Supreme Court Quashes Conviction in False Promise of Marriage Case Following Parties’ Marriage

In a rare and sensitive intervention, the Supreme Court of India quashed the conviction and sentence of Sandeep Singh Thakur, who had been convicted under Sections 376(2)(n) and 417 of the Indian Penal Code (IPC) for allegedly obtaining consent for sexual intercourse on the basis of a false promise of marriage. The dispute arose from a consensual relationship that escalated into criminal proceedings following misunderstandings over the timing of marriage. Upon judicial intervention, the parties reconciled and got married. Exercising powers under Article 142 of the Constitution, the Court quashed the FIR, conviction, and sentence, emphasizing both the equitable and social aspects of justice. The case illustrates how criminal liability in sensitive personal matters must be assessed in light of intent, consent, and reconciliation possibilities.

Case Background

The appellant, Sandeep Singh Thakur, first met the second respondent, a woman, in 2015 through a social media platform. The parties developed mutual liking and fondness, which gradually evolved into a consensual physical relationship. Over time, the second respondent alleged that the appellant had promised marriage but failed to fulfil this promise. Believing she had been misled, she filed FIR No.29 of 2021 on 02.11.2021 under Sections 376 and 376(2)(n) IPC, alleging sexual intercourse obtained on the basis of a false promise of marriage. The chargesheet was subsequently filed on 08.02.2022.

The Additional Sessions Judge, Sagar, tried the appellant in Sessions Trial No.191 of 2022. The trial court convicted him under Section 376(2)(n) IPC, sentencing him to ten years rigorous imprisonment and a fine of Rs.50,000, and under Section 417 IPC, sentencing him to two years rigorous imprisonment and a fine of Rs.5,000. The conviction was based on the prosecutrix’s claim that the appellant had obtained sexual consent through a false promise of marriage.

Aggrieved, the appellant filed Criminal Regular Appeal No.4869 of 2024 before the Madhya Pradesh High Court, seeking both suspension of the sentence and appellate relief. The High Court rejected IA No.9352 of 2024, which sought suspension of the jail sentence, on 05.09.2024. Consequently, the appellant approached the Supreme Court to challenge the rejection of interim relief.

The Supreme Court noted that the matter presented exceptional circumstances where the relationship between the appellant and the prosecutrix could potentially be reconciled. Recognizing that the criminal dispute had arisen from a misunderstanding rather than deliberate deception, the Court sought to explore whether the parties were willing to marry, thereby potentially resolving the conflict outside continued litigation.

What the Lower Authorities Held

At the trial stage, the Additional Sessions Judge, Sagar, found that the appellant had intentionally misled the prosecutrix with a false promise of marriage, thus satisfying the ingredients of Sections 376(2)(n) and 417 IPC. The court imposed substantial rigorous imprisonment terms along with fines, reflecting the gravity of the charges.

The Madhya Pradesh High Court, on appeal, declined to suspend the sentence despite an application for interim relief. The High Court held that the trial court’s findings warranted immediate enforcement of the sentence. This left the appellant in custody while his appeal was pending before the Supreme Court.

The Supreme Court’s Reasoning

Upon intervention, the Supreme Court took an approach blending legal, social, and equitable considerations. The Court observed that the essence of the dispute was a consensual relationship that had inadvertently assumed a criminal character due to a misunderstanding about the timing of marriage. Recognizing the possibility of reconciliation, the Court invited counsel for both parties to explore whether the appellant and prosecutrix were willing to marry.

During hearings on 06.05.2025, 15.05.2025, and 25.07.2025, the Court interacted with both parties in the presence of their parents. It was confirmed that both were willing to marry. Consequently, the Court granted interim bail to the appellant to facilitate marriage arrangements. The marriage occurred on 22.07.2025, and the parties have been cohabiting since.

Observing that the allegations had stemmed from a misunderstanding rather than intent to deceive, the Court concluded that continuing criminal proceedings would serve no meaningful purpose. The Court held that its powers under Article 142 allowed it to quash the FIR, conviction, and sentence to achieve complete justice.

(i) Suspension of Sentence

The appellant’s initial request for suspension of sentence was denied by the High Court. The Supreme Court, however, taking into account the unique circumstances, including the parties’ willingness to reconcile, granted interim bail. This not only allowed the appellant temporary liberty but also created an environment conducive to resolving the underlying personal dispute.

(ii) Quashing of FIR and Conviction

Upon confirmation of marriage between the parties, the Court determined that continuing the criminal proceedings would not only be unnecessary but also contrary to the interests of justice. Utilizing Article 142, the Court quashed the FIR lodged with Women Police Station, District Sagar, the conviction, and the sentence passed by the Additional Sessions Judge, and rendered the appeal pending before the High Court infructuous.

(iii) Restoration of Employment and Arrears

The appellant had been suspended from his government service due to the criminal proceedings and resulting conviction. Recognizing the quashing of proceedings as grounds for revocation of suspension, the Court directed the Chief Medical Officer, Sagar, to reinstate the appellant and pay arrears of salary within two months. This underscores the Court’s comprehensive approach to remedy both criminal and administrative consequences.

(iv) Reconciliation and Social Harmony

The Court emphasized that reconciliation between the parties was central to achieving complete justice. By facilitating dialogue and personally hearing the parties and their families, the Court ensured that the intervention was not merely legalistic but also socially constructive. This approach reflects an understanding of the societal and personal dimensions in cases of alleged false promises of marriage.

Statutory Interpretation

Sections 376(2)(n) and 417 IPC were interpreted in light of the circumstances. Section 376(2)(n) deals with sexual acts obtained by misrepresentation or deceit, while Section 417 criminalizes cheating. The Court noted that application of these provisions requires careful analysis of intent and consent. Allegations must be distinguished from situations where misunderstandings or delays in marriage arrangements create temporary disputes.

The judgment clarifies that consent and mutual intent to marry are crucial factors in assessing criminal liability in false promise of marriage cases. By invoking Article 142, the Court emphasized that equitable considerations may override rigid statutory application where it serves justice.

Why This Judgment Matters

This judgment is significant for multiple reasons. First, it demonstrates the Court’s capacity to employ Article 142 to deliver complete justice, balancing legal, social, and personal considerations. Second, it establishes that allegations of false promises of marriage must be carefully analyzed, with attention to consent, intent, and the possibility of reconciliation.

For legal practitioners, the judgment illustrates that courts may consider mediation and reconciliation as part of the resolution in sensitive criminal matters. It underscores the importance of holistic legal analysis, encompassing not only statutory interpretation but also the social realities of the parties involved.

Additionally, the case highlights the administrative consequences of criminal convictions, such as suspension of government employees. By ordering reinstatement and payment of arrears, the Court ensured that justice was not only declaratory but practically effective.

In broader jurisprudential terms, the case sets a precedent for courts to adopt flexible, equitable, and socially sensitive approaches while interpreting criminal statutes and exercising discretionary powers.

Final Outcome

The Supreme Court disposed of the appeal as follows:

• Quashed FIR No.29 of 2021 lodged with Women Police Station, District Sagar.
• Quashed the conviction and sentence of the appellant under Sections 376(2)(n) and 417 IPC.
• Declared Criminal Regular Appeal No.4869 of 2024 pending in the High Court infructuous.
• Directed the Chief Medical Officer, Sagar, to revoke the appellant’s suspension and pay arrears of salary within two months.
• Disposed of Criminal Appeal No.5256 of 2025 and all pending applications.

Case Details

• Case Title: Sandeep Singh Thakur vs. State of Madhya Pradesh & Another
• Citation: Criminal Appeal No.5256 of 2025
• Court & Bench: Supreme Court of India; Judges: B.V. Nagarathna & Satish Chandra Sharma, JJ.
• Date of Judgment: December 5, 2025