SC Reasserts Boundaries of Consent and Criminality in Long-Term Relationships

The Supreme Court’s decision in Samadhan S/o Sitaram Manmothe v. State of Maharashtra marks yet another significant reaffirmation of the doctrinal boundaries governing prosecutions for rape on the allegation of “false promise to marry.”

The judgment, delivered by Nagarathna J., scrutinises a long-term intimate relationship between a married woman and an advocate, ultimately concluding that the invocation of Section 376 including its aggravated form under Section 376(2)(n) IPC was legally unsustainable.

In doing so, the Court has once again cautioned that the criminal law, particularly an offence as grave as rape, cannot be deployed to criminalise the breakdown of personal relationships or to vindicate emotional grievances originating from mutual intimacy.

The factual matrix, drawn entirely from the complainant’s own narration, reveals a relationship that spanned nearly three years, during which the parties maintained continuous communication, met frequently, and engaged in physical intimacy of their own accord.

The complainant, who was herself married and living separately from her husband, entered into this relationship after meeting the appellant in the context of her maintenance litigation.

The record reflects not a single instance of protest, complaint, or allegation of coercion at any point during these three years.

The criminal case surfaced only after the appellant allegedly refused to pay a sum of ₹1,50,000 a circumstance the Court noted in assessing the timing and motivation behind the FIR.

The Court’s emphasis on these details underscores a long-standing jurisprudential approach: consent, when voluntarily exercised over an extended period and without contemporaneous objection, cannot be retrospectively repackaged as lack of consent solely because the relationship eventually soured.

In rejecting the High Court’s refusal to quash the proceedings, the Supreme Court meticulously revisited the legal threshold for determining whether sexual relations are vitiated by a false promise of marriage.

The Court reiterated that for such a promise to amount to a “misconception of fact” rendering consent invalid, it must be shown that the man never intended to marry the woman from the very inception and that the promise was merely a deceptive device to obtain sexual favours.

This principle, repeatedly affirmed in Mahesh Damu Khare and Deepak Gulati, formed the backbone of the Court’s analysis.

The present case did not disclose such an intention; rather, the complainant’s own statements showed that she frequently declined the appellant’s suggestion of marriage and continued to voluntarily meet him at hotels and other locations even after expressing her disinterest in marrying him.

Such conduct, the Court held, is inconsistent with the allegation that her consent was contingent solely on a promise of marriage.

The Court also contextualised this case within a broader societal and legal concern: the troubling trend of criminalising failed relationships.

It observed that while the law must remain sensitive to genuine cases where a woman is deceived, exploited, or coerced into sexual relations under the guise of marriage, it must be equally vigilant in preventing the misuse of criminal provisions.

Rape, the Court noted, is an offence of the gravest nature, and its misapplication not only trivialises its seriousness but inflicts irreparable harm on the accused, who bears the indelible stigma of such allegations.

This case, the Court found, squarely fell within the category of consensual relationships that subsequently turned acrimonious a type of dispute unsuitable for criminal prosecution.

The Court also found the High Court’s reliance on the absence of a specific pleading of consent misplaced, making it clear that the consensual nature of the relationship was evident from the very recitals of the FIR itself.

A quashing court, therefore, is not constrained by the formal pleadings of the parties but must consider the overarching factual narrative.

Since the complainant’s conduct unequivocally demonstrated voluntary participation, the continuation of the prosecution would amount to an abuse of judicial process, falling squarely within the parameters laid down in State of Haryana v. Bhajan Lal.

In the final analysis, the Supreme Court’s quashing of the FIR and chargesheet affirms a consistent line of jurisprudence that seeks to protect the integrity of criminal law from encroachments arising out of interpersonal disputes.

The decision reiterates essential distinctions between coercion and consent, deception and disaffection, criminality and human fallibility.

It is a reminder that the law must act as a shield for genuine victims of sexual violence, but it cannot become a means to redress personal bitterness or extract retributive satisfaction after the collapse of a relationship freely entered into.

The Court’s reasoning thus continues the delicate balancing exercise between the rights of women to bodily autonomy and dignity, and the need to prevent the criminal justice system from becoming a battleground for private grievances.