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Delhi, Madhya Pradesh High Courts Reinforce Limits on ‘Promise-to-Marry’ Rape Cases

Both courts underscored that rape charges based on a marriage promise require proof of deceit at inception.

Overview

  • In separate September 3 rulings, the Delhi High Court quashed an FIR and the Madhya Pradesh High Court upheld an acquittal in cases alleging rape on a false promise of marriage.
  • Justice Swarana Kanta Sharma held that an educated woman who knowingly continued a relationship with a married man cannot later claim she was misled or legally exploited.
  • Delhi judges cautioned that converting failed relationships into rape prosecutions would distort the purpose of sexual-offence law and trivialise genuine cases.
  • The Madhya Pradesh bench of Justices Vivek Agarwal and Avanindra Kumar Singh found no deception where the complainant remained legally married, noting evidentiary gaps including no medical injuries and inconsistent witnesses.
  • In the Delhi matter, the court noted investigative verification that the parties underwent a marriage in January last year, supporting its conclusion that the relationship was consensual rather than induced by fraud.