Supreme Court Clarifies the Distinction Between Breach of Promise and False Promise to Marry

Introduction

This commentary examines the Supreme Court of India’s decision in Manish Yadav v. State of Uttar Pradesh (2025 INSC 151). The case revolved around allegations of rape and certain offences under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, premised on the claim that the physical relationship in question occurred under a false promise of marriage. The appellant, Manish Yadav, challenged both the trial court’s summoning order and the High Court’s order partially upholding it. The Supreme Court ultimately quashed the proceedings against the appellant.

This judgment is significant because it reiterates and refines the legal test to determine whether a “promise of marriage” is false from the very beginning—or simply a promise that was not fulfilled due to subsequent events. It clarifies that a consensual relationship between adults does not automatically give rise to criminal liability on grounds of rape merely because the parties fail to formalize the relationship.

Summary of the Judgment

The Supreme Court, in reversing the High Court's partial affirmation of the trial court’s summoning order, ruled that there was no evidence to establish that the appellant had made a false promise of marriage right from the start. The Court observed that the complainant’s own statement did not support the theory of inducement under a fraudulent or deliberately false promise of marriage. Instead, the evidence suggested a consensual relationship between two adults that eventually declined due to interpersonal conflicts and misunderstandings.

The Court also noted that the legally essential ingredients for offences under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 were not substantiated, as the complainant did not provide any direct statement indicating she was abused or denigrated on account of her caste by the appellant. Consequently, the Court quashed the criminal proceedings against the appellant on all alleged charges, including those under the Indian Penal Code and the SC/ST Act.

Analysis

Precedents Cited

The Court relied heavily on three principal precedents to illuminate the legal standard for understanding “consent” and “promise of marriage” in the context of alleged rape under the Indian Penal Code:

1. Uday v. State of Karnataka (2003) 4 SCC 46: The Court in Uday held that where a woman consents to sexual intercourse based on the hope or assumption of marriage, such consent does not automatically become vitiated if the promise is not fulfilled. The Court further emphasized that there is no rigid formula: each case must be examined on its own facts.
2. Deepak Gulati v. State Of Haryana (2013) 7 SCC 675: This case distinguished between (i) mere breach of promise and (ii) a false promise made to deceive. The Supreme Court held that consent given on the basis of a promise intended to hoodwink the prosecutrix from the very beginning would amount to rape. However, a delayed or eventual failure to marry does not automatically qualify as a false promise.
3. Deelip Singh Alias Dilip Kumar v. State Of Bihar (2005) 1 SCC 88: The Court set aside the conviction of the accused, observing that a “breach of promise” to marry does not ipso facto translate into a prosecutable case of rape unless it is proven that the accused never intended to marry from the beginning.

These precedents collectively informed the Court’s perspective that, to sustain an allegation of rape on grounds of false promise, there must be demonstrable evidence of an intention to deceive at the very outset.

Legal Reasoning

The Supreme Court’s reasoning in Manish Yadav v. State of Uttar Pradesh rested on two crucial points:

1. Nature of Consent and Promise: The Court noted that the complainant and appellant were both adults and engaged in a consensual relationship built on mutual attraction. The complainant’s own statement under Section 164 of the Code of Criminal Procedure revealed that the sexual relations were initially founded on personal affection and not purely on a promise of marriage.
2. False Promise vs. Breach of Promise: Citing the ratio in Uday, Deepak Gulati, and Deelip Singh, the Court underlined that the operational difference between a breach of a genuine promise and a deliberately false promise is pivotal. Simply failing to follow through on an intent to marry—especially when the record reveals intervening personal disputes, changes in circumstances, mutual misunderstandings, or familial opposition—does not constitute an offence of rape. The evidence presented did not demonstrate that the appellant had a fraudulent intention from the outset.

As for the caste-based allegations, the Court held that there was no incriminating material to suggest the appellant specifically denigrated the complainant’s caste as an independent offence under the SC/ST Act.

Impact

The impact of this judgment is multifaceted:

• Clarification on “False Promise” Doctrine: This decision reinforces the well-established judicial principle that a simple breach of a mutual marriage plan does not, by itself, convert a consensual relationship into rape. It reiterates that the prosecution must establish that the accused had no intention to marry from the very beginning in order for the promise to be termed “false.”
• Stringent Evidentiary Threshold: Future litigants and prosecuting agencies will have to provide clear evidence of a deceptively constructed promise at inception. This heightened threshold offers clarity for courts assessing allegations of sexual exploitation under false marriage promises.
• Influence on SC/ST Act Prosecutions: In matters alleging caste-based atrocities, this judgment confirms the need for explicit, demonstrable evidence where the accused is shown to have targeted the complainant’s caste. This ensures that abuse of the SC/ST Act’s provisions is curtailed.

Complex Concepts Simplified

The focal legal doctrines in this case are:

1. Consent under Misconception of Fact: Section 90 of the Indian Penal Code addresses consent given under a misconception. If the accused had intended from the very start to deceive the complainant, then any “consent” by the complainant is considered vitiated. However, if the situation began consensually and the parties later fell out or parted ways, this does not automatically mean the “consent” was invalid.
2. Promise to Marry: Courts differentiate between an honest intent (that is later abandoned or becomes unworkable) and a pretended intent (deliberately made to secure consent). Only the latter might sustain a charge for rape on the basis of “false promise.”
3. SC/ST Act Offences: Offences under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act tend to carry specific requirements, such as proof of intentional insults or threats directed at a person specifically due to their caste status.

Conclusion

The Supreme Court’s decision in Manish Yadav v. State of Uttar Pradesh exemplifies an important clarification in criminal jurisprudence. It affirms that when parties to a relationship are consenting adults, a mere breach of a future marriage plan cannot serve as a conclusive basis for a prosecution under rape charges. Rather, it must be established that the accused had conceived a false promise of marriage from the onset, thereby undermining the complainant’s free consent.

More broadly, the judgment serves to preserve the integrity of the judicial process by ensuring that the statutory provisions intended to protect vulnerable individuals are not misapplied. Hence, the Court’s stance is a guiding precedent for lower courts and future litigants, signaling a measured and evidence-based approach to claims of “false promise” in matters of consensual relationships.