Justice Satish Chandra Sharma Emphasizes in Supreme Court Verdict That Failed Romantic Relationships Do Not Automatically Translate into Offences Under Section 376 IPC

Introduction

An important decision was handed down by the Supreme Court of India on May 26, 2025, in the case of Amol Bhagwan Nehul vs. State of Maharashtra and Another. This decision established the law regarding charges of rape that are based on promises of marriage.

When two consenting adults are involved in a romantic relationship, the Court ruled that the mere failure to fulfill a promise of marriage cannot automatically lead to charges under Section 376 of the Indian Penal Code (IPC).

This is the case unless it is clearly demonstrated that the consent for sexual intercourse was obtained through deceit, coercion, or fraud. In a piece that he wrote for the Bench, Justice Satish Chandra Sharma outlined the legal framework that governs situations of this kind.

He emphasized how important it is to differentiate between true instances of trust abuse and false charges that are made in order to abuse the legislative process.

History of the Case and Facts of the Situation

An agricultural student named Amol Bhagwan Nehul, who was 23 years old at the time, was implicated in the case. He was in a relationship with a lady who had just received a divorce and was now living with her kid.

Amol is accused of having sexual contact with the lady on several times, despite the fact that she was under the erroneous impression that they were married. The woman filed the complaint. Additionally, she said that he had separated himself from her in the future, borrowed money, and utilized her automobile for his own personal motives.

After almost thirteen months had passed since the claimed occurrences, the complaint was finally filed.

Amol, on the other hand, refuted all of the charges and said that the connection was one that he voluntarily entered into. The individual who filed the complaint allegedly harassed him, followed him to his college, and threatened to incriminate him in a fictitious rape case, according to his statement.

Additionally, his father filed a non-cognizable complaint with the police, stating that the complainant had harassed him and threatened with physical violence.

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Concerning the Legal Provisions Involved

The allegations that were brought against Amol were quite severe and comprised the following sections of the Indian Penal Code: Section 376 (rape), Section 376(2)(n) (repeated rape), Section 377 (unnatural sex), Section 504 (intentional insult with intent to cause disturbance of peace), and Section 506 (criminal intimidation).

According to Section 482 of the Code of Criminal Procedure (CrPC), which gives High Courts the authority to prohibit abuse of the legal process, Amol filed a petition with the High Court of Bombay in order to have the First Information Report (FIR) thrown out. But the petition that he submitted was denied by the High Court. Afterwards, he filed an appeal with the Supreme Court.

Key Concerns That Were Taken Into Account by the Court

To establish whether the criminal case against Amol should be permitted to proceed or if it was an abuse of legal laws, the Supreme Court was urged to make a decision. The most important question was whether or whether the complainant’s agreement to sexual intercourse was founded on a deliberate false promise of marriage, which would make the complainant subject to criminal culpability under Section 376 of the Indian Penal Code.

In addition to this, the court was required to determine whether or not there was any evidence to back up the charges of criminal intimidation or unnatural intercourse, as well as whether or not the complainant’s general behavior corroborated her assertions.

The Meaning of Consent According to Section 90 of the Indian Penal Code

The necessity of having a clear grasp of what precisely constituted valid consent was highlighted by the Court. It is stated in Section 90 of the Indian Penal Code that permission is not considered genuine if it is given owing to fear or because of a misunderstanding of the facts. In situations of claimed rape that include fraudulent promises of marriage, the courts have repeatedly maintained that in order for the promise to be considered rape, it must be false from the very beginning, and the male must have had no intention of marrying the woman from the very beginning.

Within the context of this particular case, the Supreme Court made the observation that the connection between the two persons was one that was voluntary, that it lasted for more than a year, and that it involved a number of meetings, trips, and stays at lodges. There was no evidence to suggest that Amol had made a false promise of marriage with the goal of tricking the complainant into engaging in a sexual relationship.

Because of the absence of evidence and the delay in filing the complaint

It was also noted by the court that the First Information Report (FIR) was submitted more than a year after the claimed first event. The complainant maintained the connection over this time period, which included engaging in activities such as traveling and staying together on a number of times. It was because of this delay, in addition to the absence of any medical proof or other indications of compulsion, that the reliability of the charges was called into question.

Moreover, there was no evidence to suggest that Amol had participated in criminal intimidation or issued threats against the individual. The court came to the conclusion that the complainant had freely entered into a relationship with the appellant, and that the evidence submitted did not provide sufficient foundation for charges under Sections 376, 377, 504, or 506 of the Indian Penal Code.

Reliance on the Guidelines Provided by Bhajan Lal

The court made reference to the seminal decision that was handed down in the case of State of Haryana vs. Bhajan Lal, which established standards for the dismissal of First Information Reports (FIRs) under Section 482 of the Criminal Procedure Code. In the case of Bhajan Lal, one of the types that was recognized is the situation in which the claims that are included in the FIR are so ludicrous or fundamentally unlikely that no reasonable person could come to the conclusion that a crime has been committed.

By using this approach, the court came to the conclusion that the complaint against Amol was within the Bhajan Lal categories, particularly those that were associated with the misuse of the judicial process and the intention to commit a crime with malice.

A remark about the inappropriate application of rape laws

Justice Satish Chandra Sharma made the observation that while laws that protect women from sexual abuse are necessary, the misuse of these laws may have severe repercussions, particularly for young people.

It was advised in the ruling that every failed relationship or broken promise of marriage should not be treated as a criminal offense. Even in the event that a romantic connection is terminated in a negative manner, it should not always result in criminal prosecution unless there is convincing proof of fraud or coercion.

The Supreme Court has voiced its worry with the rising tendency of using rape claims as a weapon in failed relationships.

This not only places a strain on the judicial system, but it also may be detrimental to the accused person’s image and future prospects. The Court cautioned that this kind of exploitation undermines the credibility of allegations that are really legitimate.

The Court’s Final Decision is as follows:

The Supreme Court overturned the ruling of the High Court and dismissed the First Information Report (FIR) as well as all proceedings against Amol. This decision was made after taking into consideration the circumstances, the absence of proof, the delay in making the complaint, and the mature age of both people involved.

It was highlighted by the court that continuing with the trial would not serve any purpose and would be unfair to a young guy who still has his whole life ahead of him.

The Finalization

The decision that was handed down in the case of Amol Bhagwan Nehul vs the State of Maharashtra serves as a striking reminder of the need of conducting thorough investigations in instances that include claims of sexual offenses that are predicated on promises of marriage.

The notion that consent must be evaluated in light of the complete relationship and behavior of the individuals involved was reaffirmed by the Supreme Court of the United States. The verdict respects the balance between preserving the rights of women and protecting persons from false charges that abuse legal laws. persons are protected from false accusations.

This case emphasizes the need of making responsible use of the criminal justice system and reinforces the necessity of the courts serving as a shield against malicious prosecution. In addition to this, it highlights the need of having a mature legal knowledge of consent, relationships, and the boundaries of criminal law in cases that involve personal and emotional judgments between adults.