SC RULING: RAVISH SINGH RANA CASE ON LIVE-IN, CONSENT & FALSE PROMISE UNDER

 Ravish Singh Rana v. State of Uttarakhand & Anr.

Introduction:-

In Ravish Singh Rana v. State of Uttarakhand & Anr. Criminal Appeal No. 2438 of 2025, the Supreme Court delivered a significant judgment that provides clarity on the nuanced intersection of live-in relationships, consent, and false promise of marriage in the context of rape allegations under Section 376 IPC. Setting aside the Uttarakhand High Court's refusal to quash an FIR, the Court emphasized a contextual and contemporary approach to interpreting "consent" and "misconception of fact" in relationships between consenting adults.

Factual Background:-

• The appellant and the complainant have been in a live-in relationship since February 2021.

• An FIR (No. 482/2023) was filed by the complainant at PS Khatima, Udham Singh Nagar, on 23.11.2023, alleging rape, assault, and criminal intimidation under Sections 376, 323, 504, and 506 IPC.

• The complainant alleged that the appellant established a physical relationship with her on the promise of marriage, which he later refused to fulfill.

• Notably, a settlement agreement dated 19.11.2023, a day after the alleged sexual assault was executed by both parties, affirming mutual love and intent to formalize marriage.

• The High Court dismissed the appellant’s plea under Section 528 BNSS (equivalent to Section 482 CrPC), refusing to quash the FIR.

• The appellant approached the Supreme Court by way of special leave.

Key Legal Issues:-

1. Whether a live-in relationship spanning two years can be the basis for a rape charge premised on a false promise of marriage.

2. Whether the FIR disclosed prima facie commission of rape or constituted an abuse of the court’s process.

Observations and Analysis by the Supreme Court:-

1. Presumption of Valid Consent in Prolonged Live-in Relationships- The Court emphasized that two adults cohabiting in a live-in relationship for more than two years, fully aware of the implications, gives rise to a presumption of valid consent. There was no evidence to suggest that the complainant’s consent was vitiated by deceit at the inception.

2. Reaffirmation of Legal Position from Precedents- The Court relied upon the following judgments:

• Pramod Suryabhan Pawar v. State of Maharashtra [(2019) 9 SCC 608], which held that a breach of a promise is distinct from a false promise.

• Deepak Gulati v. State of Haryana [(2013) 7 SCC 675], which clarified that the court must examine the intent at the time of the promise to marry.

• Sonu @ Subhash Kumar v. State of U.P. [(2021) 18 SCC 517], where the FIR was quashed in a consensual relationship after the accused expressed unwillingness to marry.

The judgment distinguished between a false promise made with a militant and a relationship that broke down due to later circumstances.

3. Role of the Settlement Agreement- The Court found the settlement agreement dated 19.11.2023 one day after the alleged incident of rape to be inconsistent with the accusation of forcible sexual assault. It reaffirmed mutual affection and intent to marry, undercutting the claim of coercion or deceit.

4. A Contemporary Approach to Social Realities- Recognizing the evolving nature of intimate relationships, the Court observed:

"A decade or two earlier, live-in relationships might not have been common. But now more and more women are financially independent and have the capacity to take conscious decisions of charting their life on their own terms."

It cautioned against adopting a “pedantic approach,” urging courts to factor in the autonomy and agency of individuals in live-in arrangements.

Conclusion and Holding:-

The Supreme Court held that the allegations in the FIR did not prima facie disclose the commission of rape or any other cognizable offence that warranted prosecution. The FIR and the consequent proceedings were quashed as an abuse of the process of law. The appeal was allowed. The judgment of the Uttarakhand High Court was set aside.

Significance of the Judgment:-

This decision underscores a progressive jurisprudence on sexual autonomy and consent, contextualized within modern relational dynamics. The Court’s insistence on distinguishing between a genuine emotional breakdown and exploitation via false promises is critical in preventing misuse of criminal law while safeguarding genuine victims. By quashing the FIR, the Court sends a clear message that criminal law cannot be weaponized against failed relationships that were entered into with mutual consent. It is a reaffirmation of the principle that every failed promise does not amount to fraud, and that courts must delve deeper into the intent behind such promises rather than rely on superficial allegations.