Lalu Yadav v. The State of Uttar Pradesh & Ors SLP (Crl) No. 9371 of 2018

In this case court held that the allegations in the FIR disclosed a prima facie case of rape under Section 376 IPC or causing miscarriage under Section 313 IPC.

• The facts of the case are as follows: 
• The complainant alleged that Lalu Yadav established a physical relationship with her on the pretext of marriage and started living with her as her husband. 
• The relationship lasted between 2013 and 2018, during which the complainant’s family was aware of their cohabitation.
• The complainant became pregnant during this period, and Lalu Yadav allegedly administered medicines that caused her miscarriage.
• After securing employment in the army, Lalu Yadav refused to marry the complainant, leading to the filing of an FIR in 2018 under Sections 376 and 313 IPC.
• Upon investigation, no evidence was found to substantiate the allegation of miscarriage, and charges under Section 313 IPC were dropped. 

1. Whether the allegations in the FIR disclosed a prima facie case of rape under Section 376 IPC or causing miscarriage under Section 313 IPC?
2. Whether the High Court was correct in refusing to quash the FIR?

• The FIR was registered after a delay of more than five years from the alleged incidents.
• This delay raised serious doubts about the credibility of the allegations.
• The complainant's FIR stated both that the accused established a physical relationship without her consent and that they lived as husband and wife for several years.
• The Court found this inconsistency significant and indicative of a consensual relationship.
• For consent to be vitiated under a "false promise to marry," there must be evidence that the promise was false from the outset.
• The Court found no prima facie evidence to suggest that Lalu Yadav entered into the relationship with a false promise to marry.
• The investigation ruled out of no evidence of the complainant being forced into a miscarriage, leading to the dropping of charges under Section 313.
• The Court highlighted its powers under Section 482 CrPC to prevent the abuse of legal processes and ensure justice.
• The Supreme Court quashed the criminal proceedings, holding that the FIR revealed a case of a consensual relationship rather than coercion or fraud.
• It noted that the High Court should have exercised its jurisdiction to quash the FIR under Section 482 CrPC.

• The Court distinguished between consensual relationships and cases of false promises, preventing misuse of laws. 
• The decision emphasized consistency in allegations and evidence in FIRs. 
• Acknowledging the significant delay in filing the FIR adds weight to ensuring fair treatment of accused persons. 
• Balancing fairness to the accused with the need to protect genuine victims of exploitation remains a critical challenge. 
• The judgment underscores the potential for misuse of stringent laws if not supported by evidence, raising the bar for proving false promises of marriage.