In this judgment, the Supreme Court exercised its plenary power under Article 142 of the Constitution to quash an entire criminal proceeding, including the conviction and sentence, to secure complete justice. The Court reasoned that since the parties had married and were residing together, continuing the prosecution would be counterproductive. Consequently, the pending appeal before the High Court was rendered infructuous.
Facts Of The Case:
The appellant and the prosecutrix first connected in 2015 through a social media platform, where they developed a mutual fondness for each other. This relationship eventually progressed into a consensual physical relationship, which the prosecutrix later claimed was based on the appellant’s alleged false promise of marriage. When the appellant sought to postpone the marriage date, it created a sense of insecurity in the prosecutrix’s mind, leading her to file FIR No.29 of 2021 on November 2, 2021, at the Women Police Station, District Sagar, under Sections 376 and 376(2)(n) of the Indian Penal Code.Following investigation, a chargesheet was filed on February 8, 2022, and the appellant was tried before the Additional Sessions Judge in Sessions Trial No.191 of 2022. The trial court convicted him under Sections 376(2)(n) and 417 IPC, sentencing him to ten years of rigorous imprisonment with a fine of Rs.50,000 for the rape charge, and two years rigorous imprisonment with a fine of Rs.5,000 for the charge of cheating. Aggrieved by this conviction, the appellant filed Criminal Regular Appeal No.4869 of 2024 before the Madhya Pradesh High Court at Jabalpur, along with I.A. No.9352 of 2024 seeking suspension of his sentence pending appeal. When the High Court rejected this suspension application on April 5, 2024, the appellant approached the Supreme Court by way of special leave petition, which forms the basis of this judgment.
Procedural History:
The procedural journey of this case began with the filing of FIR No.29 of 2021 on November 2, 2021, at the Women Police Station, District Sagar, leading to the filing of a chargesheet on February 8, 2022. The appellant was tried before the First Additional Sessions Judge, Sagar, in Sessions Trial No.191 of 2022, resulting in a conviction on April 12, 2024, under Sections 376(2)(n) and 417 IPC, with a sentence of ten years rigorous imprisonment.Aggrieved by this conviction, the appellant preferred Criminal Regular Appeal No.4869 of 2024 before the Madhya Pradesh High Court at Jabalpur. During the pendency of this appeal, he filed I.A. No.9352 of 2024 seeking suspension of his jail sentence, which was rejected by the High Court on April 5, 2024. This rejection prompted the appellant to approach the Supreme Court by way of special leave petition, giving rise to Criminal Appeal No.5256 of 2025.During the proceedings before the Supreme Court, a unique development occurred. On May 6, 2025, the Court suggested exploring the possibility of marriage between the parties, leading to their appearance before the Court in chambers on May 15, 2025, where they unequivocally stated their willingness to marry. Consequently, the Court suspended the sentence and granted bail. The marriage was solemnized on July 22, 2025, and on July 25, 2025, the Court stayed the conviction to enable the appellant to rejoin government service, ultimately leading to the final disposal on December 5, 2025.
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Court Observation:
The Supreme Court made several significant observations while disposing of this matter. The Court noted that this was “one of those rare cases” where an application seeking suspension of sentence ultimately resulted in the quashing of both conviction and sentence through judicial intervention. The Court observed that it developed a “sixth sense” that the appellant and prosecutrix could be brought together if they decided to marry each other, prompting the suggestion to explore this possibility.The Court further observed that the relationship between the parties was essentially consensual in nature, which had been given a “criminal colour” and converted into an offence of false promise of marriage owing to misunderstandings. According to the Court, the parties had actually intended to marry each other, and it was only the appellant’s request for postponement of the marriage date that may have led to insecurity in the prosecutrix’s mind, resulting in the criminal complaint. The Court expressed satisfaction with the outcome, noting that both parties were residing together happily and their parents were pleased with this development. The Court emphasized that continuing criminal proceedings in such circumstances would be counterproductive and against the interests of justice, particularly when the prosecutrix herself submitted that the proceedings should not continue. These observations formed the foundation for the Court’s invocation of its extraordinary powers under Article 142 of the Constitution to do complete justice in the matter.
Final Decision & Judgement:
In its final judgment delivered on December 5, 2025, the Supreme Court disposed of Criminal Appeal No.5256 of 2025 by invoking its plenary powers under Article 142 of the Constitution of India to secure complete justice between the parties. Taking note of the significant developments that had transpired during the pendency of the appeal—particularly the solemnization of marriage between the appellant and the second respondent on July 22, 2025, and their subsequent cohabitation as husband and wife—the Court quashed FIR No.29 of 2021 dated November 2, 2021, lodged with the Women Police Station, District Sagar. Additionally, the Court quashed the judgment of conviction and sentence dated April 12, 2024, passed by the First Additional Sessions Judge, Sagar, in Sessions Trial No.191 of 2022. Consequently, the Court declared that Criminal Regular Appeal No.4869 of 2024, pending before the Madhya Pradesh High Court, was rendered infructuous by virtue of this order.The Court further addressed the service-related consequences arising from the criminal proceedings. Recognizing that the appellant had been suspended from his government employment owing to the criminal complaint and subsequent conviction, the Court issued directions to the Chief Medical Officer (CMO), Sagar, Madhya Pradesh, to facilitate the revocation of suspension and ensure the appellant’s rejoining of duty. The Court specifically directed that all arrears of salary accrued during the suspension period be paid to the appellant within two months from the date of the judgment. All pending applications, if any, were also disposed of in terms of this final order.
Case Details:
Case Title: Sandeep Singh Thakur versus State of Madhya Pradesh & Another Citation: 2025 INSC 1499 Criminal Appeal No.: Criminal Appeal No.5256 of 2025 Date of Judgment: December 5, 2025 Bench / Judges: Justice B.V. Nagarathna and Justice Satish Chandra Sharma
Download The Judgement Here