Delhi High Court Sets Legal Precedent in Landmark Rape Case Judgment
The Delhi High Court has delivered a significant verdict, acquitting a man previously convicted of rape based on allegations of false promise of marriage. In a judgment that clarifies crucial legal principles regarding consent, Justice Manoj Kumar Ohri established that a subsequent refusal or failure to marry does not automatically render the original promise false.
The court emphasized that for a promise to be considered false from the beginning, the prosecution must prove that the intention to deceive existed at the very outset of the relationship. This ruling came while hearing an appeal against a trial court conviction that had sentenced the man to seven years of imprisonment under Section 376 of the Indian Penal Code.
Case Background and Competing Narratives
The case originated from allegations made by a woman who claimed she was residing with her mother and giving dance training to children when the appellant rented a room in their house in February 2012. According to her testimony, the man began talking to her after a month and eventually proposed marriage.
The complainant alleged that while returning from her dance academy, the appellant picked her up in his van and took her to a guest house where he allegedly committed sexual intercourse despite her resistance. She stated that he repeated his promise to marry her and continued to have sexual intercourse multiple times on the same assurance.
However, the appellant presented a completely different version of events, asserting that he never had physical relations with the complainant nor made any promise to marry her. He alleged that the complainant's mother wanted him to marry her daughter, and when he refused, he was falsely implicated in the case.
Court's Critical Observations and Reasoning
Justice Ohri's judgment highlighted several crucial aspects that raised doubts about the prosecution's case. The court noted that the parties had known each other for several months before the alleged incident and maintained a close, voluntary association during which sexual intercourse occurred multiple times.
Several factors contributed to the court's decision to acquit:
- The complainant's improvements to her testimony during the trial
- Her continued association with the appellant after the alleged incident
- Unexplained delay in filing the complaint between February and June 2012
- Absence of corroborative medical evidence
- Multiple sexual encounters over an extended period
The court observed that a sexual relationship maintained over time between two adults ordinarily raises a presumption of valid and conscious consent. The judgment stated: "Keeping in view the lapse of time between the alleged first act on 09.02.2012 and the eventual complaint in June 2012, the parties' continued contact and repeated sexual relations during that period, and the absence of corroborative medical or forensic material, this Court finds that substantial doubt arises as to whether the physical relationship, if any, was nonconsensual or vitiated by misconception of fact."
Legal Principles Established
The judgment made important clarifications about when consent can be considered vitiated in cases involving promise of marriage. The court affirmed that if it can be shown that at the time of making the promise, the promisor never intended to honor it and made such promise solely to induce the woman into sexual relations, the consent obtained would stand vitiated by misconception of fact.
However, in this particular case, the prosecution failed to prove that the physical relationship was non-consensual or that her consent stood vitiated. The cumulative effect of the inconsistencies in the complainant's testimony and the surrounding circumstances led the court to set aside the rape conviction.
This judgment, delivered on November 13, 2025, provides significant legal guidance for similar cases where relationships break down after promises of marriage, distinguishing between genuine cases of deception and situations where parties consent to relationships that eventually don't lead to marriage.
