Prolonged Consensual Relationship and the Limits of False Promise of Marriage: A New Legal Principle

1. Introduction

In Rajnish Singh @ Soni v. State of U.P. (2025 INSC 308), the Supreme Court of India addressed the complex issue of whether a long-term intimate relationship could be classified as rape when one party alleges that the consent was obtained by a false promise of marriage. The case involved the appellant, Rajnish Singh @ Soni, and the complainant (also referred to as Ms. A), who shared a relationship spanning nearly 16 years. The complainant alleged that the initial sexual act was forcible and that she repeatedly consented under a false promise of marriage. Eventually, the matter reached the High Court at Allahabad to quash the proceedings against the appellant, which the High Court declined. The Supreme Court granted leave to appeal and ultimately quashed the criminal proceedings, recognizing the consensual nature of the long-term relationship.

The key issue revolved around the ingredients of consent under the Indian Penal Code (IPC), particularly in situations where one party asserts that the consent was vitiated by a false promise to marry. The Supreme Court’s approach clarifies the distinctions between consensual relationships, mere breaches of promise, and cases where the false promise of marriage was used solely to exploit or deceive.

The parties in this case were:

• The appellant, Rajnish Singh @ Soni, who was in a relationship with Ms. A and eventually married another woman.
• The respondent-complainant, Ms. A, who alleged repeated sexual exploitation spanning 16 years under a false promise of marriage.
• The State of Uttar Pradesh, named as a respondent in the criminal proceedings.

2. Summary of the Judgment

The Supreme Court quashed the criminal proceedings against the appellant for the offenses under Sections 376, 384, 323, 504, and 506 of the IPC. The Court held that the complainant’s version of events, particularly long-standing physical intimacy under a purported false promise of marriage, was unsustainable as “rape” when viewed against the factual context:

• Over 16 years of an intimate relationship, with both parties living in separate towns and pursuing their careers, strongly indicated consent.
• The complainant was a well-educated, independent adult, suggesting that there was minimal scope for coercion or a long-term deception regarding the promise of marriage.
• Evidence revealed occasions where the complainant publicly portrayed herself as the appellant’s wife, contradicting her claim that the relationship was entirely forced or based on a false representation.
• The Court found it implausible that the complainant would remain silent for over 16 years if she truly believed her consent was wholly driven by a false promise of marriage.

Concluding that the prosecution would amount to an abuse of the legal process, the Supreme Court allowed the appeal and set aside the High Court’s order, thus quashing the criminal proceedings.

3. Analysis

3.1 Precedents Cited

The Court relied on a range of prior decisions to clarify when a consensual long-term relationship crosses into the realm of rape because of an alleged false promise of marriage. Two notable precedents include:

• Mahesh Damu Khare v. State of Maharashtra (2024 SCC OnLine SC 3471)
  This case emphasized that in order to establish rape under a false promise to marry, the promise must have been the sole reason for the complainant’s consent. The Court reasoned that voluntary participation in a relationship over an extended period casts doubt on whether the promise alone was the factor for consent.
• Prashant v. State (NCT of Delhi) (2024 SCC OnLine SC 3375)
  The Court observed that it is inconceivable for a complainant to maintain an extended relationship (both physically and socially) without exercising any independent agency. It highlighted how the long duration and mutual association between the parties imply a higher likelihood of voluntary engagement.

The judgment also drew guidance from Deepak Gulati v. State Of Haryana (2013) 7 SCC 675 on distinguishing between a mere breach of a promise and a false promise given with the sole intent to deceive. Similarly, Shivashankar v. State of Karnataka (2019) 18 SCC 204 was cited to underscore that a consensual relationship of several years, where the parties live like spouses, cannot ordinarily be construed as rape based on a subsequently unfulfilled promise of marriage.

3.2 Legal Reasoning

The Court’s reasoning hinged on several considerations:

1. Evaluating Consent: Consent, under the Indian Penal Code, can be deemed vitiated by factors such as force, duress, or a false representation that directly influences the complainant’s decision. However, the Court noted that a 16-year relationship strongly indicates repeated, voluntary acts.
2. Long-Term Relationship vs. Short-Term Inducement: When intimacy continues for nearly one and a half decades, it becomes difficult to conclude that the complainant’s consent was entirely predicated on a single promise made at the outset. By her own admission, the complainant traveled willingly, engaged in various social settings with the appellant, and even at times referred to herself as his wife.
3. Possibility of a Mere Breach of Promise: The Court highlighted that the difference between a promise not eventually fulfilled and a promise that was false from the outset must be carefully scrutinized. If the initial intention was genuine and the relationship became strained only later, a criminal charge for rape is not sustainable.
4. Contemporaneous Conduct and Delay: The complainant’s prolonged silence and willingness to continue the relationship undermined the allegation that the entire affair was non-consensual or purely based on deception.

3.3 Impact

This decision is significant for two main reasons:

• Guidance on Prolonged Relationships: It clarifies that extensive, long-term relationships with multiple shared experiences will typically be analyzed from a lens that weighs volition heavily, thereby limiting the prospect of successful prosecution for rape based on false promises of marriage.
• Balancing Rights and Abuse of Process: The ruling safeguards the legal process from being misused where the duration and mutual nature of the relationship clearly indicate consensual acts. It does not, however, dilute the seriousness of genuine rape charges. Rather, it requires courts to scrutinize the full context when allegations surface after a substantial passage of time.

4. Complex Concepts Simplified

• Consent Under IPC: Consent implies a conscious, voluntary agreement. If it is obtained through a significant misrepresentation or coercion, it may not remain valid. However, courts look at the entirety of the relationship, behavior, and timeframe to determine whether consent was genuinely obtained or not.
• False Promise vs. Breach of Promise: A “false promise” suggests that from the outset, the accused had no intention to fulfill the matrimonial promise. A “breach of promise,” on the other hand, may arise if the parties had a genuine intention to marry, but circumstances led to a later change of heart. Only the former undermines consent under Section 90 of IPC.
• Abuse of Process: A legal action becomes an “abuse of process” when it is pursued in a manner that is unfair, frivolous, or contrary to the underlying purpose of the law. In this judgment, continuing prosecution was deemed an abuse of process because the evidence did not support the complainant’s contention of coercion or deception.

5. Conclusion

The Supreme Court’s decision in Rajnish Singh @ Soni v. State of U.P. (2025 INSC 308) underlines the importance of contextual, evidence-based scrutiny of rape allegations grounded in the alleged false promise of marriage. Where a relationship spanning many years includes voluntary participation, mutual intimacy, and a lack of immediate complaint, the Court is more inclined to find it consensual rather than coerced or fraudulent from the outset.

This case serves as a reminder that not every unfulfilled pledge to marry automatically amounts to rape, especially in a scenario where both parties presented themselves as partners, lived in separate localities independently, and continued the relationship for an extensive duration without external pressure or substantial evidence of a deliberate deceit. The judgment thus provides valuable clarity on adjudication standards when distinguishing between genuine misconceptions of fact and mere breaches of trust in long-term relationships.

Disclaimer: This commentary is for informational purposes only and does not constitute legal advice.