Consensual Relationships Do Not Constitute Rape Under Promise of Marriage: Supreme Court

In a recent landmark decision, the Supreme Court of India reaffirmed the legal principle that consensual relationships, even those arising from a promise of marriage, cannot be equated to rape unless there is clear evidence of coercion or misconception. The ruling came in response to the criminal appeal filed by Lalu Yadav (Appellant) against the State of Uttar Pradesh and others (Respondents). The case raised important questions about the interpretation of consent in relationships and the scope of legal recourse under Sections 376 and 313 of the Indian Penal Code (IPC).

In Lalu Yadav v. State of Uttar Pradesh & Ors., Criminal Appeal No. 4222 of 2024, the appellant, Lalu Yadav, was accused of rape and abortion by the complainant, based on allegations of deception and non-consensual physical relationships over several years. The complaint was lodged five years after the alleged incidents occurred. The appellant sought to quash the FIR, arguing that the relationship was consensual, and the complaint was filed belatedly with ulterior motives.

The High Court of Judicature at Allahabad had previously dismissed Yadav’s plea for quashing the FIR, leading him to appeal before the Supreme Court. The Supreme Court granted leave and heard the matter, ultimately quashing the FIR and dismissing the allegations under IPC Sections 376 (rape) and 313 (abortion).

Legal Context and Provisions of Rape to understand Consensual relationships

The key legal provisions under scrutiny were:

• Section 376, IPC: This section deals with the crime of rape, including situations where consent is obtained under false pretences or coercion.
• Section 313, IPC: This section pertains to the offense of causing miscarriage without a woman’s consent.
• Article 226, Constitution of India: Allows for writ petitions to be filed in the High Court to enforce rights or seek remedy against wrongful actions, including the quashing of FIRs.
• Section 482, Code of Criminal Procedure (CrPC): Empowers the High Courts to exercise inherent powers to prevent abuse of the judicial process and ensure justice.

The appellant sought quashment of the FIR under Article 226 of the Constitution and Section 482 of the CrPC, citing the absence of evidence for coercion and delay in lodging the complaint.

Facts of the Case

The complainant, Preeti (name changed), alleged that the appellant had promised to marry her and established physical relations with her without consent over the course of several years. She further claimed that she became pregnant twice, with the appellant pressuring her into abortions. The complaint, however, was filed only in 2018, five years after the incidents reportedly took place, raising suspicions of ulterior motives.

The appellant, Lalu Yadav, countered these allegations, arguing that the relationship was consensual, and the complainant had willingly lived with him as a wife. He also pointed out the significant delay in filing the FIR, which he contended was indicative of the complainant’s malice.

Court’s Findings

The Supreme Court carefully analysed the facts of the case, including the nature of the relationship and the complainant’s delay in filing the FIR. Key observations by the Court included:

1. Delay in Filing FIR: The Court noted that the alleged incidents occurred between 2013 and 2018, yet the FIR was filed only in February 2018, with a time lag of five years. The Court observed that such a delay in reporting undermined the credibility of the complainant’s allegations.
2. Nature of the Relationship: The complainant admitted that she had lived with the appellant as a wife for a considerable period, which, in the Court’s view, indicated a consensual relationship. The Court found inconsistencies in the complainant’s statements, such as her claim of non-consensual sex while simultaneously acknowledging that they had lived as a married couple.
3. Lack of Prima Facie Case: The Court concluded that the allegations did not establish a prima facie case of rape. The complainant’s consent to the physical relationship, even if given under a promise of marriage, could not be construed as coerced consent. Furthermore, the Court emphasized that the mere refusal to marry at a later stage does not transform a consensual relationship into rape.
4. Quashing of FIR: Based on the facts and evidence, the Court quashed the FIR, stating that the allegations lacked substance and did not meet the legal standards for prosecuting offenses under Sections 376 and 313 of the IPC. The Court observed that allowing the case to proceed would constitute an abuse of the legal process.

Court’s Reasoning and Precedents

In reaching its decision, the Court referred to several key precedents, including:

• Pepsi Foods Ltd. v. Special Judicial Magistrate (1998): In this case, the Supreme Court reiterated that the High Courts have the authority to quash FIRs under Article 226 of the Constitution or Section 482 of the CrPC to prevent misuse of judicial processes.
• State of Haryana v. Bhajan Lal (1992): This landmark judgment outlined specific circumstances in which an FIR can be quashed, including situations where the allegations do not constitute a cognizable offense or where the complaint is filed with mala fide intentions.
• Shivashankar alias Shiva v. State of Karnataka (2019): This case clarified that a long-term relationship, even if it involves a promise of marriage, cannot be retrospectively labelled as rape unless there is evidence of fraud or coercion at the time of consent.

In this case, the Apex Court  heavily  relied on the rulings to establish that consensual physical relations, even if accompanied by a promise of marriage, do not automatically fall under the definition of rape unless there is clear evidence of deceit or coercion.

The Supreme Court’s ruling in Lalu Yadav v. State of Uttar Pradesh & Ors. provides clarity on the legal boundaries of consent in relationships. The judgment reinforces the principle that consensual relationships, even those initiated with a promise of marriage, cannot be classified as rape unless there is substantial evidence of coercion or misconception. The Court’s decision to quash the FIR underscores the importance of a clear, prima facie case when prosecuting serious offenses like rape.

This judgment serves as a reminder that the legal system cannot be weaponized to settle personal grievances, and that allegations must be backed by substantive evidence to warrant criminal prosecution. It also highlights the courts’ duty to prevent the misuse of judicial processes in cases involving personal relationships.

For legal practitioners, this case reaffirms the importance of timely reporting, consistent testimony, and the clear establishment of consent in prosecuting cases of sexual offenses. The judgment provides a crucial precedent for future cases where the line between consensual relationships and allegations of coercion is blurred.

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