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Rajasthan High Court Refuses To Quash Rape FIRs, Cites Fear of Victims and False Marriage Promises

6 Jun 2025 12:05 PM - By Shivam Y.

Rajasthan High Court Refuses To Quash Rape FIRs, Cites Fear of Victims and False Marriage Promises

The Rajasthan High Court has rejected the plea to quash two FIRs filed against a man accused of repeatedly engaging in sexual relations with two women under the pretense of marrying them. The FIRs, registered in February and March 2024, contain serious allegations including rape under Section 376(2)(n) IPC, criminal intimidation, and voluntarily causing hurt.

“In Indian societal norms, the matters relating to sexual assault in large number of cases are not being reported by women timely in police due to the embarrassment which they may have to face later on... The possibility of accused taking benefit of the situation or the fear instilled in the women victim thus cannot be ruled out,” said Justice Kuldeep Mathur while hearing the case.

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The court found that the complainants were in an intermittent relationship with the accused, Arpit Naraniwal. Despite earlier separations, they resumed their relationships based on repeated promises of marriage. The judge noted that this pattern may have misled the women into believing the accused would eventually marry them.

“It is highly probable that the complainants of the impugned FIRs, owing to embarrassment and on being continuously promised marriage by the petitioner, did not report the matter earlier as they were under a bonafide belief that he would keep his promise,” the court observed.

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Justice Mathur further said that consent obtained through deceit, especially under the false promise of marriage, does not qualify as valid under Section 90 of the IPC. The FIRs show a consistent claim that Naraniwal never intended to marry the women from the beginning.

In one case (FIR No. 115/2024), the woman identified as ‘S’ reportedly attempted suicide after the accused evaded marriage. She was allegedly tricked into signing a live-in agreement without reading it. The court remarked:

“The document of live-in relationship was got prepared by the petitioner which prima facie indicates that he was giving a fictitious assurance to the complainant that he has started living with her as husband.”

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In the second FIR (No. 76/2024), the woman referred to as ‘A’ initially refused to engage in physical relations but agreed only after Naraniwal promised marriage. He later resumed the relationship post-rehabilitation and threatened to leak intimate videos when she resisted.

The High Court refused to treat the FIRs as false or malicious, stating that the material collected during investigation supports the allegations and merits further inquiry.

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“This Court is of the firm view that the impugned FIRs cannot be labelled as false/frivolous... particularly when the case diaries indicate that the investigating agency has collected material to establish commission of an offence,” the court said.

The case, titled Arpit Naraniwal v State and batch, featured Senior Advocate Manish Shishodiya representing the petitioner, while Public Prosecutor Narendra Singh and Additional Government Advocate Ravindra Singh Bhati appeared for the State.