Overview

• Justices JB Pardiwala and Sandeep Mehta ruled that a mere failure to marry does not constitute rape unless a false promise was made with malicious intent to exploit.
• The court outlined a four-step filter for High Courts under Section 482 CrPC (now Section 528 of the Bharatiya Nagarik Suraksha Sanhita) to assess quashing requests based on impeccable, undisputed material that undermines the case and shows abuse of process.
• The Supreme Court criticized the magistrate and Allahabad High Court for allowing proceedings on allegations lacking dates, locations, corroboration, and timely filing, noting even the accused’s parents were unnecessarily arraigned.
• In Delhi, Justice Swarana Kanta Sharma quashed an FIR, holding that an educated woman who continued a voluntary relationship despite knowing the man was married cannot later claim legal exploitation.
• The Madhya Pradesh High Court upheld an acquittal, finding no deception where the complainant remained legally married during the alleged relationship and evidence indicated consensual conduct.