Supreme Court: Sour Relationship Not Ground for Rape Charge on False Marriage Promise
The Supreme Court, in Amol Bhagwan Nehul v. State of Maharashtra & Ors., held that a consensual relationship turning sour or partners parting ways cannot justify invoking rape charges on the ground of a false promise of marriage. The Bench of Justices BV Nagarathna and Satish Chandra Sharma noted that such cases misuse the criminal justice system, overburden courts, and unfairly tarnish the reputation of the accused. Reiterating previous concerns, the Court emphasized that not every breach of a marriage promise amounts to a false promise warranting prosecution under Section 376 IPC.
5/30/20251 min read
In the case of Amol Bhagwan Nehul v. State of Maharashtra & Ors., the appellant challenged the criminal proceedings initiated against him under Section 376 of the Indian Penal Code (IPC) for rape on the alleged ground of a false promise of marriage. The complainant claimed that the sexual relationship was consensual but based on a promise to marry, which the accused later failed to fulfill. The case arose after the relationship between the parties deteriorated and they separated.
The Supreme Court examined the increasing trend of misuse of rape laws in cases involving failed romantic relationships. The Bench, comprising Justice BV Nagarathna and Justice Satish Chandra Sharma, observed that:
A consensual relationship that later turns sour or results in separation cannot automatically be construed as rape.
The Court emphasized that criminal law cannot be used as a tool of vengeance when a personal relationship ends.
It reiterated its previous stance that not every breach of a promise to marry constitutes a false promise, and Section 376 IPC should not be invoked lightly in such cases.
The Court warned that such misuse leads to miscarriage of justice, damages the accused’s reputation, and clogs the judicial system with cases lacking criminal intent.
The Supreme Court held that the allegations made by the complainant did not disclose the commission of rape, as the sexual relationship appeared consensual and not induced by any fraudulent or dishonest promise. The Court concluded that:
There was no material to show any intention to deceive from the beginning of the relationship.
Filing of rape charges in such scenarios amounts to abuse of process and unjustified criminalization of a failed relationship.
The Supreme Court reaffirmed that failed consensual relationships should not be criminalized under the guise of false promises of marriage. It cautioned against treating personal disputes as criminal offences, especially when they arise from emotional breakdowns rather than deceit or coercion. This judgment serves as a significant reminder of the need for judicial restraint in such sensitive matters and ensures the protection of individuals from unwarranted criminal prosecution.