The Supreme Court of India quashed a criminal proceeding against a man accused of sexually exploiting a woman under the false pretext of marriage. The Court held that a 16-year consensual relationship cannot be classified as rape unless it is proven that the accused had no intention of marrying the woman from the beginning. The judgment, delivered on March 3, 2025, by a bench comprising Justices Vikram Nath and Sandeep Mehta, emphasized that the complainant, a highly educated and well-established woman, did not report the alleged sexual assaults for over a decade, raising doubts about the credibility of her claims.
Background of the Case:
The case revolved around Rajneesh Singh @ Soni, the appellant, who was accused of sexually assaulting the complainant, a woman with whom he had a 16-year-long relationship. The complainant alleged that the appellant had repeatedly sexually exploited her under the false promise of marriage. However, the Court found that the relationship was consensual and that the allegations were raised only after the appellant married another woman.
The FIR was lodged in 2022, accusing the appellant of offences under Sections 376 (rape), 384 (extortion), 323 (voluntarily causing hurt), 504 (intentional insult), and 506 (criminal intimidation) of the Indian Penal Code (IPC). The complainant claimed that the appellant had sexually assaulted her in 2006 and continued to exploit her under the guise of marriage. However, the Court noted that the complainant did not report the alleged assaults for 16 years, and the FIR was filed only after the appellant married another woman.
The Court expressed skepticism about the complainant’s claims, stating that it was “hard to believe” that a highly qualified and well-placed woman would allow herself to be sexually exploited for 16 years without raising any protest. The Court observed:
“It is almost impossible to swallow the version of the complainant that for the entire period of 16 years, she unreservedly allowed the appellant to subject her to repeated acts of sexual intercourse under the impression that the accused would someday act upon his promise of marriage.”
The Court further noted that the complainant and the appellant had a long-standing consensual relationship, during which they even performed informal marriage rituals. The Court referred to precedents like Mahesh Damu Khare v. State of Maharashtra and Prashant v. State (NCT of Delhi), which held that a prolonged consensual relationship cannot be considered rape based on a false promise of marriage unless the consent was vitiated by deceit from the outset.
Distinction Between Breach of Promise and False Promise:
The Court emphasized the distinction between a mere breach of promise and a false promise of marriage. It stated that for an accused to be held liable for rape, there must be evidence that he never intended to marry the complainant from the beginning. The Court quoted from Deepak Gulati v. State of Haryana:
“Consent may be express or implied, coerced or misguided, obtained willingly or through deceit. Consent is an act of reason, accompanied by deliberation, the mind weighing, as in a balance, the good and evil on each side. There is a clear distinction between rape and consensual sex.”
The Court also noted that the complainant had, on multiple occasions, portrayed herself as the appellant’s wife, further weakening her claim that the relationship was based on a false promise of marriage.
The Supreme Court allowed the appeal, quashing the FIR and all related proceedings. The judgment reaffirms the principle that a prolonged consensual relationship cannot be deemed rape unless there is clear evidence of mala fide intent from the outset.
Case Title: RAJNISH SINGH @ SONI VERSUS STATE OF U.P. AND ANOTHER
