RAVISH SINGH RANA .… APPELLANT(S)
Versus
STATE OF UTTARAKHAND & ANR. … RESPONDENT(S)
Date of Order:-28.04.2025
Introduction
The Supreme Court of India delivered a landmark judgment in April 2025, addressing the complexities of live-in relationships and the legal implications of broken promises of marriage. The case involved an appeal by Ravish Singh Rana against the Uttarakhand High Court’s refusal to quash an FIR accusing him of rape, assault, and criminal intimidation under Sections 376, 323, 504, and 506 of the Indian Penal Code (IPC).
Background of the Case
The complainant, a woman in a live-in relationship with Rana since 2021, alleged that he repeatedly had physical relations with her under the false promise of marriage. She claimed that when she insisted on marriage, Rana refused, threatened her, and even assaulted her. The FIR was filed in November 2023, leading to criminal proceedings. Rana, however, argued that their relationship was entirely consensual and supported by a settlement agreement signed by both parties in November 2023, which acknowledged their love and intention to formalize their relationship.
High Court’s Decision
The Uttarakhand High Court dismissed Rana’s petition to quash the FIR, ruling that the allegations disclosed a cognizable offense. The court did not consider the settlement agreement as conclusive evidence of consent, prompting Rana to appeal to the Supreme Court.
Supreme Court’s Analysis
The Supreme Court scrutinized the facts and legal precedents, emphasizing the following key points:
- Long-Term Consensual Relationship: The parties had lived together for over two years, cohabiting in a rented accommodation, which indicated voluntary participation in the relationship.
- Presumption of Consent: The Court held that in long-drawn live-in relationships, consent is presumed unless proven otherwise. Financial independence and societal changes make such relationships a conscious choice for many adults.
- False Promise vs. Breach of Promise: Citing Pramod Suryabhan Pawar (2019) and Deepak Gulati (2013), the Court distinguished between a false promise (made with deceitful intent) and a broken promise (due to unforeseen circumstances). The complainant failed to prove Rana’s mala fide intent at the outset.
- Settlement Agreement: The November 2023 agreement, which stated the parties “love each other,” contradicted the allegation of forced relations on November 18, 2023.
Judgment and Implications
The Supreme Court quashed the FIR, ruling it an abuse of the legal process. It underscored that:
- Live-in relationships, by nature, imply mutual consent unless coercion is proven.
- A mere breach of marriage promise does not equate to rape if the relationship was otherwise consensual.
- Courts must avoid a “pedantic approach” and consider societal evolution in evaluating such cases.
Conclusion
The judgment reaffirmed the autonomy of adults in live-in relationships while cautioning against weaponizing rape allegations after breakups. It balanced gender justice with the need to prevent misuse of criminal laws, setting a precedent for future cases involving similar disputes.
Final Order
The Supreme Court allowed Rana’s appeal, set aside the High Court’s order, and quashed all proceedings against him. The ruling highlighted the judiciary’s role in distinguishing between genuine abuse and consensual relationships gone sour.
About the Author: Neeraj Gogia, Advocate, 9891800100, specializing in family law cases, alimony, maintenance matters and custody cases etc. This article is intended for informational purposes only and does not constitute legal advice.
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