Court rules that a prolonged consensual relationship cannot be criminalized as rape on the grounds of a broken promise to marry.
In a significant ruling, the Allahabad High Court, presided over by Justice Vivek Kumar Singh, has quashed the criminal proceedings against Lokendra Singh accused of rape under the guise of a false promise of marriage. The judgment, dated June 18, 2026, highlighted the consensual nature of the relationship between Lokendra Singh and the complainant, asserting that such relationships cannot be criminalized based on a subsequent failure to fulfill a marriage promise.
The case arose from an FIR filed on March 2, 2024, by the complainant, alleging that Lokendra Singh had established a sexual relationship with her based on a false promise of marriage. The complainant and Lokendra Singh had been in a relationship for over a year and a half, during which they engaged in sexual relations multiple times. However, issues arose when Lokendra Singh decided to marry another woman, leading to the complaint.
The High Court, referencing numerous precedents from the Supreme Court, emphasized that consensual relationships that later turn sour do not automatically amount to rape. The court underscored that for a rape charge to be sustained, there must be clear evidence that the accused had no intention to marry from the beginning, and that the promise of marriage was a deceitful tactic to obtain consent.
Justice Singh further noted that the complainant was an adult who voluntarily engaged in the relationship, fully aware of its implications. The court observed that the complainant's allegations lacked the necessary elements to constitute rape, as there was no evidence of coercion or deceit at the inception of the relationship.
The judgment also highlighted the need for caution in criminalizing failed relationships, as doing so can lead to an abuse of the legal process and cause undue harm to the accused. The court concluded that continuing the proceedings would be an exercise in futility and a misuse of judicial resources.
This ruling serves as a reminder of the judiciary's role in distinguishing between genuine cases of sexual violence and those arising from personal grievances in failed relationships.
Bottom line:-
Criminal proceedings alleging rape based on a false promise of marriage cannot be sustained if the relationship was consensual, long-standing, and there is no evidence to suggest deceit or inducement from the inception of the relationship.
Statutory provision(s): Section 376, 504, 506 IPC; Section 528 BNSS; Section 164 Cr.P.C.
Lokendra Singh v. State of U.P., (Allahabad) : Law Finder Doc id # 2947287
