Rape - Evidence of consensual relationship and no false promise of marriage - Acquittal upheld

Chhattisgarh High Court Upholds Acquittal in False Promise of Marriage Case. Court Finds No Cogent Evidence of Misconduct, Cites Consensual Relationship and Delay in FIR as Key Factors

In a significant judgment, the Chhattisgarh High Court has upheld the acquittal of an accused charged with sexual intercourse under the false pretext of marriage. The case, which was brought forward by the appellant, ABC, against the State of Chhattisgarh, involved allegations against respondent No.2, who was accused of establishing physical relations with the victim by falsely promising marriage.

The division bench, comprising Justices Sanjay S. Agrawal and Radhakishan Agrawal, delivered the judgment on November 10, 2025, reaffirming the verdict of the Additional Sessions Judge, South Bastar, Dantewada. The trial court had earlier acquitted the accused of charges under Sections 376(2)(n) and 313 of the Indian Penal Code (IPC).

The High Court examined the evidence, which revealed a consensual relationship between the victim and the accused. The victim, in her deposition, admitted that she had voluntarily consented to the physical relations and that the accused had not coerced her. Furthermore, the court noted the significant delay in lodging the First Information Report (FIR), which was filed three years after the alleged incidents, undermining the credibility of the allegations.

The appellate court emphasized the legal principle of "double presumption of innocence" in acquittal appeals, asserting that an acquittal strengthens the presumption of innocence and necessitates thorough scrutiny for reversal. The court found no substantial evidence to overturn the trial court's decision, highlighting the absence of any signs of injury reported by the medical examination and the lack of support from other witnesses.

The judgment also referenced previous Supreme Court decisions, illustrating the stringent criteria required for appellate interference in acquittal cases. Despite the appellant's reliance on landmark cases, the High Court found them inapplicable due to factual distinctions.

With this decision, the High Court reinforces the importance of cogent evidence and timely reporting in cases involving allegations of sexual misconduct under false pretenses. The judgment underscores the judiciary's cautious approach in overturning acquittals, ensuring that justice is served while upholding the presumption of innocence.

Bottom Line:

Appeal against acquittal in cases of alleged sexual intercourse under false pretext of marriage - Evidence revealed a consensual relationship and no false promise of marriage - Acquittal upheld due to lack of cogent and reliable evidence.

Statutory provision(s): Sections 376(2)(n), 313 of the Indian Penal Code, 1860; Section 378 of the Criminal Procedure Code, 1973

ABC (Victim) v. State Of Chhattisgarh, (Chhattisgarh)(DB) : Law Finder Doc Id # 2806234