In a significant judgment, the Madras High Court recently acquitted a 26-year-old man who had been convicted of raping his partner under the pretext of a false promise to marry. The court's decision underscores the complexities involved in cases where prolonged consensual relationships deteriorate, leading to allegations of sexual offenses.
Background of the Case
The appellant and the complainant were involved in a romantic relationship that spanned six years. During this period, they engaged in a physical relationship. The complainant later alleged that the appellant had coerced her into sexual intercourse by threatening suicide and making a false promise of marriage. She contended that despite their differing religious backgrounds, the appellant assured her of marriage, which led her to consent to the sexual relationship. Upon realizing that the appellant was not intent on fulfilling his promise, she filed a complaint in July 2020, leading to the appellant's arrest and subsequent conviction by a sessions court in 2022 under Sections 376 (rape) and 417 (cheating) of the Indian Penal Code (IPC).
High Court's Observations
Justice Sunder Mohan, presiding over the appeal, meticulously examined the evidence and circumstances surrounding the case. He noted that the relationship between the appellant and the complainant was consensual and had lasted for a considerable duration. The court emphasized that the complainant, being 24 years old at the time of the alleged offense, was mature enough to understand the implications of her actions. Justice Mohan observed, "The victim was aged 24 years at the time of occurrence and she was aware of the consequences of her act, and it cannot be said that her consent to have sexual intercourse is only on the false promise of marriage. The victim is not naive or gullible, and she was capable of understanding the consequences of her acts."
The court further highlighted that the evidence did not substantiate the claim that the appellant had engaged in sexual relations with the complainant solely based on a false promise of marriage. Instead, it appeared to be a case where a long-term consensual relationship had soured over time. Justice Mohan stated, "The evidence only reveals a consensual relationship for a prolonged period of time that turned sour, and hence, the offense under Sections 376 and 417 of the IPC are not made out on the facts of the case."
Reliance on Supreme Court Precedent
In arriving at its decision, the High Court relied on the Supreme Court's ruling in Mahesh Damu Khare v. The State of Maharashtra & Another. In that case, the apex court had delineated the distinction between consensual relationships and instances where consent for sexual intercourse is obtained through a false promise of marriage. The Supreme Court had observed that for an offense of rape to be established on the grounds of a false promise to marry, it must be proven that the accused had no intention of marrying the complainant from the outset and that the promise was made solely to induce the complainant into a sexual relationship.
The High Court found that the present case did not meet these criteria. The prolonged nature of the relationship and the absence of evidence indicating that the appellant had deceitful intentions from the beginning led the court to conclude that the charges under Sections 376 and 417 were not substantiated.
Implications of the Judgment
This judgment underscores the judiciary's cautious approach in distinguishing between consensual relationships that deteriorate and genuine cases where individuals are misled into sexual relationships through deceitful promises of marriage. It highlights the importance of evaluating the entirety of the relationship, the maturity and understanding of the individuals involved, and the intentions behind promises made during the relationship.
The court's decision also reflects a recognition of the autonomy and agency of adult individuals in making informed decisions about their personal relationships. By acknowledging that a mature individual is capable of understanding the consequences of their actions, the judiciary reinforces the principle that not all failed relationships, even those involving unfulfilled promises of marriage, constitute criminal offenses.
Conclusion
The acquittal of the appellant by the Madras High Court serves as a significant precedent in cases involving allegations of rape based on false promises of marriage. It emphasizes the necessity for courts to carefully assess the nature of the relationship, the context of the promises made, and the individual capacities of the parties involved. This approach ensures that the legal system differentiates between genuine instances of deceit leading to sexual exploitation and situations where consensual relationships simply do not culminate in marriage.
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