Ranchi, September 3: The Jharkhand High Court has quashed criminal proceedings in a rape case involving a man and a woman who had been in a relationship for more than seven years, observing that the failure of a proposed marriage does not by itself establish that a promise to marry was false from the beginning.
Justice Anil Kumar Choudhary passed the order while hearing a petition seeking cancellation of the FIR and subsequent proceedings against the accused.The case concerned a relationship that began in 2016 after the petitioner and the complainant met at a friend’s wedding.
According to the complaint, the two remained in contact and subsequently entered into a physical relationship after the man allegedly assured the woman that he would marry her.The complainant alleged that their relationship continued for several years.
She further stated that the two stayed at a hotel in Ranchi in December 2022, where they had a physical relationship. She later alleged that the man ended the relationship, stopped communicating with her and did not agree to the proposed marriage.
Following the dispute, a criminal case was registered and the police later filed a charge sheet. The trial court subsequently took cognizance of the alleged offence under Section 376(2)(n) of the Indian Penal Code.
The accused approached the High Court seeking quashing of the proceedings. His counsel argued that both parties were adults and had remained in a relationship voluntarily for a considerable period. It was also submitted that there was no material indicating that the accused had decided from the outset not to marry the woman.
The High Court examined whether the alleged promise of marriage was fraudulent when it was made or whether the relationship subsequently failed for other reasons.The Court relied on the legal principles laid down by the Supreme Court in cases involving allegations of sexual relationships based on promises of marriage.
It noted that the mere fact that a marriage did not eventually take place cannot, by itself, establish that the original promise was dishonest.
According to the Court’s assessment of the material before it, there was no specific allegation or evidence sufficient to demonstrate that the petitioner had entered the relationship with a predetermined intention to deceive the complainant.
The Bench also considered the prolonged nature of the relationship. The parties had remained associated for more than seven years, and the material placed before the Court did not indicate that the relationship was based on a fraudulent promise from its inception.
The High Court consequently held that the allegations did not disclose the essential ingredients required to continue the criminal proceedings under the alleged provision.
Finding that further continuation of the case would amount to an abuse of the judicial process, the Court quashed the FIR, the criminal proceedings arising from it and the cognizance order issued by the trial court on August 16, 2024.
The ruling in Lalu Mahtha @ Lalu Mahta v. State of Jharkhand and Another, Criminal Miscellaneous Petition No. 915 of 2025, highlights the legal distinction between a genuinely deceptive promise of marriage and a relationship in which marriage was contemplated but ultimately did not take place.
The judgment makes clear that the crucial consideration in such cases is the intention of the person making the promise at the time it was made, rather than the mere fact that the relationship later ended without marriage.
