Background of the Dispute The Supreme Court in Ajeet Singh v. State of Uttar Pradesh & Ors. dealt with a case involving allegations of rape based on a promise of marriage. According to the complaint, the appellant and the victim were in a relationship and had developed feelings for each other. It was alleged that the appellant established a physical relationship with the victim on the assurance that he would marry her. When disputes arose between the families, an FIR was registered against the appellant for offences under Sections 376 and 506 of the IPC. The appellant approached the High Court seeking quashing of the FIR. However, the High Court declined to interfere, leading to an appeal before the Supreme Court.
Supreme Court's Findings The Supreme Court closely examined the material placed on record and found significant inconsistencies in the allegations. One of the most important documents considered by the Court was a legal notice issued on behalf of the victim herself. In that notice, the victim expressly described herself as the wife of the appellant and stated that a marriage had been solemnised between them according to Hindu rites at an Arya Samaj Mandir. The Court also noted that shortly thereafter, the appellant had filed a petition for restitution of conjugal rights under Section 9 of the Hindu Marriage Act. The victim's own statement indicated that the relationship between the parties continued over a period of time and ultimately culminated in marriage. In these circumstances, the Supreme Court held that the allegation that the physical relationship was maintained solely because of a false promise to marry was not supported by the material on record.
Why the Decision Matters Cases involving allegations of rape on the basis of a false promise to marry often require courts to carefully distinguish between a genuine case of deception and a consensual relationship that later turns sour. This judgment reiterates that every failed relationship or matrimonial dispute cannot automatically give rise to criminal prosecution for rape. The Court emphasised that where the material clearly shows a consensual relationship that eventually resulted in marriage, allegations that consent was obtained through a false promise of marriage may not be sustainable. The decision highlights the importance of examining the surrounding circumstances and documentary evidence rather than relying solely on the allegations contained in the FIR.
Key Takeaways from the Judgment What stands out in this case is the Court's focus on the admitted facts rather than the later allegations. The victim's own legal notice acknowledged the marriage and described the parties as husband and wife. The record also showed that the relationship had progressed beyond a mere promise and had culminated in a marriage ceremony. In our view, the judgment reinforces an important principle: criminal law should not be used to convert every relationship dispute into a prosecution for rape. The Supreme Court did not enter into disputed questions of fact. Instead, it examined whether the allegations in the FIR, when read alongside the admitted documents, disclosed the commission of an offence at all. Finding that they did not, the Court intervened to prevent misuse of the criminal process.
Relief Granted by the Court The Supreme Court set aside the judgment of the Allahabad High Court and quashed the FIR registered against the appellant. The Court held that the case fell within the principles laid down in State of Haryana v. Bhajan Lal, particularly where the allegations are such that no prudent personcould conclude that sufficient grounds exist for proceeding with the prosecution. Accordingly, the criminal proceedings against the appellant were brought to an end.
Conclusion The decision in Ajeet Singh v. State of Uttar Pradesh underscores that allegations of rape based on a false promise to marry must be assessed in light of the entire factual background. Where a consensual relationship ultimately culminates in marriage and the surrounding material contradicts the allegation of deception, criminal prosecution may not be justified. The judgment serves as a reminder that courts must carefully distinguish between genuine cases of exploitation and disputes arising from failed relationships or matrimonial discord.
