The Delhi High Court, on September 3, 2025, quashed an FIR lodged under Section 376 of the Indian Penal Code (rape) against a bank manager from Bihar. Justice Swarana Kanta Sharma ruled that the case arose from a complicated consensual relationship rather than sexual exploitation, highlighting that criminal law cannot be misused to address failed personal relationships.
Background
The FIR was registered at Nabi Karim police station in November 2024 on the complaint of a 24-year-old woman from Bihar. She alleged that the man had exploited her physically and emotionally on repeated assurances of marriage, only to later marry another woman for dowry. She narrated incidents in Varanasi, Delhi, and other cities where she said he forced intimacy under the guise of eventual marriage.
During the investigation, however, a marriage certificate dated January 2024 from an Arya Samaj Mandir in Bihar surfaced. The man insisted he and the complainant were married, while she shifted between calling him her husband and denying the marriage’s validity.
Court's Observations
Justice Sharma carefully traced the contradictions. On one hand, the complainant told the Crime Against Women Cell that she had indeed married him in January 2024, even calling him her husband. On the other hand, she claimed later that the certificate was fabricated.
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The bench noted,
"If the two were married, then allegations of rape cannot stand between spouses. If they were not, then her continued consensual relationship even after knowing of his other marriage raises doubts on the claim of deception."
The Court emphasized that both were adults - she was an educated UPSC aspirant living independently in Delhi.
The Judge pointed out that consensual intimacy over a long period, continued even after knowledge of his marriage to another woman, weakens the charge of rape based on false promise of marriage.
Citing Supreme Court precedents, the Court distinguished between a false promise made with no intention to marry and a broken promise due to later circumstances.
"Consent induced by deliberate fraud is different from choices consciously made in an ongoing relationship," the judge remarked.
The Decision
In the end, the Court held that the FIR did not disclose the essential ingredients of rape. Justice Sharma quashed FIR No. 447/2024 and all related proceedings, stressing that criminal courts are not arbiters of morality.
The order concluded:
"Adults entering intimate relationships must accept responsibility for their choices. To convert every failed relationship into a rape case would trivialize genuine cases and overburden the justice system."
Case Title: Ankit Raj v. State of NCT of Delhi & Others
Case Number: CRL.M.C. 3061/2025 & CRL.M.A. 13572/2025
Date of Decision: 03 September 2025
