Facts Of The Case:
The appellant, an advocate, met the complainant (respondent No.2) in January 2022 while she was engaged in a maintenance case against her estranged husband. They developed a close relationship and engaged in a consensual physical relationship over three years, during which she became pregnant multiple times and underwent abortions. The complainant alleged the appellant established relations on a false pretext of marriage and later refused to marry her, also threatening her. Based on this, an FIR was registered under Sections 376, 376(2)(n), and 507 IPC. The appellant, granted anticipatory bail, filed for quashing the FIR, which the High Court refused, noting a chargesheet was filed and a fiduciary relationship existed. In appeal, the Supreme Court examined whether the relationship was consensual or based on a mala fide false promise of marriage warranting criminal liability for rape.
Procedural History:
The case originated with the registration of FIR No. 294 of 2024 at City Chowk Police Station for offences under Sections 376, 376(2)(n), and 507 IPC. The appellant was granted anticipatory bail by the Additional Sessions Judge, Aurangabad. After investigation, a chargesheet was filed. The appellant then filed Criminal Application No. 601 of 2025 before the Bombay High Court at Aurangabad under Section 528 of the BNSS (akin to Section 482 CrPC) seeking quashing of the FIR. The High Court dismissed the application, primarily on the grounds that a chargesheet had been filed, the matter was ripe for trial, and the relationship could be fiduciary. Aggrieved, the appellant approached the Supreme Court by way of Special Leave, which granted leave and, after hearing, allowed the appeal, quashing the FIR and the chargesheet.
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Court Observation:
The Supreme Court observed that the relationship between the parties, spanning three years, was prima facie consensual. It noted the absence of any immediate complaint, the voluntary meetings at hotels, and the complainant’s own resistance to the idea of marriage due to her subsisting wedlock. The Court emphasized that for a “false promise of marriage” to vitiate consent under Section 90 IPC and constitute rape, it must be proven that the promise was mala fide and made with no intention to marry from the very inception. Relying on precedents like Mahesh Damu and Prashant, the Court held that not every breach of a promise to marry qualifies as rape, and criminalizing a soured consensual relationship amounts to an abuse of the legal process. The allegations, even taken at face value, did not disclose the essential ingredients for offences under Sections 376 or 507 IPC.
Final Decision & Judgement:
The Supreme Court allowed the appeal and set aside the impugned order of the Bombay High Court. Consequently, FIR No. 294 of 2024 and the accompanying Chargesheet No. 143 of 2024 were quashed. The Court held that the allegations, even accepted in their entirety, did not prima facie constitute the offences of rape or criminal intimidation, as the physical relationship was consensual and not induced by a mala fide false promise from the inception. The continuation of prosecution was deemed a gross abuse of the process of law.
Case Details:
Case Title: Samadhan S/o Sitaram Manmothe vs. State of Maharashtra & Another Citation: 2025 INSC 1351 Criminal Appeal No.: Criminal Appeal No. 5001 of 2025 Date of Judgement: November 24, 2025 Judges/Justices: Justice B.V. Nagarathna and Justice R. Mahadevan
Download The Judgement Here