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Prashant vs. State of NCT of Delhi

Not available · 2024 INSC 879Decided 20 Nov 2024
Not available
Justice B.V. Nagarathna · Justice Nongmeikapam Kotiswar Singh

Background

The complainant and the appellant were in a relationship from 2017 that included consensual meetings over roughly two years, during which they also discussed marriage. After the appellant married someone else in 2019, the complainant filed an FIR in 2019 alleging that he had forced a sexual relationship on her under threat, and had refused to marry her. The Delhi High Court declined to quash the FIR, holding the allegations were sufficient to disclose an offence. The appellant approached the Supreme Court seeking quashing of the FIR and the resulting criminal proceedings.

Decision Breakdown

The Supreme Court held that, taking the FIR and the complainant's statement at face value, the relationship was consensual throughout: the parties met repeatedly over two years, the complainant voluntarily shared her address, and both parties at one point intended to marry. It found no evidence that any promise of marriage was made at the outset specifically to obtain her consent, and by the time the complainant filed the FIR both parties had since married other people. Applying the Bhajan Lal guidelines on when FIRs may be quashed to prevent abuse of process, the Court held the ingredients of rape under Section 376(2)(n) IPC and criminal intimidation under Section 506 IPC were not made out, and allowed the appeal, quashing the FIR, chargesheet, and pending trial.

Lesson Learnt

A consensual relationship that later ends does not automatically become a criminal offence merely because one party feels aggrieved by the breakup; criminal law requires that the essential ingredients of the specific offence (such as a false promise of marriage made in bad faith at the very outset) actually be established, even at the FIR stage.

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

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