The Supreme Court has quashed criminal proceedings against Martanda Singh in a case arising from a three-year relationship, holding that the material on record did not show that the woman’s consent for the physical relationship was obtained through coercion or a false promise of marriage. The judgment was delivered by Justices J. B. Pardiwala and K. Vinod Chandran
Background
The dispute arose from FIR No. 191 of 2025 registered at Sirgitti Police Station in Bilaspur, Chhattisgarh. The second respondent alleged that Singh had a physical relationship with her on the pretext of marriage and later refused to marry her.
The Court noted that both parties had met while attending an academy for competitive examinations and had developed a relationship. Their families had also discussed their marriage. According to the order, the physical relationship continued for around three years while Singh visited the woman’s house when her mother was away. The relationship eventually ended, while the marriage proposal discussed by the families also did not materialise.
A subsequent undertaking to marry before the Mahila Thana Counselling Centre, Bilaspur, was also relied upon in the proceedings. The Supreme Court, however, observed that such an undertaking could not itself be treated as a promise to marry, particularly after a relationship that had already continued for three years.
The Bench relied upon the principle laid down in Deepak Gulati v. State of Haryana, explaining that a failed promise to marry does not automatically establish that consent was obtained through a misconception of fact. The Court emphasised that there must be material indicating that the accused never intended to honour the promise from the beginning.
The Court further observed:
“We cannot but reiterate the proposition as enumerated in the above extract that the consent under fear or misconception cannot be loosely inferred to fasten criminal liability on one of the parties when both admittedly, had a consensual relationship and the other party willingly permitted physical relationship.”
The Bench also noted that the complaint did not contain a clear assurance or promise of marriage preceding the relationship. It found the allegation of a relationship continuing for three years on the alleged pretext of marriage insufficient, on the facts before it, to establish criminal culpability. The Court also observed that the criminal process could not be used as a “strong-arm tactic”.
The Supreme Court found no criminal culpability against Martanda Singh and held that there was no reason for the criminal proceedings to continue. It quashed Charge Sheet No. 199 of 2025 dated June 17, 2025, and closed Sessions Case No. 216 of 2025 pending before the Additional Sessions Judge (FTC), Bilaspur.
The appeal was accordingly allowed.
