Case Note & Summary
The case involved an appeal against an FIR registered under Section 69 of the Bhartiya Nyaya Sanhita (BNS) concerning allegations of false promise of marriage. The appellant, was accused of entering into a physical relationship with the complainant under the pretext of marrying her, only to later withdraw the promise citing his mother's disapproval. The High Court had previously declined to quash the FIR, prompting the appellant to seek relief from the Supreme Court. The Supreme Court examined the nature of the relationship, which began through a digital platform and evolved into a love affair, with the appellant allegedly expressing his desire to marry during their first meeting. The court noted that the complainant allowed sexual intercourse based on this promise, but emphasized that the relationship appeared consensual and lacked evidence of deceitful conduct. The court referenced a prior judgment which clarified that a promise made with good intentions, even if later unfulfilled due to unavoidable circumstances, does not constitute a misconception of fact. Ultimately, the Supreme Court found no basis for the continuation of the proceedings and quashed the FIR, allowing the appeal and rejecting any pending applications.
Headnote
A) Criminal Law - Quashing of FIR - Lack of Deceitful Conduct - Bhartiya Nyaya Sanhita, 2025, Section 69 - The court found no evidence of deceitful conduct by the appellant as the relationship was consensual and the promise to marry was made with good intentions. The FIR was quashed as the allegations did not substantiate the claim of fraudulent behavior (Paras 5-7).
Issue of Consideration
Whether the FIR alleging false promise of marriage should be quashed due to lack of deceitful conduct.
Final Decision
The Supreme Court quashed the FIR bearing No. 11196030250292 dated 20.05.2025, registered at Sayajiganh Police Station, Vadodara City, Gujarat, allowing the appeal and rejecting any pending applications.
Law Points
- quashing of FIR
- false promise of marriage
- deceitful conduct
- consent
- misconception of fact
