Physical relationship established on marriage promise despite social barriers warrants trial to determine fraudulent intent.

The appellant and the victim were in a long-term relationship spanning from approximately 2008 to 2024

The victim alleged that the appellant cohabited with her and maintained physical relations on repeated occasions based on a promise of marriage

The relationship allegedly soured when the appellant ultimately refused to marry the victim, citing caste differences

The victim filed an FIR on 22.06.2024 for offences under Section 376(2)(n) of the IPC and Section 3(2)(v) of the SC ST (POA) Act

Following a charge-sheet and the appellant's release on bail, the appellant filed a discharge application under Section 227 Cr.P.C.

The 4th Additional Sessions Judge, Bhubaneswar, rejected the discharge application on 10.12.2025, leading to the present appeal

1. Whether the trial court erred in rejecting the discharge application despite a significant delay in filing the FIR and the allegedly consensual nature of the relationship

2. Whether there are sufficient prima facie materials on record to proceed with charges under Section 376(2)(n) of the IPC and Section 3(2)(v) of the SC ST (POA) Act

The Court applied the principles of Sections 227 and 228 of the Cr.P.C. regarding discharge and framing of charges

It relied on Union of India v. Prafulla Kumar Samal, establishing that a judge must sift evidence only to determine if a prima facie case exists, rather than conducting a roving enquiry or trial

It further applied State of Orissa v. Debendra Nath Padhi, which mandates that at the stage of framing charges, the court must primarily consider prosecution materials and not the accused's defense

Regarding "consent" versus "rape on promise of marriage," it referenced Pramod Suryabhan Pawar v. State of Maharashtra and Kunal Chatterjee v. State of West Bengal, distinguishing between a false promise made at inception and a subsequent breach of promise

The Court observed that at the discharge stage, it cannot conduct a meticulous appreciation of evidence or resolve factual disputes such as whether the appellant knew the victim's caste or if the initial promise to marry was made in bad faith

While the appellant argued the relationship was consensual and the 12-year delay indicated an afterthought, the Court noted the prosecution's materials suggest the victim remained in the relationship under the bona fide belief of marriage, which was only shattered when the appellant cited caste as a bar

The Court reasoned that these contentions are matters of trial and cannot be adjudicated at a preliminary stage

Since the FIR and statements under Sections 161 and 164 Cr.P.C. provide a prima facie basis for the allegations, the statutory threshold for "sufficient grounds for proceeding" was met

The Court held that the materials collected during the investigation disclose a prima facie case against the appellant, warranting a trial

The Court clarified that the observations made in this judgment are limited to the disposal of the appeal and should not influence the trial court’s independent evaluation of evidence during the full trial