Madhya Pradesh High Court Rules on Rape Allegations in Consensual Relationships

The Madhya Pradesh High Court recently addressed the legal implications of long-term consensual relationships that do not culminate in marriage. In a significant ruling, the Court quashed a criminal case of rape filed against a man accused of making a false promise of marriage.

Justice Sanjay Dwivedi emphasized that a woman cannot allege rape merely because a consensual relationship did not lead to marriage. The Court noted that the accused and the complainant had engaged in a ten-year relationship out of mutual consent but eventually separated as the man did not wish to marry. This decision aligns with previous rulings by the Supreme Court and other High Courts, which have held that such relationships cannot be classified as rape.

The complainant had claimed that during their relationship, which began in high school and included physical relations until 2020, the accused had promised to marry her. When the relationship ended in 2021 without marriage, the complainant filed a rape charge against the accused.

Justice Dwivedi highlighted that youthful impressions and emotional engagements often lead individuals to believe that their relationships will naturally result in marriage. However, when such relationships fail, it does not constitute grounds for a rape charge.

The High Court scrutinized the timeline and nature of the relationship. It observed that if the physical relationship had indeed started on the pretext of marriage in 2010, the complainant had ample opportunity to file a complaint at that time. The continued relationship until 2020, without any complaint until the refusal to marry in 2021, suggested that the physical relationship was consensual rather than based on a false promise.

The Court distinguished between a false promise of marriage and a genuine breach of promise. It noted that various circumstances might prevent an individual from fulfilling a marriage promise, and in such cases, it cannot be said that the woman entered into a physical relationship under a misconception of fact.

Justice Dwivedi reiterated that Section 90 of the Indian Penal Code (IPC), which addresses consent under a misconception of fact, could not be applied to pardon the actions of an individual who engages in a consensual relationship believing it will lead to marriage.

Ultimately, the Court allowed the petition and quashed the criminal case against the accused, concluding that the relationship, being consensual and lasting over ten years, did not fit the definition of rape under Section 375 of the IPC. The Court found that the complainant's consent for a physical relationship was not obtained through a false pretext of marriage.

This ruling underscores the legal distinction between consensual relationships and allegations of rape, emphasizing the need for clear evidence of false promises when filing such serious charges.

Author: Anushka Taraniya

News writer