Manish Yadav v. State of Uttar Pradesh & Anr.
Background
The complainant and the appellant met on Instagram and developed a romantic relationship that turned physical. She alleged he had promised to marry her, that she became pregnant and was forced to abort, and that he later abused her and used caste-based slurs, refusing to marry her because she belonged to a different caste. An FIR was registered under IPC provisions (including rape) and the SC/ST Act; the trial court summoned the appellant and his father, and the Allahabad High Court quashed the summons only as against the father, upholding it against the appellant.
Decision Breakdown
The Supreme Court examined the complainant's own Section 164 CrPC statement and found she had admitted the initial physical relationship was consensual, arising from mutual affection rather than any promise of marriage; it was in fact the appellant who suggested eloping and marrying, which the complainant declined pending his securing a job. Relying on precedents (Uday, Deepak Gulati, Deelip Singh), the Court reiterated the distinction between a "breach of promise" and a "false promise" to marry, only the latter, made with no genuine intention from the outset, can vitiate consent and sustain a rape charge. Finding no evidence of caste-based abuse in her own statement either, the Court held continuing the prosecution would be an abuse of process, quashed the summoning order and all proceedings against the appellant, and allowed the appeal.
Lesson Learnt
A consensual relationship between adults that later sours does not automatically become rape merely because a promised marriage did not happen: criminal liability requires proof that the promise was false and insincere from the very beginning, not just that it was later broken.