False Promise of Marriage and Rape Allegations: Supreme Court Quashes FIR Against Ajeet Singh

The Supreme Court of India, in its judgment dated 3 January 2024, addressed a crucial issue concerning allegations of rape on the pretext of marriage. The case, Ajeet Singh vs. State of Uttar Pradesh & Ors., revolved around whether a consensual relationship culminating in marriage could constitute rape under Section 376 of the Indian Penal Code (IPC).

Background of the Case

The case originated from an FIR registered at Naka Police Station, Lucknow, based on a complaint filed by the victim’s father. The allegations were that:

The victim, a 25-year-old woman preparing for banking exams, developed a relationship with Ajeet Singh, who ran IIT coaching classes in Delhi.
Singh assured the victim of marriage, and under this pretext, he maintained a physical relationship with her.
When the victim’s father approached Singh’s family for marriage, they refused.
Singh later obtained a certificate of marriage from Arya Samaj Mandir, allegedly to deceive the victim.
Singh eventually abandoned the victim at her father’s house on 22 April 2015.

The complaint was lodged on 27 May 2015, and an FIR was registered under Sections 376 (rape) and 506 (criminal intimidation) of the IPC.

Singh challenged the FIR before the Allahabad High Court (Lucknow Bench), seeking its quashing. However, the High Court dismissed the petition on 7 December 2016, declining to interfere in the investigation.

Petitioner’s Arguments

Singh’s defense, as presented before the Supreme Court, was:

The relationship was consensual and culminated in marriage on 16 February 2015 at Arya Samaj Mandir.
A legal notice dated 1 May 2015, issued by the victim’s lawyer, explicitly acknowledged the marriage.
Singh filed a petition for restitution of conjugal rights under Section 9 of the Hindu Marriage Act on 6 May 2015, demonstrating his commitment to the marriage.
The victim’s father filed the complaint after these events, indicating a malicious intent to harass Singh.
An investigating officer’s affidavit confirmed that the allegation of rape was not substantiated since a valid marriage existed.

Respondent’s Arguments

The State of Uttar Pradesh opposed the petition, arguing that:

Singh deceived the victim by obtaining a fraudulent marriage certificate to coerce her into a relationship.
The FIR disclosed offenses under Sections 376 and 506 IPC, warranting a full-fledged trial.

Supreme Court’s Ruling

The Supreme Court, comprising Justice Abhay S. Oka and Justice Pankaj Mithal, quashed the FIR and allowed Singh’s appeal.

Key observations included:

The victim’s legal notice acknowledged the marriage, stating, “On 16.02.2015, Ajeet Singh solemnized marriage with my client [the victim] at Arya Samaj Mandir.”
Singh’s petition for restitution of conjugal rights, filed before the complaint, contradicted the rape allegations.
The victim’s statement recorded on 23 November 2016 admitted to a physical relationship before marriage but confirmed cohabitation as husband and wife afterward.
The allegations in the FIR, when viewed in totality, did not make out a case under Section 376 IPC.
Since the relationship led to marriage, the charge of rape on the false promise of marriage could not be sustained.

The Court applied the principles laid down in State of Haryana vs. Bhajan Lal (1992 Supp (1) SCC 335), holding that:

“Where allegations in the FIR are so improbable that no prudent person can conclude that an offense has been committed, the FIR must be quashed.”

Accordingly, the Court quashed Case Crime No. 106 of 2016 registered at Naka Police Station, Lucknow.

Impact of the Judgment

This ruling reinforces key principles:

A consensual relationship culminating in marriage does not constitute rape.
An FIR can be quashed if the allegations are inherently improbable.
False promises of marriage must involve intentional deception at the outset to constitute rape.
The Court must safeguard individuals from malicious prosecution.

Conclusion

The Supreme Court’s decision in Ajeet Singh vs. State of Uttar Pradesh sets an important precedent on rape allegations based on false promises of marriage. The ruling underscores that relationships culminating in marriage cannot later be labeled as sexual exploitation. By quashing the FIR, the Court upholds the principle that criminal law should not be misused to settle personal grievances.

Petitioner Name: Ajeet Singh.
Respondent Name: State of Uttar Pradesh & Ors..
Judgment By: Justice Abhay S. Oka, Justice Pankaj Mithal.
Place Of Incident: Lucknow, Uttar Pradesh.
Judgment Date: 03-01-2024.

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