Rajnish Singh @ Soni v. State of U.P.
Background
A woman filed an FIR in 2022 alleging that the accused had first forced himself on her in 2006 in her own home while her parents were present, and that a coercive relationship (including a later drugging incident, an obscene video used for blackmail, and a forced miscarriage) continued for about 16 years under a repeated promise of marriage. She only went to the police after learning the accused had married another woman in 2022. The Allahabad High Court refused to quash the criminal proceedings against him.
Decision Breakdown
The Supreme Court found the allegations implausible and internally contradictory: it was hard to believe forcible sex occurred undetected in the woman's own house with her parents present, and harder still to believe an educated, independent adult woman would silently endure alleged sexual exploitation for 16 years without ever reporting it until the relationship ended for other reasons. The Court noted she had at one point described herself as the accused's wife, and that both parties appeared to have lived as a couple, including informal marriage rituals. Applying its precedents (including Deepak Gulati v. State of Haryana and Shivashankar v. State of Karnataka), the Court held that a prolonged, voluntary sexual relationship generally cannot be re-characterised as rape based on a false promise of marriage unless the physical relationship is shown to be directly and solely traceable to a promise the accused never intended to keep from the very outset. Finding this was, at best, a long relationship that went sour, the Court quashed the FIR and all related proceedings as an abuse of the legal process.
Lesson Learnt
Criminal charges of rape based on a "false promise of marriage" require proof that the promise was false from the beginning and that it was the sole reason for the physical relationship: a long-running, voluntary intimate relationship that later ends badly is not, by itself, enough to sustain such a charge.