Delhi High Court

Sexual intercourse based on a false promise of marriage by a concealed married partner vitiates consent.

Karamveer Rathi vs State Of Nct Of Delhi And Anr

Delhi High CourtJUDGMENT: April 17, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant sought regular bail regarding FIR No. 580/2025 under Section 376 of the IPC and Sections 69/351(3) of the BNS

Source reference: p. 1

The prosecutrix, an air hostess, alleged she entered a live-in relationship with the applicant in 2022 based on a promise of marriage

Source reference: p. 1-2

She claimed the applicant coerced her into physical relations and later became abusive while deferring marriage

Source reference: p. 2

In October 2025, she discovered the applicant was already married with a child, a fact allegedly concealed by him and his relatives

Source reference: p. 2

The applicant was arrested on 12.11.2025, and a chargesheet has been filed

Source reference: p. 3

The applicant argued the relationship was consensual and that the prosecutrix, being educated, likely knew of his marital status

Source reference: p. 3-4
02

Issues

1. Whether the applicant is entitled to regular bail considering the allegations of sexual intercourse obtained through deceitful assurance of marriage under Section 69 of the BNS

Source reference: p. 5

2. Whether the consensual nature and duration of the relationship, coupled with the completion of the investigation, warrant the release of the applicant pending trial

Source reference: p. 3, 5
03

Law Applied

The court applied Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, regarding bail

Source reference: p. 1

Substantively, it considered Section 69 of the Bharatiya Nyaya Sanhita (BNS), which criminalizes sexual intercourse by "deceitful means" or a promise to marry without intention to fulfill it, and Section 376 of the IPC

Source reference: p. 1

The court relied on the principles for bail established in Manik Madhukar Sarve v. Vitthal Damuji Meher (2024) and Zeba Khan v. State of U.P. (2026), focusing on the gravity of the offence and the risk of witness intimidation

Source reference: p. 5

It further referenced Samadhan v. State of Maharashtra (2025) regarding the distinction between a breach of promise and a false promise made in bad faith to exploit a woman

Source reference: p. 7
04

Reasoning

The court rejected the applicant's contention that the prosecutrix’s education and the three-year duration of the relationship automatically implied informed consent

Source reference: p. 5

It noted that the prosecutrix maintained a consistent stance of being unaware of the applicant’s existing marriage, and the applicant did not deny the sexual relationship while being married

Source reference: p. 5-6

The court reasoned that since the charges were yet to be framed, granting bail would be premature

Source reference: p. 6

Distinguishing the precedents cited by the applicant, the court found that unlike Samadhan, there was no evidence here that the prosecutrix had ever refused marriage; rather, the applicant allegedly actively concealed his marital status to obtain consent

Source reference: p. 6-7

The court emphasized that a promise of marriage becomes the "foundation of consent," and if made in bad faith to exploit, it vitiates that consent

Source reference: p. 15

Finally, the court noted the risk of witness intimidation given the applicant's alleged prior threats

Source reference: p. 5, 8
05

Holding

The court held that the applicant failed to make out a case for regular bail at this stage due to the serious nature of the allegations involving deceit, physical assault, and intimidation

The court clarified that the indulgence in a sexual relationship while concealing a marriage does not inspire confidence for the grant of bail during the nascent stage of proceedings

Source reference: p. 6

Consequently, the bail application was dismissed

Source reference: p. 8
Delhi High Court

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Karamveer RathivsState Of Nct Of Delhi And Anr

Delhi High Court · April 17, 2026

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