Long-Term Consensual Relationship Maintained on Promise of Marriage Does Not Constitute Rape Under Section 376 IPC

The petitioner sought to quash Session Trial No. 49/2021 and FIR No. 0132/2021 filed under Sections 376(2), 377, 313, 294, 506, and 509B of the IPC, Section 6 of the POCSO Act, and Section 67 of the IT Act.

The complainant (respondent No. 3), an educated graduate, alleged that the petitioner engaged in a sexual relationship with her for 12 years (from ages 16 to 28) under a false promise of marriage, recorded obscene videos to threaten her, and forced a termination of pregnancy.

The petitioner contended the relationship was consensual and fueled by mutual affection, noting the lack of medical evidence regarding pregnancy or seized digital evidence regarding IT Act charges.

1. Whether a long-term sexual relationship maintained under an alleged promise of marriage can be categorized as rape under Section 376 of the IPC when the parties are educated adults and the relationship appears consensual.

2. Whether the continuation of criminal proceedings constitutes an abuse of the process of law in the absence of corroborative evidence of coercion or deceit.

Inherent powers of the High Court to quash proceedings to prevent abuse of process under Section 482 of the CrPC.

A man cannot be held guilty of rape if an educated woman willingly engages in a long-term sexual relationship without evidence of inception-level deceit or "misconception of fact" under Section 90 of the IPC (Principle from Rajnish Singh v. State of Uttar Pradesh (2025)).

Parameters for quashing FIRs where allegations, even if taken at face value, do not prima facie constitute an offence as per State of Haryana v. Bhajan Lal (1992).

The Court observed that the complainant was well-educated and aware of the consequences of her actions throughout the 12-year relationship.

The Court reasoned that the prolonged duration of the relationship (2009–2020) without any prior complaints to authorities or family strongly suggested the physical intimacy was consensual rather than forceful.

The Court noted a critical lack of material evidence, such as medical records for the alleged termination of pregnancy or the obscene videos mentioned in the FIR, to support the charges under Sections 313 IPC or 67 IT Act.

Applying the Samadhan v. State of Maharashtra precedent, the Court found that the relationship fell within the "contours of a voluntary and willing" association, and the subsequent "breach of promise" did not retroactively transform consensual sex into rape.

The Court ruled that continuing the prosecution would be an abuse of the court machinery and consequently quashed the entire proceedings of Session Trial No. 49/2021, the FIR, the charge sheet, and the charge memo dated 27.06.2022.