Bhopal, February 2025 – In a significant ruling, the Madhya Pradesh High Court has held that a married woman cannot claim that her consent for a physical relationship was obtained through a false promise of marriage. The judgment, which quashed a rape case filed by a married woman, has sparked debate in legal and social circles.
The Case at a Glance
The case in question revolved around a complaint lodged by a married woman, who accused a man of raping her under the pretext of marriage. She alleged that the man had promised to marry her and, relying on that promise, she had entered into a physical relationship with him. However, when the relationship soured and the promise was allegedly not fulfilled, she approached the authorities, leading to the registration of a case under Section 376 (rape) of the Indian Penal Code (IPC).
The accused moved the High Court, seeking quashing of the charges. He contended that the woman was already married, and hence, the promise of marriage was legally and practically untenable. The High Court, after hearing both parties, ruled in his favor, stating that a married woman cannot claim that she was deceived into giving consent based on a promise of marriage.
The Court’s Reasoning
The High Court bench, while delivering the verdict, emphasized certain key legal principles:
1. Consent Under Misconception of Fact – Under Section 90 of the IPC, consent obtained under a misconception of fact is not valid. However, the court reasoned that in cases where the complainant is already married, a promise of marriage lacks legal sanctity and cannot be considered a valid ground for alleging rape.
2. Knowledge of Marital Status – The court noted that the woman, being aware of her own marital status, could not reasonably believe in the possibility of a lawful marriage with the accused. Thus, her claim that she was misled into consent was legally unsustainable.
3. Abuse of Rape Laws – The bench highlighted that the misuse of rape provisions to settle personal scores or due to broken relationships is a rising concern. While the law aims to protect victims of sexual assault, it should not be weaponized to target individuals in consensual relationships that later turn sour.
Legal Precedents and Implications
The ruling aligns with previous judgments wherein courts have distinguished between genuine cases of rape and those arising from failed romantic relationships. Courts have consistently held that consensual relationships cannot be retrospectively termed as rape merely because they ended unfavorably for one party.
For instance, in Pramod Suryabhan Pawar v. State of Maharashtra (2019), the Supreme Court clarified that a breach of a promise to marry does not constitute rape unless the promise was made with no intention of being fulfilled from the very beginning. The MP High Court’s ruling further extends this principle by specifically addressing cases where the complainant is married.
Mixed Reactions from Legal and Social Circles
The judgment has triggered varied reactions. While legal experts view it as a step towards preventing misuse of rape laws, women’s rights activists have expressed concerns over its potential impact.
Legal Perspective:
Many lawyers have lauded the verdict for upholding the sanctity of consent in sexual relationships and preventing its misuse.
Some argue that it brings clarity to the often-misunderstood concept of consent in cases involving false promises of marriage.
Others point out that it reinforces the principle that criminal law should not be used as a tool for moral policing or personal vendettas.
Social Perspective:
Women’s rights groups fear that such rulings might discourage genuine victims from coming forward.
Some activists argue that the court should consider power imbalances in relationships, as promises—whether realistic or not—can influence a woman’s decision-making.
Others believe that while the judgment is legally sound, it highlights the need for broader social awareness about relationships, consent, and legal rights.
What This Means for Future Cases
The ruling sets a precedent for similar cases in the future. While it does not invalidate all claims of rape based on false promises of marriage, it makes a clear distinction where the complainant’s marital status renders such promises legally implausible.
For individuals involved in romantic relationships, this judgment reinforces the importance of understanding legal principles surrounding consent and false promises. It also underscores the judiciary’s focus on ensuring that criminal law is not misused for personal grievances.
Conclusion
The Madhya Pradesh High Court’s decision is a significant addition to the evolving legal discourse on consent, promises of marriage, and misuse of rape laws. While the judgment is being debated, it undeniably raises important questions about personal responsibility, legal awareness, and the fine line between betrayal and criminal liability.
As legal experts and activists continue to discuss its implications, one thing remains clear—understanding one’s rights and responsibilities in relationships is crucial. The law must strike a balance between protecting genuine victims and preventing its misuse, ensuring that justice is served fairly and equitably for all parties involved.
About Author
Kusha Mehta is a law student at Campus Law Centre, University of Delhi, with a background in economics. She has experience in legal research, writing, and analysis, with internships at NyayaSarthak and the International Institute of SDGs & Public Policy Research. Passionate about advocacy and policy, she has also completed certifications from Harvard University.
