The Supreme Court dealt with an appeal to quash an FIR alleging rape, cheating, and other offenses. The Court analyzed the prolonged consensual relationship (2008–2017) between the appellant and the complainant, concluding that the claim of false promise of marriage lacked credibility due to the extended duration and circumstances. The Court clarified the law on consent, misconception of fact, and the criminal liability attached to false promises.

1. Background of the Case

The appellant, a social worker, was accused of offenses under Sections 376, 420, 504, and 506 IPC. The allegations stemmed from a decade-long physical relationship, with the complainant claiming it was based on a false promise of marriage.

2. Initial Allegations

The complainant alleged that the appellant forcibly engaged in sexual intercourse and continued the relationship by promising marriage, financial support, and housing. However, the appellant contended the relationship was consensual.

3. Procedural History

• FIR No. 302 of 2017 was filed against the appellant under IPC provisions.
• Anticipatory bail was granted by the Sessions Court, emphasizing that the relationship appeared consensual.
• A second FIR regarding alleged molestation of the complainant's daughter was also registered but viewed skeptically due to delays.

4. High Court's Decision

The Bombay High Court dismissed the appellant's plea to quash the FIR, citing the seriousness of rape allegations as societal offenses requiring thorough investigation.

5. Supreme Court's Observations

• Consent Analysis: The Court emphasized that consent under Section 375 IPC and its vitiation by misconception must involve deliberate deceit.
• Prolonged Relationship: A decade-long consensual relationship negated claims of deceit.
• Delayed Allegations: The complainant's delay in raising objections pointed to a consensual relationship, not coercion.

6. Final Judgment

The Supreme Court quashed the FIR, noting the allegations were inconsistent with the consensual nature of the relationship and did not constitute offenses under the cited sections.

Acts and Sections Discussed:

1. Section 376 IPC: Rape and the role of consent under various circumstances.
2. Section 90 IPC: Consent obtained under misconception or fear.
3. Section 420 IPC: Cheating, requiring intent to deceive from the outset.
4. Sections 504 and 506 IPC: Relating to criminal intimidation, not substantiated in this case.
5. Section 482 CrPC: High Court's inherent powers to quash criminal proceedings to prevent abuse of process.

Ratio Decidendi:

For a promise of marriage to vitiate consent under Section 375 IPC, it must be proven to be false at the outset, with intent to deceive. Long-term consensual relationships without prompt objections dilute the claim of coercion or misconception of fact.

Subjects:

False promises of marriage, consensual relationships, and the scope of rape under Indian Penal Code.

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