Introduction:

In a landmark judgment dated March 3, 2025, the Supreme Court of India quashed criminal proceedings against Rajnish Singh, who was accused of sexually assaulting a woman with whom he had maintained a consensual relationship for 16 years under the alleged false pretext of marriage. The bench, comprising Justices Vikram Nath and Sandeep Mehta, emphasized that a mere breach of a marriage promise does not constitute rape unless it is proven that the accused never intended to marry the woman from the outset of the relationship. citeturn0search0

Background:

The complainant, a highly educated and well-established adult, entered into a consensual relationship with Rajnish Singh in 2006. This relationship spanned 16 years, during which both parties engaged in intimate relations. The complainant alleged that Singh had initially coerced her into the relationship by sneaking into her house and subjecting her to forcible sexual intercourse. However, no formal complaint was lodged during this extensive period. It was only after Singh married another woman in 2022 that the complainant filed an FIR, accusing him of rape under the false promise of marriage.

Complainant’s Arguments:

The complainant contended that Singh had exploited her sexually for 16 years under the false pretext of marriage. She asserted that she had consented to the relationship based on Singh’s continuous assurances of marriage, which he ultimately did not honor. The complainant argued that this breach of promise amounted to rape, as her consent was obtained deceitfully.

Defense’s Arguments:

Rajnish Singh’s defense argued that the relationship was entirely consensual, spanning over a decade and a half, and that the complainant, being an educated and mature woman, willingly engaged in the relationship. The defense highlighted that the complainant did not raise any objections or file any complaints during the 16-year period, indicating the consensual nature of their association. They further contended that the allegations were fabricated and motivated by Singh’s subsequent marriage to another woman.

Court’s Judgment:

The Supreme Court meticulously examined the facts and circumstances surrounding the case. The bench observed that the prolonged period of 16 years, during which the sexual relations continued unabatedly between the parties, was sufficient to conclude that there was never an element of force or deceit in the relationship. The Court expressed skepticism over the complainant’s claim that she unreservedly allowed Singh to subject her to repeated acts of sexual intercourse under the impression that he would someday act upon his promise of marriage.

The Court reaffirmed the legal principle that a mere breach of a marriage promise does not constitute rape unless it is proven that the accused had mala fide intentions from the inception of the relationship. Citing precedents such as Mahesh Damu Khare v. State of Maharashtra and Prashant v. State (NCT of Delhi), the Court emphasized that a prolonged consensual relationship cannot be considered rape based on a false promise of marriage unless the consent was vitiated by deceit from the outset.

In light of these observations, the Supreme Court quashed the criminal proceedings against Rajnish Singh, stating that continuing such proceedings would be unjust and amount to an abuse of the process of law.