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Lalu Yadav vs. The State of Uttar Pradesh and Others

Not available · 2024 INSC 782Decided 16 Oct 2024
Not available
Justice C.T. Ravikumar · Justice Rajesh Bindal

Background

An FIR was registered against the appellant under Sections 376 (rape) and 313 (causing miscarriage without consent) of the IPC, based on a complaint alleging a relationship built on a false promise of marriage. The appellant sought quashing of the FIR before the Allahabad High Court under Article 226 of the Constitution, but the High Court dismissed his petition. He then appealed to the Supreme Court.

Decision Breakdown

The Supreme Court found that the material on record, including the complainant's own statements in the FIR that she had travelled with and stayed in hotels with the appellant with her family's knowledge, and had referred to him as her husband: pointed to a long, consensual physical relationship rather than sex obtained through a false promise to marry made at the very outset. The Court held that a subsequent refusal to marry does not, by itself, establish that consent was given under a "misconception of fact" within the meaning of rape law. Since the Section 313 IPC allegation had already been dropped and no prima facie case survived for Section 376, the Court held this was a fit case for the High Court to have exercised its inherent power under Section 482 CrPC to prevent abuse of the court's process. It set aside the High Court's order and quashed the FIR and all consequent proceedings.

Lesson Learnt

Not every broken promise to marry converts a consensual relationship into rape. Courts will look at whether the promise was false from the very beginning (used only to obtain consent) versus a relationship that was genuinely consensual and only later ended in a refusal to marry; only the former can sustain a rape charge based on "consent obtained by misconception of fact."

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

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