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Pramod Kumar Navratna v. State of Chhattisgarh & Others

Criminal Appeal · 2026 INSC 124Decided 5 Feb 2026
Crl.A. No.-000693-000693 - 2026
Justice B.V. Nagarathna · Justice Ujjal Bhuyan

Background

The complainant, a married woman with a young son and a divorce case pending, met the appellant (both were advocates) at a social event in 2022 and began a relationship with him. In 2025 she filed an FIR alleging he had raped her repeatedly on a false promise of marriage, and later got her pregnant and pressured her to abort. The appellant denied the allegations, claimed the relationship was consensual, and said he was himself being harassed and blackmailed by her. The Chhattisgarh High Court refused to quash the FIR and chargesheet, so the appellant approached the Supreme Court.

Decision Breakdown

The Supreme Court held that no case of rape by false promise of marriage was made out because, given that the complainant was already married throughout the relationship, any "promise" of marriage to her would have been legally void and unenforceable from the outset under Section 5 of the Hindu Marriage Act, 1955, which bars a second marriage while a spouse is living. Since both parties knew of her married status from the earliest meetings, her claim of being deceived into consent could not stand: consent and the alleged deception were mutually contradictory on these facts. Relying on precedents distinguishing a "false promise" from a mere "breach of promise," and on the principle that consensual relationships turning acrimonious should not be criminalised, the Court found the case fell squarely within the categories in State of Haryana v. Bhajan Lal where quashing is warranted. The FIR, chargesheet, and the resulting Sessions Case were accordingly quashed and the appeal allowed.

Lesson Learnt

A promise of marriage made to someone who is already legally married to another person cannot form the basis of a "rape by false promise" prosecution, since such a promise could never have been legally fulfilled in the first place; courts will not allow the criminal justice system to be used to punish a consensual relationship that has simply soured.

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

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