Supreme Court Quashes Rape and Intimidation Charges in Consensual Relationship Case.
20 November 2024
FIR >> Criminal Law | Rape >> Criminal Law
In a significant judgment, the Supreme Court of India quashed a rape and criminal intimidation case against an individual, emphasizing the importance of consensual relationships and the abuse of legal processes. The case pertains to FIR No. 272 of 2019, registered under Sections 376(2)(n) and 506 of the Indian Penal Code (IPC), which the complainant filed against the appellant. The Delhi High Court had previously dismissed a petition for quashing the FIR. However, upon closer examination of the facts, the Supreme Court reversed the decision, highlighting key legal considerations that call for the dismissal of the case.
Facts of the Case:
The complainant filed the FIR on 29th September 2019, accusing the appellant of forceful sexual acts and criminal intimidation. According to the complainant, she had met the appellant in 2017 through a call, and their relationship evolved into physical intimacy over time. In January 2019, she alleged that the appellant had forced himself on her and used threats to compel her into a sexual relationship. Despite these accusations, she continued meeting the appellant, even visiting his house and engaging in further physical intimacy.
The complainant later filed the FIR, stating that the appellant had threatened to harm her brother if she refused to continue the relationship. However, her statement was inconsistent, with discrepancies between her accounts in the FIR, the medical report, and her statement under Section 164 of the CrPC.
Legal Proceedings and High Court's Dismissal:
The appellant approached the Delhi High Court, seeking the quashing of the FIR under Section 482 of the Criminal Procedure Code (CrPC), arguing that the case lacked merit and was based on inconsistencies. The High Court, however, dismissed the plea, ruling that the FIR contained sufficient material to justify a trial under Sections 376(2)(n) and 506 IPC. It emphasized that the complainant's statements, if taken at face value, supported the allegations of rape and criminal intimidation.
Supreme Court's Analysis:
The Supreme Court, however, disagreed with the High Court’s findings, carefully analyzing the facts and legal principles involved. The Court noted that the allegations in the FIR, even when accepted in their entirety, did not establish a prima facie case of rape under Section 376(2)(n) or criminal intimidation under Section 506 of the IPC.
The relationship between the appellant and the complainant, which began in 2017, appeared to have been consensual. Despite the complainant’s claims of forceful sexual acts, she continued to meet the appellant, indicating that her actions were not consistent with a victim of coercion. Moreover, the appellant was able to ascertain her address, suggesting that the complainant had voluntarily shared this information.
The Court observed that both parties had the intention to marry at one point, but when their relationship did not materialize, the complainant filed the FIR. The appellant's subsequent marriage in 2019 appeared to have been a catalyst for the complainant’s decision to lodge the complaint. The Court emphasized that a consensual relationship, even if it ended without marriage, cannot be converted into a criminal act merely because of personal grievances or a change in circumstances.
Absence of Consent and Criminal Intimidation:
The Court further analyzed the allegations of criminal intimidation. Section 506 of the IPC deals with threats to cause harm to a person or their property, but the Court found no substantial evidence of such threats in the present case. The relationship between the appellant and the complainant was not one characterized by force or intimidation but rather mutual understanding, at least in the initial stages. The appellant’s alleged threats appeared to be linked to the breakdown of the relationship, and the complainant's subsequent actions seemed to stem from personal issues rather than genuine fear for her safety.
Legal Precedents and Conclusion:
The Supreme Court drew on previous judgments to bolster its reasoning. In Pramod Suryabhan Pawar v. State of Maharashtra (2019), the Court had clarified that a false promise of marriage must be made in bad faith and with no intention of fulfillment for it to vitiate consent. In the present case, there was no evidence that the appellant had made a false promise of marriage or used it as a coercive tool to obtain the complainant's consent.
In light of these factors, the Court concluded that the continuation of the prosecution would amount to an abuse of legal process. It quashed the FIR and all subsequent legal proceedings, including the charge-sheet and the trial, highlighting that the facts did not establish the criminal offences alleged by the complainant.
Conclusion:
This case underscores the importance of carefully examining the nature of the relationship and the consistency of allegations before proceeding with serious charges like rape and criminal intimidation. The Supreme Court's decision reinforces the need to prevent the misuse of legal provisions in cases where the allegations do not meet the necessary legal thresholds. It also serves as a reminder that personal disputes, particularly those arising from failed relationships, should not be transformed into criminal matters unless there is clear evidence of criminal conduct.
Code of Criminal Procedure, 1973