Introduction:

The Karnataka High Court recently delivered a significant judgment emphasizing that the criminal justice system cannot be invoked to settle grievances arising out of failed romantic relationships. In the case arising from a complaint lodged at the Mangalore Women’s Police Station, the Court examined whether allegations stemming from a live-in relationship could justify the initiation of criminal proceedings under Sections 69 and 115(2) of the Bharatiya Nyaya Sanhita (BNS). The matter was decided by the single-judge bench of Justice M Nagaprasanna, who quashed the FIR registered against the petitioner. The Court made strong observations regarding the misuse of criminal law in cases where consensual relationships later break down. The petitioner approached the High Court seeking the quashing of the FIR which accused him of engaging in sexual relations with the complainant on the alleged false promise of marriage. According to the complaint, the relationship between the parties began when they met in Ireland in 2021 and subsequently developed into a live-in relationship. However, after the relationship deteriorated and both individuals returned to India, the complainant filed a criminal complaint in 2024 alleging that the petitioner had deceived her by promising marriage and then refusing to fulfill that promise. The Court carefully examined the factual matrix of the case, the nature of the relationship between the parties, and the applicable legal principles governing allegations of sexual relations based on false promises of marriage. During the proceedings, the High Court emphasized that while the law must protect individuals from exploitation and deception, it cannot be stretched to criminalize consensual relationships merely because they end unsuccessfully. The Court reiterated that criminal prosecution can arise only where the promise of marriage was false from the very inception and was made solely to obtain consent for sexual relations. In the absence of such fraudulent intent at the beginning of the relationship, the continuation of criminal proceedings would amount to an abuse of the legal process. The judgment thus reflects the Court’s attempt to strike a balance between safeguarding genuine victims and preventing the misuse of criminal law in matters of personal relationships.

Arguments of the Petitioner:

The petitioner, represented by his counsel, argued that the FIR registered against him was entirely misconceived and was based on a distorted portrayal of a consensual relationship that had simply run its course. According to the petitioner, the relationship between the parties began in Ireland when both individuals were living abroad. At the time they met in 2021, the complainant was already married and had a seven-year-old child. The petitioner contended that the complainant had already initiated steps for divorce even before meeting him, which clearly demonstrated that her marital issues were independent of their subsequent relationship. The petitioner submitted that the relationship developed gradually and was based on mutual affection and consent rather than any fraudulent inducement. Both parties voluntarily entered into a live-in relationship and shared emotional and personal companionship during their stay in Ireland. The petitioner strongly denied the allegation that he had established a physical relationship on the basis of a false promise of marriage. He argued that at no point did he deceive the complainant or make a promise with the intention of breaking it. According to him, the relationship later deteriorated due to personal differences and emotional incompatibility, which is a common occurrence in romantic relationships. The petitioner further submitted that the criminal complaint was filed only after the relationship ended and communication between the parties ceased. He argued that the FIR was an attempt to convert a personal grievance into a criminal case. The petitioner emphasized that the essential ingredient required to attract criminal liability under Section 69 of the Bharatiya Nyaya Sanhita was the existence of fraudulent intention at the inception of the relationship. Since the relationship was consensual and continued for a substantial period, the allegation that the petitioner had deceitfully induced the complainant into a sexual relationship was inherently untenable. The petitioner also relied upon several judgments of the Supreme Court which clearly distinguish between consensual sexual relationships and rape or sexual exploitation. In particular, reliance was placed on the landmark decision in Dr. Dhruvaram Murlidhar Sonar v. State of Maharashtra where the Supreme Court held that consensual sexual relations between adults cannot be treated as rape merely because the relationship eventually fails or the man refuses to marry the woman. The petitioner also cited the judgment in Shambhu Kharwar v. State of Uttar Pradesh, in which the Supreme Court clarified that there is a crucial distinction between a promise made in bad faith with no intention of being fulfilled and a genuine promise that later remains unfulfilled due to changing circumstances. On the basis of these legal principles, the petitioner argued that the FIR did not disclose any criminal offence and that allowing the investigation to continue would amount to harassment and abuse of the criminal justice system. The petitioner therefore requested the High Court to exercise its inherent powers to quash the FIR and prevent the misuse of criminal law in a purely personal dispute.

Arguments of the Respondent:

The respondent-complainant, on the other hand, defended the registration of the FIR and argued that the petitioner had indeed misled her by promising marriage and subsequently refusing to honor that promise. According to the complainant, the petitioner had induced her to enter into a physical relationship by assuring her that he intended to marry her after the dissolution of her previous marriage. She contended that she relied upon these assurances and developed a serious emotional commitment to the petitioner. The complainant argued that the petitioner’s conduct amounted to deception and emotional manipulation, which ultimately caused her significant distress and humiliation. She further submitted that the petitioner had abruptly stopped responding to her when the issue of marriage was raised after both parties returned to India. This sudden change in attitude, according to the complainant, demonstrated that the petitioner never had genuine intentions of marrying her and had merely exploited her trust. The complainant maintained that the investigation should be allowed to proceed so that the truth of the allegations could be properly examined by the investigating authorities. The State authorities also opposed the petition for quashing the FIR. They submitted that the allegations contained in the complaint disclosed a prima facie case and that the investigation should not be halted at a preliminary stage. According to the State, the question of whether the petitioner had made a false promise of marriage was a matter that required detailed investigation and evaluation of evidence. The prosecution argued that the High Court should exercise caution while interfering with criminal proceedings at the initial stage. It was contended that the power to quash an FIR should be exercised sparingly and only in cases where the allegations clearly fail to disclose any offence. The State therefore urged the Court to allow the investigation to continue so that the facts surrounding the relationship could be thoroughly examined.

Court’s Judgment:

After carefully considering the submissions of both sides and examining the materials on record, the Karnataka High Court delivered a detailed judgment explaining the legal principles governing allegations of sexual relationships based on false promises of marriage. Justice M. Nagaprasanna began by analyzing the factual background of the case. The Court noted that the parties first met in Ireland in 2021 and subsequently entered into a live-in relationship. At that time, the complainant was already married and had a child. The Court observed that the complainant had initiated divorce proceedings even before meeting the petitioner, which indicated that her marital relationship had already broken down independently of the petitioner’s involvement. The Court further noted that the relationship between the parties lasted for a considerable period and was marked by voluntary companionship and mutual consent. The Court emphasized that criminal liability for sexual relations based on a promise of marriage arises only when the promise is false from the very beginning and is made solely to obtain consent. In other words, the prosecution must establish that the accused had a fraudulent intention at the inception of the relationship. If the relationship was genuinely consensual and later failed due to changing circumstances, the law cannot treat it as a criminal offence. Justice Nagaprasanna strongly observed that the criminal justice system cannot be turned into a mechanism for addressing the emotional turmoil that follows the breakdown of personal relationships. The Court remarked that if every failed relationship were to be converted into a criminal case, courts would become forums for personal vendettas rather than institutions dedicated to the administration of justice. The Court also examined the precedents laid down by the Supreme Court in cases dealing with similar allegations. Referring to the decision in Dr. Dhruvaram Murlidhar Sonar, the Court reiterated that there is a clear doctrinal distinction between rape and consensual sexual relations between adults. The Supreme Court had clarified that when two adults voluntarily engage in a consensual relationship over a prolonged period, the subsequent refusal of the man to marry the woman cannot automatically convert the relationship into a criminal offence. The High Court also relied upon the judgment in Shambhu Kharwar, which highlighted the difference between a promise made with dishonest intention and a genuine promise that later remains unfulfilled. The Court further noted that the complainant had moved forward in life and entered into another relationship. While the Court clarified that such developments are not determinative of guilt or innocence, they nevertheless reinforced the conclusion that the case essentially concerned a relationship that had simply ended. Justice Nagaprasanna also referred to the Supreme Court’s observations in another case which held that where the complainant is already married, the allegation of physical intimacy based on a promise of marriage becomes inherently weak because such a promise is legally unenforceable in the first place. In light of these considerations, the Court concluded that even if the allegations contained in the complaint were accepted in their entirety, they did not disclose the essential ingredients of an offence under Section 69 of the Bharatiya Nyaya Sanhita. The Court therefore held that allowing the investigation to continue would amount to an abuse of the criminal justice system. The High Court accordingly allowed the petition and quashed the FIR registered against the petitioner. By doing so, the Court reaffirmed the principle that criminal law must not be misused to settle personal disputes arising from failed relationships.