New Delhi, Feb 6, KDC: The Supreme Court of India has quashed an FIR and all criminal proceedings against advocate Pramod Kumar Navratna, who had been accused of rape on the false promise of marriage, holding that the case arose out of a consensual relationship between two adults and did not disclose the ingredients of an offence under Section 376(2)(n) of the Indian Penal Code.
A Bench comprising Justice B. V. Nagarathna and Justice Ujjal Bhuyan set aside the March 3, 2025 order of the Chhattisgarh High Court and quashed FIR No. 213/2025 registered at Sarkanda Police Station, Bilaspur, along with the chargesheet and the consequential sessions trial, reported news agency Kashmir Dot Com.
The FIR had been lodged by a woman advocate alleging that the accused had repeatedly raped her on the false promise of marriage. However, the Court noted that the complainant was a married woman with a minor son, and that divorce proceedings between her and her husband were still pending at the time of the alleged relationship.
After examining the material on record, the Bench observed that the complainant was fully aware of her marital status and the legal bar on remarriage during the subsistence of her marriage. The Court held that a promise of marriage made in such circumstances could not be considered legally enforceable or capable of being acted upon.
The judgment emphasised that not every breach of a promise to marry amounts to rape, and that an offence under Section 376 IPC is made out only when a false promise of marriage is given from the very inception with the sole intention of obtaining sexual consent.
Terming the case a “classic example of a consensual relationship turning acrimonious,” the Court cautioned against the growing tendency to give criminal colour to failed personal relationships, observing that such misuse of the criminal justice system trivialises the seriousness of the offence of rape.
Accordingly, the Supreme Court allowed the appeal and quashed the FIR, chargesheet and Sessions Case No. 89/2025 pending before the District and Sessions Judge, Bilaspur. (KDC)
