'Instagram Friendship Led to Consensual Relationship’: SC Quashes Rape Case

Post By 24law
February 15, 2025

Pranav B Prem

The Supreme Court recently quashed criminal proceedings against a man accused of rape on the pretext of a false promise of marriage, ruling that the relationship stemmed from mutual attraction and was consensual. The Court held that the facts of the case did not establish that the accused had given an inherently false promise of marriage to induce physical relations.

Background of the Case

A bench of Justices Vikram Nath and Sandeep Mehta allowed the appeal filed by Manish Yadav, challenging the summoning order issued by the Special Court, Ghazipur, on August 24, 2023. The accused was charged under Sections 376, 323, 504, and 506 of the IPC and Sections 3(1)(r), 3(1)(s), 3(2)(5a), and 3(2)(v) of the SC/ST Act. The complainant had alleged that she met the accused on Instagram, and their friendship soon turned into a romantic relationship. She claimed that Yadav had assured her that they would marry and live together as husband and wife. On this premise, she engaged in a physical relationship with him at various locations, including Ghazipur and Varanasi.

Court’s Observations

Examining the complainant’s statement recorded under Section 164 of the CrPC, the Court noted: "We find that she had herself admitted that despite her reservations about engaging in a physical relationship with the appellant, she trusted him and had feelings for him."

The Court further observed that, as per the prosecution, the complainant had moved to Varanasi for work in September 2022, while the appellant relocated to Prayagraj. Despite the physical distance, he continued visiting her in Varanasi. In December 2022, she discovered her pregnancy, which the accused allegedly pressured her to terminate. However, the Court found no substantial evidence proving that the appellant had forced the complainant to terminate the pregnancy. Consequently, the charge under Section 313 IPC was dropped from the charge sheet.

Analysis of Consent and False Promise of Marriage

Referring to previous judgments, including Uday v. State of Karnataka (2003), Deepak Gulati v. State of Haryana (2013), and Deelip Singh v. State of Bihar (2005), the bench reiterated that there is a clear distinction between a breach of promise and an inherently false promise. The Court stated: "While it can be said that initially the relationship between the complainant and appellant had developed on the basis of mutual attraction and affection, which cannot by any stretch of imagination fall within the ambit of a relationship flowing from a promise to marry."

The Court also noted that the complainant, at one stage, had refused the appellant’s offer to elope and insisted on waiting until he secured a job. This, the Court opined, contradicted the claim that the appellant induced the complainant into a physical relationship by falsely promising marriage.

SC/ST Act Allegations Unsubstantiated

The complainant also alleged that the accused used caste-based slurs and refused to marry her due to her caste. However, after reviewing her statement, the Court observed: "The complainant has not uttered a single word which shows that she was maligned or abused by the appellant for belonging to a particular caste." Accordingly, the Court ruled that the SC/ST Act charges were not made out from the allegations in the charge sheet.

Verdict

The Supreme Court found that the complainant and appellant were consenting adults who voluntarily engaged in a relationship. The Court held that allowing the prosecution to proceed would amount to an abuse of the legal process, stating: "Hence, allowing the prosecution of the appellant for the offences mentioned above would tantamount to sheer abuse of the process of law and nothing else." Consequently, the Court quashed the summoning order and all proceedings against the appellant, emphasizing that not every failed relationship can be criminalized under allegations of a false promise of marriage.