Supreme Court Quashes Rape Charges in False Marriage Promise Case: Key Legal Analysis
In a significant ruling, the Supreme Court of India recently set aside rape charges against a man accused of establishing physical relations on false promises of marriage. The case of Jaspal Singh Kaura vs The State of NCT of Delhi & Anr. revisits the legal distinction between breach of promise and false promise in sexual consent cases under Section 376 IPC.
Case Background
The dispute originated from FIR No. 281/2021 registered at PS Sagarpur, where Respondent No. 2 (the complainant) alleged that:
- The appellant had known her since 2011 before their respective marriages
- Their relationship rekindled in 2016 when both were experiencing marital discord
- Physical relations began in February 2017 after the appellant promised marriage post-divorce
- She divorced her husband in 2019 based on this assurance
- The appellant later refused marriage and allegedly threatened her children in May 2021
Legal Proceedings
The trial court had discharged the appellant in June 2023, observing:
“consent by prosecutrix was very well reasoned and was given after understanding the nature and consequence of sexual indulgence and not out of any misconception of fact.”
However, the Delhi High Court reversed this decision in January 2024, noting prima facie material existed to frame charges under Sections 376/506 IPC.
Supreme Court’s Analysis
The bench comprising Justices B.V. Nagarathna and Satish Chandra Sharma extensively analyzed the legal principles:
1. Consent vs False Promise
The Court cited its precedent in Naim Ahmed vs State (NCT) of Delhi (2023):
“There is a difference between giving a false promise and committing breach of promise by the accused. In case of false promise, the accused right from the beginning would not have any intention to marry the prosecutrix… whereas in case of breach of promise, one cannot deny a possibility that the accused might have given a promise with all seriousness to marry her.”
2. Maturity of Parties
The judgment emphasized:
“The prosecutrix being a married woman and the mother of three children was mature and intelligent enough to understand the significance and the consequences of the moral or immoral quality of act she was consenting to.”
3. Prolonged Relationship Factor
The Court noted the relationship continued for five years (2016-2021), observing:
“The prolonged period of the relationship, during which the sexual relations continued between the parties, is sufficient to conclude that there was never an element of force or deceit in the relationship.”
Key Findings
- The physical relationship was consensual without evidence of dishonest inducement
- No material established criminal intimidation under Section 506 IPC
- The appellant’s actions (like gifting a mangalsutra) indicated initial marriage intent
- The complainant was in a subsisting marriage during most of the relationship
Final Ruling
The Supreme Court allowed the appeal, setting aside the High Court’s order and restoring the trial court’s discharge decision. The Court concluded:
“A bare review of the FIR and the charge-sheet and material placed on record by the prosecution, would clarify that the ingredients of offences under Section 375/506 IPC are not established.”
The judgment clarifies that not every broken marriage promise constitutes rape, distinguishing between genuine relationship breakdowns and predatory deception from the outset.
Petitioner Name: Jaspal Singh Kaura.Respondent Name: The State of NCT of Delhi & Anr..Judgment By: Justice B. V. Nagarathna, Justice Satish Chandra Sharma.Place Of Incident: Delhi.Judgment Date: 06-04-2025.Result: allowed.
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