Rape FIR quashed where prolonged physical relationship was not induced solely by a promise of marriage.

The complainant and the applicant became acquainted through Facebook in 2012 while the complainant was pursuing a Ph.D. and later working as an Economics Assistant at IIM Ahmedabad.

The complainant alleged that, during the period from September–November 2012 and between 6 February and 20 March 2013, the applicant established physical relations with her on four occasions against her will after inducing her with an assurance of marriage.

She further alleged that the applicant subsequently ceased communication, became engaged, and married another woman.

The FIR was lodged on 22 September 2014 at Satellite Police Station, Ahmedabad, alleging an offence under Section 376 of the Indian Penal Code, 1860.

The applicant invoked Section 482 of the Code of Criminal Procedure, 1973, seeking quashing of the FIR and consequential proceedings, contending that the relationship was consensual, the FIR was belated and retaliatory, and that he had issued a legal notice to the complainant before registration of the FIR.

Whether the allegations in the FIR, taken at face value, disclosed the offence of rape under Section 376 IPC so as to justify continuation of the criminal proceedings.

Whether the High Court should exercise its inherent jurisdiction under Section 482 CrPC to quash the FIR on the ground that the allegations reflected a consensual relationship, contained material contradictions, and were belated and retaliatory.

Whether repeated physical relations in the context of an alleged love relationship and promise of marriage, without material demonstrating that the consent was obtained solely through deception or a false promise to marry, warranted prosecution for rape.

The Court applied Section 482 CrPC, which empowers the High Court to quash criminal proceedings to prevent abuse of the process of court and secure the ends of justice, and Section 376 IPC concerning the offence of rape.

The Court relied on Samadhan S/o Sitaram Manmothe v. State of Maharashtra & Anr., 2025 INSC 1351, for the principle that where a complainant has engaged in repeated physical relations and the allegations do not establish that such relations were induced solely by deception or a false promise to marry, continuation of a rape prosecution may be unwarranted.

The Court also considered the principle that the prima facie criminality must emerge from the FIR itself when exercising quashing jurisdiction.

The Court found that the FIR itself described a love relationship and continued physical and direct contact between the parties, while simultaneously alleging that the relations were against the complainant’s will.

According to the Court, these were contradictory and self-destructive assertions.

It further held that the complainant had not specifically asserted that she submitted to the applicant solely because of a promise of marriage, and that the allegation of repeated physical relations over a period of time did not, by itself, establish rape induced by deception.

The Court also relied on the belated registration of the FIR, the applicant’s prior legal notice dated 3 September 2014, and the allegations that the complainant had contacted the applicant’s fiancée, observing that these circumstances supported the applicant’s contention that the FIR was retaliatory.

On the basis of the FIR and the material placed on record, the Court concluded that the essential ingredients of Section 376 IPC were not made out.

Exercising jurisdiction under Section 482 CrPC, it allowed the application and quashed and set aside FIR C.R. No. I-219 of 2014 registered at Satellite Police Station, Ahmedabad, dated 22 September 2014, together with all consequential proceedings.

Rule was made absolute, and direct service was permitted.