually got married at an Arya Samaj temple in Prayagraj, with both families present. Despite this, the case continued, and police filed a chargesheet in January 2020. A magistrate took cognizance in September 2021, prompting Saroj to approach the High Court to get the entire case thrown out.
Court’s Observations
After examining the FIR, witness statements and the legal principles laid down by the Supreme Court in several recent judgments, the High Court noted that the woman was an educated adult and had remained in the relationship from 2014 to 2019 without making any complaint during that period.
The Court observed:
“The long gap of five years between the first alleged act of sexual intercourse and the continued relationship for five years until the filing of the first information report, convinces this Court that it is a clear case of a love relationship turned sour.”
The bench further found that the record did not show that the accused had made a false promise of marriage from the very beginning solely to obtain consent for a physical relationship. It also noted that the parties eventually married after registration of the FIR.
According to the Court, the available material indicated a consensual relationship between two adults, and the allegations of assault, abuse and threats were not supported by specific material particulars.
Decision
Allowing the petition, the High Court held that continuation of the criminal case would amount to misuse of the criminal process and that no prima facie offence was made out on the facts presented before it.
“The present case stands on the footing of rarest of rare case to invoke the inherent jurisdiction for quashing the criminal proceedings,” the Court said while concluding that the matter fell within the categories identified by the Supreme Court for exercise of quashing powers.
The Court accordingly quashed the charge sheet dated 8 January 2020, the cognizance and summoning order dated 4 September 2021, and the entire criminal proceedings pending before the Special Chief Judicial Magistrate, Allahabad.
Case Details
Case Title: Sanjay Saroj @ Sanjay Kumar v. State of U.P. and Another
Case Number: Application U/S 482 No. 752 of 2022
Judge: Justice Vivek Kumar Singh
Decision Date: 18 June 2026
