The Chhattisgarh High Court has ruled that merely refusing to marry a long-term live-in partner does not by itself amount to the offence of rape. The Court observed that when two adults willingly enter into and continue a relationship for a considerable period, the failure of the relationship or the decision not to marry later cannot automatically be treated as proof that the relationship was based on a false promise of marriage.
The judgment was delivered while hearing an appeal filed against the acquittal of a man who had been accused of rape and other offences. The woman had alleged that the accused had developed a relationship with her and maintained physical relations with her on the assurance that he would marry her. According to her, after being in a relationship for several years, the accused later refused to marry her due to opposition from his family.
The case arose from a relationship between the two individuals who had known each other for a long period. The allegations stated that they developed a close relationship and eventually lived together. The woman claimed that the accused continued the relationship by repeatedly assuring her of marriage. However, after certain disagreements and family objections, the accused allegedly decided not to proceed with the marriage.
Following the end of the relationship, the woman approached the authorities, leading to registration of a criminal case. The accused faced allegations under provisions relating to rape and other offences. During the trial, the court examined the statements of the parties, witness accounts, medical evidence, and surrounding circumstances before reaching a decision.
The trial court acquitted the accused, observing that the prosecution had failed to establish that the physical relationship was obtained through a false promise of marriage. The woman challenged this decision before the High Court, arguing that the accused had deceived her by giving a promise of marriage and later withdrawing from it.
While examining the matter, the High Court focused on the important legal distinction between a false promise of marriage and a genuine promise that could not later be fulfilled. The Court explained that for an allegation of rape based on a promise of marriage to succeed, it must be shown that the accused never intended to marry from the beginning and that the promise was made only to obtain consent for a physical relationship.
The Court observed that a person changing their decision about marriage at a later stage does not automatically mean that the earlier promise was dishonest. Relationships may fail due to several reasons, including family pressure, personal differences, or changes in circumstances. Such situations alone cannot establish criminal liability.
The High Court noted that the relationship in the present case continued for a long period and involved mutual participation by both individuals. The Court observed that the nature and duration of the relationship were relevant factors while determining whether the consent was voluntary or obtained through deception.
The Bench also considered the evidence presented during the proceedings. The Court found that the material on record indicated that the parties were involved in a consensual relationship. The evidence did not establish that the accused had entered into the relationship with a dishonest intention from the beginning or that he had used a false promise only as a means to obtain consent.
The Court further examined the medical evidence and other circumstances surrounding the allegations. The evidence did not support the claim that the relationship involved force or lack of consent. The Court considered all these factors together while deciding whether the ingredients of the alleged offences were satisfied.
The High Court emphasized that criminal law should not be applied to every failed relationship. A breakup, disagreement, or refusal to marry after a relationship has continued for a long time cannot automatically be converted into a criminal offence unless the required legal elements are proved.
The judgment also highlighted the importance of examining the intention of the accused at the beginning of the relationship. The central question in such cases is whether the promise of marriage was false from the start or whether circumstances later prevented the marriage from taking place.
The Court stated that cases involving allegations of sexual relations based on a promise of marriage require careful evaluation of facts. Courts must consider the conduct of both parties, the length of the relationship, the circumstances surrounding the promise, and the evidence available before reaching a conclusion.
The High Court ultimately upheld the acquittal of the accused and dismissed the appeal. It held that the evidence did not prove that the accused had obtained consent through a false promise of marriage or that his conduct amounted to rape.
The decision reinforces the principle that criminal responsibility cannot arise merely because a relationship ends unsuccessfully. The law requires proof that there was deception, dishonest intention, or lack of genuine consent at the relevant time.
In conclusion, the Chhattisgarh High Court clarified that refusal to marry a long-term live-in partner does not automatically amount to rape. The Court held that a failed relationship or a later decision not to marry is not sufficient to establish a criminal offence unless it is proved that the promise of marriage was false from the very beginning and was made with the intention to deceive.
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