Recently, the Delhi High Court ruled that the criminal justice system cannot be used to punish the mere breakdown of a consensual romantic relationship, noting that turning every failed relationship into a rape case trivializes the offense and causes ‘indelible stigma and grave injustice’ to the accused.

Brief Facts:

The case originated from FIR, registered at Police Station Wazirabad, Delhi, on September 13, 2023, under Section 376 of the Indian Penal Code and Section 3(2)(v) of the SC/ST Act. The prosecutrix, a Ph.D. scholar, alleged that the petitioner, whom she had known since 2019 through a student organization, forcibly subjected her to sexual intercourse on April 3, 2023, at his flat in Wazirabad.

 She further claimed that the petitioner had manipulated her with a false promise of marriage and had used derogatory casteist remarks, such as "Dalits are exploited, and now I will exploit you," during the alleged assault. However, the investigation revealed that the parties had been in regular communication for four years, with the prosecutrix staying at the petitioner's flat for several days in January 2023 prior to the alleged incident.

Contentions:

The Counsel for the Petitioner argued that the allegations were a result of a consensual romantic relationship spanning from 2019 to 2023 that had simply turned sour. He submitted that verified WhatsApp conversations between the parties reflected mutual affection rather than coercion and that the prosecutrix had suppressed material facts, including her stay at the petitioner's flat in January 2023 and her knowledge of his existing marriage in 2021. The petitioner emphasized that the five-month delay in filing the FIR and the lack of medical evidence further demonstrated that the criminal proceedings were an abuse of the process of law.

In contrast, the Counsel for the Respondent (Prosecutrix) vehemently opposed the petition, contending that the FIR disclosed serious cognizable offenses that warranted a full trial. She argued that the petitioner had exploited the prosecutrix's dignity and bodily autonomy under the false pretext of marriage, leveraging his knowledge of her Scheduled Caste identity to humiliate her. The State's counsel further noted that a chargesheet had already been filed and that the petitioner’s arguments regarding consent should be addressed during the trial stage rather than through a quashing petition.

Observations of the Court:

The Court conducted a meticulous analysis of the WhatsApp exchanges and the conduct of the parties, finding that the relationship was characterized by "mutual regard and affection" rather than coercion. Justice Swarana Kanta Sharma noted that the prosecutrix’s messages on April 4, 2023, the day after the alleged rape, were casual and "did not indicate any immediate distress or protest". Integrating recent Supreme Court precedents, the Court highlighted that physical intimacy during a functioning relationship cannot be "retrospectively branded" as rape merely because it fails to culminate in marriage. 

The Court further observed that for an offense under the SC/ST Act to be made out, it must be shown that the act was committed because the victim belonged to a protected caste, which was not supported by the contemporaneous materials on record. The judgment emphasized that an "educated and independent adult" must recognize that "the law cannot be invoked to criminalize the mere failure of a relationship".

The decision of the Court:

The Court allowed the petition and quashed FIR and all subsequent proceedings, concluding that the case fell squarely within the parameters for exercising inherent jurisdiction under Section 482 of the Cr.P.C.. The core legal principle (Ratio Decidendi) established is that a prolonged, consensual relationship between adults that ends in disappointment does not constitute rape, and the criminal justice system must not be misused to settle personal grievances arising from relationship breakdowns

Case Title: Dr Avadesh Kumar Vs. State Nct Of Delhi And Another

Case No.: Crl.M.C. 3/2025