P. N. v. State of Chhattisgarh & Others, 2026
The Court reaffirmed settled jurisprudence distinguishing false promise of marriage from a mere breach of promise.
Judgement Details
Court
Supreme Court of India
Date of Decision
5 February 2026
Judges
Justice B. V. Nagarathna & Justice Ujjal Bhuyan
Citation
Acts / Provisions
Facts of the Case
- The complainant, a 33-year-old advocate, was a married woman with a pending divorce petition.
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She alleged that the appellant, also an advocate, established a physical relationship with her from September 2022 to January 2025 on a promise of marriage.
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The complainant became pregnant during the relationship and alleged that she was compelled to undergo an abortion.
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After disputes with the appellant and his family, she lodged an FIR in February 2025.
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The FIR was registered under Section 376(2)(n) IPC, alleging repeated rape on the same woman.
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The Chhattisgarh High Court refused to quash the criminal proceedings.
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Aggrieved, the appellant approached the Supreme Court of India seeking quashing of the FIR.
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It was an admitted fact that the complainant was legally married throughout the alleged relationship.
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The appellant argued that any promise of marriage to a married woman was legally impossible from inception.
Issues
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Whether a promise of marriage made to a woman who is legally married can constitute a false promise so as to vitiate consent under Section 375 IPC?
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Whether sexual relations between two aware, educated adults, in the given facts, amounted to rape under Section 376(2)(n) IPC?
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Whether continuation of criminal proceedings in cases arising from a consensual relationship gone sour amounts to an abuse of process of law?
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Whether the High Court erred in refusing to quash the FIR despite absence of mens rea to deceive from the inception?
Judgement
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The Supreme Court allowed the appeal.
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The impugned order of the Chhattisgarh High Court was set aside.
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The criminal proceedings under Section 376(2)(n) IPC were quashed.
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The Court held that the facts did not disclose the essential ingredients of rape on the basis of false promise of marriage.
Held
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A promise of marriage can vitiate consent only when it is shown to be false from the very inception and made solely to obtain sexual consent.
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A married woman cannot plead inducement on a promise of marriage which is legally impermissible under Section 5(i) of the Hindu Marriage Act, 1955.
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The relationship in the present case was consensual, involving two adults aware of each other’s circumstances.
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Criminal law should not be invoked to settle disputes arising out of personal relationships turning acrimonious.
Analysis
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The Court reaffirmed settled jurisprudence distinguishing false promise of marriage from a mere breach of promise.
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Emphasis was placed on mens rea at inception as the determinative factor in rape cases based on promise of marriage.
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The complainant’s subsisting marriage made performance of any promise of marriage legally impossible, negating deception.
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The judgment cautions against over-criminalisation of failed relationships.
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The Court reiterated concerns expressed in Prashant v. State of NCT of Delhi and Samadhan v. State of Maharashtra.
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The ruling strengthens safeguards against misuse of Section 376 IPC while preserving protection for genuine victims.
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It reinforces the need for judicial caution before allowing prosecution in such sensitive cases.