In a significant judgment, the Supreme Court of India addressed the complex issue of whether allegations of rape can be sustained when sexual relations occur within a long-term live-in relationship, purportedly based on a promise of marriage. The Court emphasized that such allegations require careful scrutiny, especially when the relationship has spanned several years without any immediate complaint.
The case in question involved a woman who filed a First Information Report (FIR) against a man, accusing him of rape on the grounds that he had engaged in sexual relations with her under the false pretext of marriage. Notably, the couple had been in a live-in relationship for 16 years, during which they cohabited and shared a life together. The woman lodged the complaint only after the man married someone else, raising questions about the timing and intent behind the allegations.
The Supreme Court bench, comprising Justices Vikram Nath and Sandeep Mehta, observed that the prolonged duration of the relationship indicated a consensual association between two adults. The Court found it implausible that a well-educated and mature woman would remain in a relationship for such an extended period solely based on an unfulfilled promise of marriage. The judges noted that the absence of any complaint during the 16 years of cohabitation undermined the credibility of the claim that the relationship was non-consensual or based on deceit.
The Court further elaborated that for a promise of marriage to be considered false, and thus vitiate consent, it must be established that the promise was made with no intention of being fulfilled from the outset. In this case, there was no evidence to suggest that the man had a malicious intent or that he never intended to marry the woman. The relationship appeared to have been genuine and consensual, and the eventual breakdown did not, in itself, constitute grounds for a rape allegation.
This judgment aligns with previous rulings where the Supreme Court has distinguished between a breach of promise and a false promise made with intent to deceive. In earlier cases, the Court has held that a mere failure to fulfill a promise of marriage does not amount to rape unless it is shown that the promise was a mere tool to obtain consent for sexual relations. The Court has cautioned against the misuse of rape laws in situations where relationships sour, emphasizing the need to protect the integrity of the legal process.
The Supreme Court's decision underscores the importance of context and intent in cases involving allegations of rape based on promises of marriage. It highlights the necessity for courts to differentiate between genuine breaches of promise and instances where false promises are used to exploit individuals. The ruling serves as a reminder that the criminal justice system must be vigilant against potential abuses while ensuring that genuine cases of exploitation are addressed with the seriousness they deserve.
In conclusion, the Supreme Court's judgment reinforces the principle that long-term consensual relationships cannot be retrospectively labeled as non-consensual based solely on unfulfilled promises of marriage. It calls for a nuanced understanding of consent, intent, and the dynamics of adult relationships, ensuring that the law is applied judiciously and fairly.
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