In a recent ruling, the Supreme Court delivered a significant judgment concerning the complexities of consent and the understanding of consequences in cases of alleged rape. 

The case involved a dispute between a woman, referred to as the complainant, and a man, the appellant, who were engaged in a tumultuous relationship fraught with promises, allegations, and ultimately, legal repercussions.

The bench comprising Justices C.T. Ravikumar and Rajesh Bindal presided over the appeal, which contested a previous High Court order denying the appellant's plea to quash the FIR filed against him under Section 482 of the Criminal Procedure Code (Cr.P.C.). The complainant had accused the appellant of rape, alleging that he had engaged in physical relations with her under the guise of marriage promises.

The narrative unfolded with the complainant revealing that she had experienced marital discord leading to separation from her husband. Subsequently, the appellant, who was associated with Sadbhav Company, had taken residence on the first floor of her house in 2017. 

The complainant alleged that despite assurances of marriage, the appellant engaged in physical relations with her on multiple occasions without formalizing their union. She claimed to have divorced her husband in anticipation of marrying the appellant, even participating in a ceremonial union at a temple. 

However, the appellant later reneged on his promises, leading the complainant to file an FIR in December 2020.

Crucially, the Supreme Court scrutinized the complainant's statements, particularly her testimony under Section 164 of the Cr.P.C., which revealed inconsistencies in her narrative. 

The court highlighted the fact that the complainant had initially concealed her marital status and misrepresented the timeline of her divorce, casting doubt on the veracity of her claims.

Moreover, the court observed that the complainant, being of sound mind and maturity, was well aware of the implications of her actions, including engaging in physical relations outside the confines of her marriage. 

Drawing parallels with precedent, the court referenced the case of Naim Ahamed v. State (NCT of Delhi), where a similar scenario was deliberated upon, ultimately leading to the dismissal of rape charges against the accused.

Ultimately, the bench concluded that the complainant's consent, albeit under the guise of marriage promises, was apparent throughout the course of their relationship. Given her awareness of the consequences and her mature understanding, the court ruled in favor of the appellant, quashing the rape FIR against him.

Case: XXXX vs. STATE OF MADHYA PRADESH & ANOTHER,

CRIMINAL APPEAL NO. 3431 OF 2023. 

Click to read/download Judgment