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Ajeet Singh vs. State of Uttar Pradesh

Not available · 2024 INSC 5Decided 3 Jan 2024
Not available

Background

A woman's father lodged an FIR in 2015 alleging that the appellant had a physical relationship with his daughter on a false promise of marriage, prepared a fake marriage certificate to pressure her, and then abandoned her. The appellant had sought to quash the FIR before the Allahabad High Court (Lucknow Bench), which declined to exercise its extraordinary jurisdiction. However, the record showed that a genuine marriage certificate from an Arya Samaj Mandir existed, a legal notice sent by the woman's own lawyer described her as the appellant's wife, and the appellant had filed a petition for restitution of conjugal rights under the Hindu Marriage Act before the FIR was even lodged.

Decision Breakdown

The Supreme Court examined the record, including the woman's own statement to police describing a consensual relationship culminating in marriage, and the notice issued on her behalf admitting the marriage, and found that no prudent person could conclude, on these facts, that the relationship was based on a false promise to marry rather than a genuine (if troubled) marriage. Applying the settled test from State of Haryana vs. Bhajan Lal for when an FIR should be quashed (where allegations, even if taken at face value, do not disclose an offence), the Court held this was a fit case for quashing. It set aside the High Court's order and quashed the FIR, allowing the appeal.

Lesson Learnt

A criminal case for "rape on false promise of marriage" cannot stand where the evidence itself shows that a marriage was actually solemnized. Courts will look past the label of the FIR to the substance of the material on record before allowing a criminal prosecution to proceed.

Official source (sci.gov.in)View Judgment (PDF)

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