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Delhi High Court Acquits Man in Rape Case, Finds Relationship Was Consensual Despite Failed Marriage Promise

 

Delhi High Court Acquits Man in Rape Case, Finds Relationship Was Consensual Despite Failed Marriage Promise

A bench of the Delhi High Court, led by Justice Jasmeet Singh, has overturned a rape conviction against a man accused of indulging in physical relations with a well-educated woman under the purported promise of marriage. The court noted that their relationship was of substantial duration and entirely consensual, and that the promise of marriage, while present in the past, no longer defined or conditioned the woman's ongoing consent.

The original First Information Report alleged that the man had repeatedly raped the woman after falsely promising to marry her, despite having no intention of fulfilling that promise. It further accused him of marrying someone else eventually, thereby nullifying any presumption of future marriage. The trial court convicted the man under Sections 366 (kidnapping or inducing a woman to compel marriage) and 376 (rape), imposing a ten-year rigorous imprisonment sentence.

Upon appeal, the High Court meticulously examined the evidence and the nature of the relationship. Justice Singh emphasized that for consent to be vitiated on grounds of a false promise of marriage, the prosecution must demonstrate that sexual intercourse occurred solely on the basis of that promise, made without a genuine intention to marry. The court held that when a relationship, initially rooted in affection and a mutual commitment, evolves into a long-term consensual arrangement that continues even after the formal marriage proposal fell through, its character fundamentally changes. Such sustained intimacy, the court observed, cannot logically be attributed to a singular unfulfilled promise of marriage, particularly in the absence of clear evidence that the promise was deceitfully used as leverage.

Additionally, the court recognized that the promise of marriage might be genuine, albeit later unfulfilled due to unforeseen circumstances. In such cases, the broken promise does not automatically transform the physical relationship into an offense. Intentions at the time of the promise must be carefully scrutinized, and a promise made in good faith—though not realized—does not constitute deception vitiating consent. This distinction is crucial to preserving the integrity of consent and preventing the misuse of criminal law to address personal grievances after a relationship ends.

Having applied these legal principles to the facts before it, the court concluded that the woman’s consent did not arise solely from manipulation. Instead, it was a reflection of mutual affection and voluntary participation in the relationship over time. Consequently, the conviction lacked a firm evidentiary basis, and was therefore set aside. The appellant was acquitted, with the court underscoring that consensual relationships must not be retroactively criminalized due to the breakdown of expectations or societal norms.

Logical Structure of Judgment:

  1. The High Court pointed out that the relationship began with consent and continued on that basis over a sustained period, undermining the idea that consent was induced merely by a false promise.

  2. It held that consent premised on a false promise could only vitiate consent if the promise was made knowingly without intent to fulfil it.

  3. A prolonged consensual relationship cannot be equated with rape grounded in a failed promise.

  4. Absent evidence proving that the promise was disingenuous from the start, the conviction could not stand.

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