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Supreme Court Quashes Criminal Proceedings After Consensual Relationship Turns Sour

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Supreme Court quashes criminal proceedings after finding a consensual relationship had turned sour, holding that continuing the trial would serve no purpose. - Sachin Gupta v. The State of Chhattisgarh and Anr.

Supreme Court Quashes Criminal Proceedings After Consensual Relationship Turns Sour
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The Supreme Court has quashed criminal proceedings arising from a relationship that, according to the Court, had initially been consensual but later turned sour. A bench of Justice J. B. Pardiwala and Justice K. Vinod Chandran held that the material on record did not justify continuing the criminal case and set aside the High Court’s refusal to quash the proceedings.

Background

The dispute arose from FIR No. 326 of 2025, registered at Manipur Police Station, Surguja, Chhattisgarh, on December 5, 2025. The allegations included sexual assault, refusal to marry, assault and threats.

The complainant alleged that the appellant had sexually assaulted her in May 2024 and subsequently agreed to marry her. She said the relationship continued thereafter and alleged that she became pregnant twice, with both pregnancies being aborted. She also alleged that she was assaulted in a hotel in October 2025 and threatened with the circulation of intimate videos.

The appellant, however, claimed that the relationship was consensual and that the allegations arose after a dispute involving money. He relied on two complaints submitted to the police before the FIR was registered.

The Court examined the matter through the principles governing quashing of criminal proceedings and noted that the record indicated a consensual relationship between the parties.

The bench particularly noted that there was no allegation that a promise of marriage had been made to induce the complainant into a sexual relationship. According to the Court, the allegation was that the desire to marry was expressed after the alleged incident and was thereafter voluntarily accepted.

The Court observed:

"On step two, we have to specifically notice that admittedly there was a courtship and even according to the 2nd respondent she was raped against her will and then the desire to marry was put forth. No allegation of a promise to marry, proffered to entice the 2nd respondent into a sexual relationship, was raised."

The bench also took note of the delay in raising the allegation of rape, the absence of contemporaneous complaints regarding the alleged hotel assault and threats, and the fact that the medical material did not indicate the alleged abortions.

The Court further observed that the complaint was filed in circumstances where the complainant wanted the appellant to marry her and sought punitive action if he did not.

After examining the entire record, the Supreme Court concluded that continuing the trial would serve no purpose. It held that the High Court should have exercised its power under Section 482 of the Code of Criminal Procedure to quash the proceedings.

The Court therefore set aside the impugned High Court order and quashed Charge Sheet No. 5 of 2026 in Criminal Case No. 147 of 2026 pending before the Chief Judicial Magistrate, Ambikapur, District Sarguja. It directed that no criminal proceedings should continue against the appellant or the other accused in the FIR.

The appeal was accordingly allowed.

Case Details:

Case Title: Sachin Gupta v. The State of Chhattisgarh and Anr.

Case Number: Criminal Appeal No. 4721 of 2026 (@ SLP (Crl.) No. 4615 of 2026)

Judge: Justice J. B. Pardiwala and Justice K. Vinod Chandran

Decision Date: October 1, 2026

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