XXX vs. State of Madhya Pradesh [March 6, 2024]
Background
This Supreme Court case centered on allegations of rape committed under the false promise of marriage. The petitioner (XXX) sought quashing of the FIR at the initial stage, arguing that the case was an abuse of process and that the facts did not constitute an offence of rape, as the physical relationship was consensual.
Factual Matrix
The complainant alleged that the accused established a sexual relationship with her by promising marriage, but later reneged on this promise. The FIR was registered under Section 376 of the Indian Penal Code (rape). The accused approached the Supreme Court after failing to secure relief from lower courts, seeking quashing of the FIR on the grounds that the relationship was consensual and the promise of marriage was not made in bad faith.
Legal Issues
Whether the FIR alleging rape on the basis of a false promise of marriage should be quashed at the threshold.
Whether the facts disclosed in the FIR, if accepted as true, constituted an offence of rape under Section 376 IPC.
Supreme Court’s Analysis
The Court reiterated established principles regarding quashing of FIRs at the initial stage:
At the stage of considering a petition for quashing, the Court must accept the allegations in the FIR as true and examine whether they prima facie disclose the commission of an offence.
The distinction between a false promise (made without intention to marry from the outset) and a breach of promise (where intention existed but circumstances changed) is crucial in such cases.
Upon examining the facts, the Court found that the allegations in the FIR, if taken at face value, made out a clear case of rape on the basis of a false promise to marry. The FIR specifically alleged that the accused never intended to marry the complainant and induced her into a physical relationship by deception.
Judgment
The Supreme Court refused to quash the FIR, holding that the matter involved disputed questions of fact requiring trial. The Court emphasized that the allegations, if proved, would constitute an offence under Section 376 IPC. It was held inappropriate to interfere at the preliminary stage, as the FIR disclosed a cognizable offence and the investigation should proceed.
Significance
The judgment reinforces the principle that FIRs alleging rape on a false promise of marriage should not be quashed at the threshold if the allegations, on their face, disclose an offence.
The Court clarified that such cases must be decided on evidence at trial, not at the stage of quashing.
Citation:
Supreme Court of India, XXX vs. State of Madhya Pradesh, March 6, 2024.
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