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Rape: No allegation that promise of marriage was made to induce sexual relationship not a rape

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Rape: No allegation that promise of marriage was made to induce sexual relationship not a rape

Supreme Court Quashes Rape Case, Says Complaint Appeared to Be Counterblast to Pressure Marriage - Top court finds consensual relationship, no promise to marry at inception, and holds that continuing proceedings would amount to abuse of process.


The Supreme Court has quashed a criminal case alleging rape, refusal to marry, assault and criminal intimidation, holding that the dispute arose out of a consensual relationship that later turned sour and was being used to pressure the accused into marriage.


A Bench of Justice J.B. Pardiwala and Justice K. Vinod Chandran allowed the appeal filed by Sachin Gupta and set aside the Chhattisgarh High Court’s refusal to quash the FIR and charge-sheet. The Court said the materials on record showed that the relationship between the parties had been consensual and that there was no allegation that a promise of marriage had been made from the beginning to induce the complainant into a sexual relationship.


The complainant had alleged that the accused raped her on 5 May 2024 after taking her in a car and intoxicating her, and later expressed a desire to marry her so that she would not report the incident. She also claimed that she became pregnant twice and that the pregnancies were aborted. Further allegations included an assault in a hotel room on 29 October 2025, threats of circulation of intimate videos, and intimidation by the accused’s relatives.


However, the Supreme Court noted several circumstances that, in its view, undermined the prosecution version. The Court pointed out that the parties had known each other through the bank where the complainant worked, that the relationship continued for a long period after the alleged incident, and that the complainant herself stated that the accused’s desire to marry was expressed only after the alleged rape, not as an inducement before the sexual relationship began.


The Bench also took note of the appellant’s claim that the complainant had been pressuring him for money and that he had already lodged two complaints against her before the FIR in question. The Court observed that the complaint was lodged after more than one and a half years and appeared to have been filed to coerce the accused into marrying the complainant.


Relying on its earlier decision in Pradeep Kumar Kesarwani v. State of Uttar Pradesh and the principles laid down in Rajiv Thapar v. Madan Lal Kapoor, the Court reiterated that while considering a plea for quashing, courts must examine whether the accused has produced material of sterling and impeccable quality, whether it rules out the allegations, whether it is unrefuted, and whether continuing the trial would amount to abuse of process.


Applying those principles, the Bench concluded that the case did not disclose a sustainable allegation of rape on the promise of marriage. It held that the alleged assault in the hotel was never reported by hotel staff or the complainant at the time, the alleged threats by relatives


Bottom Line:

Alleging rape and refusal to marry - Where materials showed consensual relationship, no allegation that promise of marriage was made to induce sexual relationship, complaint was lodged after long delay and appeared to be filed to coerce accused into marriage - Supreme Court held that continuation of criminal proceedings would be abuse of process and quashed FIR, charge-sheet and consequential proceedings.


Sachin Gupta v. State of Chhattisgarh, (SC) : Law Finder Doc id # 2990915

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