EMPOWERING LEGAL AWARENESS

EMPOWERING LEGAL AWARENESS

XXXX vs. State of Madhya Pradesh & Anr.

Not available · 2024 INSC 181Decided 6 Mar 2024

Not available

Justice C.T. Ravikumar · Justice Rajesh Bindal

Background

The complainant, a married woman with a teenage daughter, alleged that the appellant, her tenant, had a physical relationship with her from 2019 to 2020 on the promise of marriage, and filed an FIR under Section 376(2)(n) (rape) and Section 506 IPC when he later refused to marry her. The appellant sought to have the FIR quashed by the Madhya Pradesh High Court, arguing the allegations were an abuse of process, but the High Court dismissed his petition, leading to this appeal.

Decision Breakdown

The Supreme Court found major inconsistencies between the complainant's FIR and her later statement under Section 164 Cr.P.C., including contradictory dates for her divorce from her earlier husband, which records showed was actually finalized in January 2021, well after she claimed to have already "remarried" the appellant in a temple in January 2019. This meant the relationship, on her own admitted timeline, began and continued while she was still legally married to someone else. Relying on its precedent in Naim Ahamed v. State (NCT of Delhi), involving similar facts, the Court held that a mature, married woman who continues a long relationship cannot later claim the consent was obtained solely through a false promise to marry, especially when the "marriage" she claimed could not have legally occurred during the subsistence of her prior marriage. The Court quashed the FIR and all proceedings arising from it, allowing the appeal.

Lesson Learnt

Courts distinguish between rape by genuinely false promise of marriage and a consensual relationship between mature adults that later turns sour: inconsistent or provably false claims by a complainant (such as fabricated dates) can lead to an FIR being quashed at the threshold stage itself.

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

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