The Supreme Court of India in a recent case addressed a critical issue concerning allegations of rape based on a false promise of marriage. The judgment is a yet another important precedent in distinguishing between consensual relationships and cases of sexual exploitation under deceit.

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Facts/ Headnote

The complainant is a highly qualified woman with M.Com and B.Ed degrees. The complainant alleged that the appellant Rajnish Singh had sexually exploited her under the false pretext of marriage for 16 years. The relationship began in 2006 when the appellant allegedly coerced her into a sexual act and later pacified her with assurance to marry the complainant.

The complainant claimed she was subjected to threats, blackmail, and financial exploitation. She eventually filed a complaint when the appellant married another woman in 2022.

The central issue revolved around whether the prolonged sexual relationship could be considered rape under Section 376 IPC if the consent was obtained under a false assurance of marriage. The FIR was lodged 16 years after the alleged first incident which raised concerns as to the credibility of the claims.

Interestingly, the complainant’s own actions, including voluntarily meeting with the accused, portraying herself as his wife, and maintaining the relationship for over a decade, indicate towards a consensual association rather than coercion.

The Supreme Court promptly noted the inconsistencies in the complainant’s narrative, especially regarding the alleged forceful nature of the relationship and her independent choices over the years.

Supreme Court’s Findings

The Court reaffirmed the stance that prolonged relationships are not an indicator of the offence of rape. In its observations, it stated;

“It is hard to believe that the complainant, being a highly qualified and well-placed major woman, kept on bending to the demands of the appellant for a period of nearly 16 years without raising any protest to any quarter that the appellant was exploiting her sexually under the pretext of a false promise of marriage.”

The Court applied principles from Mahesh Damu Khare v. State of Maharashtra (2024) and Deepak Gulati v. State of Haryana (2013), holding that sexual relationships must be directly traceable to a false promise. A long-term consensual relationship does not meet this criterion.

The Court also expressed its susceptibility in accepting the view that the appellant had brought criminal force and coercion for his perusal to exploit the complainant since the evidence brought does not establish a case beyond reasonable doubt. The Court remarked;

“Throughout the prolonged period of 16 years, the complainant kept completely quiet about the alleged sexual abuse, meted out to her by the appellant until she learnt that the appellant had married another woman.”

The complainant’s allegations of physical assault, threats, and forced abortion lacked substantive evidence. The police investigation had already dropped charges under Section 313 IPC (causing miscarriage) which further weakened the claims made by the complainant.

The Court also remarked that a mere breach of promise does not amount to the offense of rape, stating;

“There is a distinction between rape and consensual intercourse. Mere breach of a promise does not equate to a false promise unless the accused’s mala fide intent is established from the very inception of the relationship.”

The Court reiterated that a failed relationship or broken promise to marry does not automatically amount to sexual exploitation unless mala fide intent is established.

The Court despised the delay caused in lodging the FIR and worriedly remarks;

“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 highlighted that prolonged silence and delayed FIRs irretrievably weaken the credibility of allegations.

The Court in this case also highlighted prejudiced use of rape provisions, and said;

“While laws against sexual offenses are crucial for protecting victims, the Court must remain cautious of cases where allegations of rape are misused as a tool to settle personal scores.”

The judgment ensures that false accusations do not dilute genuine cases.The Court also highlighted that no reasonable person would accept that the complainant maintained the relationship purely under the misconception of marriage.

The Supreme Court quashed the FIR and subsequent proceedings, categorizing the case as an abuse of legal provisions.

CASE DETAILS: Rajnish Singh @ Soni vs State of Uttar Pradesh, 2025 LiveLaw (SC) 279

About Author

Tanishq, a law student at the Department of Legal Studies and Research, Barkatullah Vishwavidyalaya, Bhopal, is a budding legal writer with a sharp eye for evolving legal landscapes. Passionate about Intellectual Property Rights, Constitutional Law, and Women and Child Safety Laws, Tanishq actively explores contemporary legal nuances through writing and research