The Supreme Court on Thursday quashed a rape case filed against an advocate from Chhattisgarh, holding that a consensual relationship between two adults cannot automatically be treated as rape merely because the relationship later ended without marriage. The Court found that the allegations did not satisfy the legal ingredients required to prosecute the accused under the charge of repeated rape.
Background of the Case
The case arose from an FIR lodged on February 6, 2025, by a woman advocate against fellow lawyer Pramod Kumar Navratna. She alleged that he had repeatedly engaged in sexual relations with her on the false promise of marriage.
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According to the complaint, the two met at a social event in September 2022 and gradually developed a close relationship. The complainant alleged that during one meeting, the accused forcibly established physical relations and later assured her that he would marry her. She claimed that the relationship continued on that promise and that she later became pregnant, following which he allegedly forced her to undergo an abortion.
The woman also alleged that when she approached the accused and his family in January 2025 regarding marriage, she was assaulted and threatened.
The accused, however, claimed that the relationship was consensual and that the complainant had been pressuring him to marry her. He approached the High Court seeking to quash the FIR, but the High Court refused, stating that the issue of consent required investigation.
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Proceedings Before the Supreme Court
During the hearing, counsel for the accused argued that the complainant was a 33-year-old married woman with a child and was fully aware of her marital status and legal implications. It was submitted that she voluntarily entered into the relationship and continued it for more than two years.
On the other hand, the State and the complainant contended that the accused had exploited her emotional vulnerability by promising marriage while knowing he would never fulfil it. They also relied on alleged WhatsApp conversations suggesting that the accused had misled her.
Court’s Observations
The Bench of Justice B.V. Nagarathna and Justice Ujjal Bhuyan examined whether the allegations constituted rape under Section 376(2)(n) of the Indian Penal Code, which deals with repeated sexual assault.
The Court noted that the complainant was legally married at the time of the alleged incidents and divorce proceedings between her and her husband were still pending. It emphasised that under Indian marriage laws, a person cannot legally enter into another marriage while the first marriage is subsisting.
“The complainant herself was not legally eligible to marry the accused during the relevant period,” the Bench observed, adding that any alleged promise of marriage in such circumstances could not be legally enforceable.
The Court also highlighted that both parties were aware of the complainant’s marital status from the beginning. It rejected the argument that her consent was obtained through deception.
The judges further remarked that the complainant, being an advocate, was expected to understand the legal position. The Court observed, “The facts unmistakably indicate a consensual relationship turning acrimonious.”
Difference Between False Promise and Breach of Promise
The Bench relied on earlier Supreme Court rulings distinguishing a false promise of marriage from a breach of promise. It clarified that rape charges can arise only when a promise to marry was made from the very beginning with no intention to fulfil it and solely to obtain consent for sexual relations.
The Court noted that every failed relationship cannot be converted into a criminal prosecution. It warned that misuse of rape laws in personal disputes could trivialise genuine cases of sexual violence.
“The offence of rape must be invoked only in cases involving genuine coercion or absence of free consent,” the Bench said, cautioning against criminalising failed relationships.
Decision of the Court
After reviewing the FIR, charge sheet, and investigation records, the Supreme Court concluded that no prima facie case of rape was made out. The Court ruled that continuing the prosecution would amount to abuse of the legal process.
The Bench set aside the High Court’s order and quashed the FIR, charge sheet, and all related proceedings, including the pending trial before the Sessions Court.
The appeal was accordingly allowed.
Case Title: Pramod Kumar Navratna v. State of Chhattisgarh & Others
Case No.: Criminal Appeal arising out of SLP (Crl.) No. 4452 of 2025
Decision Date: February 5, 2026
