Facts
The complainant (Ms. A), a lecturer M.Com & B. Ed qualified, on 5th July 2022 went to police station of Bakewar, District Etawah filed an FIR against appellant Rajnish Singh @ Soni. (Case Crime No. 269/2022). [1]
Allegations date back to 2006, when appellant sneaked into complainant house at night and forcefully committed sexual intercourse. Later, apologized to her and promised for marriage.
Then over the years their intimacy continued, in 2009 appellant drugged her (complainant) and recorded obscene videos of her, after which he used those videos to blackmail her.
She also alleged miscarriage induced by him through spiked drinks.
During 2006 – 2021 appellant also extort money from complainant, in which there was cheque of Rs.94, 000.
In 2021 complainant got to know that appellant is having relationship with another women named “Namrata”.
Then on March 2022 complainant filed a complaint in one stop center, Lalitpur which got closed because appellant signed an agreement to marry the complainant. But on 22nd April 2022 appellant married to Namrata.
After complainant said everything to her family and community, after which following threats and intimidation were alleged.
On this basis, offences under section 313, 376, 384, 323, 504, 506 IPC were registered. Later, section 313 IPC and involvement of co – accused were dropped by investigating officer.
The magistrate took cognizance, and the appellant’s petition for quashing (under section 482 CrPC) before Allahabad High Court was dismissed on 24th April 2023. This led to present appeal before the Supreme Court.
Issues Raised
- Whether the High Court was justified in quashing the criminal proceedings under Section 482 CrPC at the stage of cognizance, despite serious allegations made by the complainant?
- Whether the allegations of rape, blackmail, assault, and forced miscarriage made against the accused, Ragnish Singh @ Soni, prima facie disclosed a case under sections 313, 376, 384, 323, 504, and 506 IPC (now corresponding provisions under the Bharatiya Nyay Sanhita, 2023), sufficient to proceed with trial?
- Whether the defenses of “consensual relationship” based on the promise of marriage and subsequent marriage to another women can be accepted at the quashing stage, without allowing the case to go through full trial?
- Whether the principle that inherent jurisdiction under section 482 CrPC should be exercised sparingly and only in the rarest of rare cases was properly applied by the High Court in quashing the proceedings?
Contention
Contention of the Appellant (Rajnish Singh @ soni):
- Unreliable Evidence: appellant argued that convictions are wrong because prosecution witnesses’ statements are contradictory and unreliable. Several discrepancies existed between their depositions before the police and their testimony in court. [2]
- Failure to establish motive: prosecution not able to establish any clear motive that why appellant did these crimes, which make the case weak. [3]
- Benefit of doubt: the appellant emphasized that inconsistencies in the prosecution’s version were so material that they should have been resolved in his favor, in line with the principle that the benefit of doubt must go to the accused. [4]
- Erroneous Appreciation by lower courts: both trial court and high court ignore these lapses and appreciate the evidence in a wrong way, for which conviction got sustain. [5]
- Misapplication of Law: it was further contended that the conviction under sections 302 and 307 IPC was unsustainable in law as the prosecution did not meet the standard of proof “beyond reasonable doubt”. [6]
Contention of the Respondent (state of U.P):
- Credible witness Testimony: state argued that prosecution witnesses were natural and trustworthy, and their depositions were corroborate each other on material points. [7]
- Minor contradictions not fatal: The respondent emphasized that minor inconsistencies in witness testimony were immaterial and did not affect the prosecution’s case as a whole.[8]
- Confirmation by Lower courts: both trial court and high court scrutinize different evidence and found appellant guilty, which makes their findings more credible. [9]
- Gravity of offence: the respondent contended that the evidence on record clearly established the appellant’s guilty under sections 302, and 307 IPC, and therefore the conviction and sentences were fully justified. [10]
- No grounds for acquittal: the state asserted that the appellant was not entitled to acquittal or benefit of doubt since the prosecution had discharged its burden satisfactorily. [11]
Rationale
Issue 1: Supreme Court held that high court did wrong by dismissing the petition. Court repeated that the power of section 482 CrPC exist to stop the “abuse of report” and deliver justice. Since the allegations in the FIR, even if taken at face value, did not disclose the commission of the offences alleged, allowing the proceedings to continue would have amounted to harassment. The court therefore set aside the high court’s refusal to quash and exercised its inherent jurisdiction.[12]
Issue 2: court noticed that investigation itself dropped the section 313 IPC and excluded other accused due to lack of evidence. As to section 376 IPC, the court emphasized that the complaint, being an educated adult, maintained a voluntary relationship with the accused over 16 years, which could not later be constructed as rape. Similarly, the allegations of blackmail, intimidation, and extortion were unsupported by consistent evidence. Accordingly, the court held that no prima facie case was made out to justify a full trail.[13]
Issue 3: court answered this by yes. On the basis of precedent, court held that breach of promise to marry will only categorized as rape when it will prove that the intent of promise has been false and mala fide from the start.[14] In this case, complainant continue having intimate and long – term voluntary relationship with the accused, even after marriage of the accused, clearly shows that this was an “consensual relationship” not coerced. Therefore, the defense of consent was rightly accepted at the quashing stage.[15]
Issue 4: court clarified that this was precisely such a case warranting intervention. Where the allegations are impossible, stale, and inherently unreliable, allowing the criminal process to continue would be an abuse of law. The Supreme Court emphasized that the object of section 482 CrPC is not to stifle legitimate prosecutions but to protect individuals from malicious or baseless proceedings. Since the complainant’s allegations were inconsistent and belated, this case fell within the exceptional category justifying quashing. [16]
Defects of Law – Rajnish Singh @ Soni v. State of U.O. (2025 INSC 308)
- Ambiguity in ‘False promise of marriage = Rape’ Doctrine
Indian courts approach is not clear when the breach of promise becomes rape. Some judgment treat it as rape if the promise was false from inception (Deepak Gulati), while others take a stricter or looser view.
This inconsistency leaves scope for misuse of rape provisions in long – term relationship.
- Delay in FIR and evidentiary standards
In this FIR lodged 16 years after the alleged first incident. While delay can be explained in genuine cases, such a long gap raises serious evidentiary concerns.
The law lacks clear statutory guidance on how much delay should weaken the prosecution’s case.
- Overlap of consent and coercion
This case shows show the thin line between consensual relationship and coercion under the threat of promise. Current law (IPC section 375; now BNS section 63) which clearly does not define that “consent under misconception of fact” applies in long – term relationship.
- Overuse of section 482 CrPC petition
While the SC emphasized that inherent powers must be used sparingly, in practice, section 482 CrPC is increasingly invoked to quash FIRs even before trial.
This creates a tension between accused’s liberty and victim’s right to trial.
- Lack of protection for victims in Intimate partner exploitation
The law is not – equipped to handle cases where intimate partners exploit trust without clear evidence of initial deceit.
This gap risks leaving genuine victims unprotected while also exposing accused persons to harassment.
Inference
Rajnish singh @ soni v. state of Uttar Pradesh, 2025 INSC 308 case reaffirm an important balance between safeguarding an accused from harassment through frivolous prosecutions and protecting the complainant’s right to fair trial. The Supreme Court quashed that a prolonged consensual relationship spanning 16 years, without of coercion or deceit at inception, cannot later be retrospectively characterized as rape merely due to the accused’s subsequent refusal to marry.
The judgment is significant because it:
- Clarifies the scope of section 482CrPC by underscoring that inherent powers must be exercised sparingly, but should intervene when proceedings are clearly abusive or baseless.
- False promise of marriage = rape only if deceit existed at the beginning, aligning with precedents such as Deepak Gulati v. State of Haryana.
- Highlights the necessity of prima facie evidence before subjecting an accused to trial, especially in cases involving long – term intimate relationships.
Thus, the inference drawn is that the Supreme Court, through this judgment, sought to prevent misuse of rape provisions in consensual relationships while upholding the broader constitutional mandate under Article 21 to protect individual liberty against unwarranted criminal prosecution.
Name: Tasneem nafiss
College name: capital law college, Bhubaneswar odisha
[1] Rajnish singh @ soni v. state of U.P., 2025 INSC 308,
[2] Kali ram v. state of Himachal Pradesh, (1973) 2 SCC 808;
[3] Surinder Kumar v. state (Delhi Admn.), (1977) 1 SCC 697 ;
[4] Sharad Birdhichand sarda v. state of Maharashtra, (1984) 4 SCC 116 ;
[5] State of U.P. v. Krishna Gopal, (1988) 4 SCC 302.
[6] Hanumant govind nargundkar v. state of M.P., AIR 1952 SC 343;
[7] State of U.P. v. M.K. Anthony, (1985) 1 SCC 505;
[8] Appabhai v. state of Gujarat, 1988 supp SCC 241;
[9] State of Rajasthan v. kashi ram, (2006) 12 SCC 254 ;
[10] Indian penal code, No. 45 of 1860, s 302, 307 ;
[11] State of Punjab v. karnil singh, (2003) 11 SCC 271
[12] Code of criminal procedure, No. 2 of 1947, s 482; state of Haryana v. bhajan lal, 1992 Supp (1) SCC 335
[13] Indian penal code, No. 45 of 1860, ss 313, 376, 384, 323, 504, 506; Rupan deol bajaj v. kanwar pal singh gill, (1995) 6 SCC 194;
[14] Deepak Gulati v. state of Haryana, (2013) 7 SCC 675;
[15] Prashant v. state (NCT of Delhi), 2024 SCC online SC 3375;
[16] Zandu pharmaceutical works ltd. V. mohd. Sharaful haque, (2005) 1 SCC 122.