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Sandeep Singh Thakur vs. State of Madhya Pradesh & Anr.

Not available · 2025 INSC 1499Decided 5 Dec 2025
Not available
Justice B.V. Nagarathna · Justice Satish Chandra Sharma

Background

The appellant and the second respondent met on social media in 2015 and entered a consensual relationship; when the promised marriage did not take place, she filed an FIR alleging rape on a false promise of marriage. He was convicted by the trial court under Sections 376(2)(n) and 417 IPC and sentenced to ten years' rigorous imprisonment. While his appeal against the High Court's refusal to suspend his sentence was pending before the Supreme Court, the Court sensed the two could reconcile, facilitated dialogue between them and their families, and they eventually married on 22 July 2025 and began living together, with the FIR having been lodged in November 2021.

Decision Breakdown

After the marriage, the complainant (now the appellant's wife) told the Court she no longer wished the criminal proceedings to continue, and both sides asked that they be quashed. The Court held that a consensual relationship that was mischaracterised as a criminal false-promise offence, and which was later resolved through marriage, warranted the exercise of the Supreme Court's special power under Article 142 of the Constitution to do "complete justice." It quashed the FIR, the trial court's conviction and sentence, and rendered the pending High Court appeal infructuous. It also directed that the appellant's job suspension (which followed from the conviction) be revoked and his salary arrears paid within two months.

Lesson Learnt

The Supreme Court can use its special Article 142 power to end criminal proceedings that have effectively become moot due to reconciliation between the parties, especially in sensitive matters involving relationships, but this is an exceptional, case-specific remedy, not a general rule that marriage automatically erases a criminal charge.

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

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