The Supreme Court overturned criminal proceedings against a man accused of raping and impregnating a woman under the pretense of marriage, highlighting that their relationship resembled a long-term partnership rather than coercion.
The bench, consisting of Justices C.T. Ravikumar and Rajesh Bindal, noted that although the case was brought through a writ petition under Article 226 of the Constitution, it could justifiably have been treated under Section 482 of the Criminal Procedure Code (CrPC). This distinction allowed the court to exercise judicial discretion to prevent misuse of legal proceedings.
Key Findings
The complaint detailed a five-year relationship (2018–2023) where the two lived as partners. Allegedly, the man, identified as Lalu Yadav, made promises of marriage, which fell apart once he secured employment in the Army. Despite allegations that he forced the woman to terminate a pregnancy, police investigations did not uncover evidence supporting claims of forced abortion under Section 313 of the Indian Penal Code (IPC).
The bench remarked on contradictions in the woman’s account, noting discrepancies between her claims of non-consensual physical relations and her admission of cohabiting as spouses. It emphasized that the relationship, described as consensual over an extended period, did not align with the legal definition of rape, which requires proof of sexual interaction based on deceit or misconception.
Ruling Highlights
The justices underscored the absence of any valid grounds for pursuing rape charges under Section 375 IPC, concluding that the complainant willingly participated in the relationship. The subsequent decision by the man not to marry did not amount to a violation of consent at the relationship’s outset.
Furthermore, the five-year delay in filing the First Information Report (FIR) raised additional doubts about the credibility of the claims. As the court clarified, without clear evidence of coercion or deception from the beginning, no prima facie case of rape could be established.
The judgment also criticized the Allahabad High Court for not adequately assessing whether the allegations reflected a consensual relationship or a case of exploitation.
WE CAN HELP
The Supreme Court ruled that criminal proceedings against Lalu Yadav lacked legal merit and should have been dismissed by the High Court using its powers under Section 482 CrPC. By erasing the charges, the court reinforced the distinction between broken personal commitments and criminal misconduct, reminding that unfulfilled promises in intimate relationships do not always warrant legal action.
