Pramod Kumar Navratna v. State of Chhattisgarh & Others, 2026 INSC 124.
Factual Background
The case involves two legal professionals the appellant and the complainant who met at a social gathering in September 2022 and subsequently entered into a relationship. At the time their relationship began, the complainant was already married and had a ten-year-old son; although she was involved in divorce litigation with her husband, the marriage had not been legally dissolved.
In February 2025, the complainant filed an FIR alleging that the appellant had engaged in sexual relations with her by falsely promising to marry her, including a claim that he once applied vermilion to her head as a symbolic gesture. She further alleged that the relationship led to a pregnancy which the appellant forced her to terminate before he eventually ended the relationship. The appellant, conversely, maintained that the relationship was entirely consensual and that he was being harassed. After the High Court of Chhattisgarh refused to quash the criminal proceedings, the appellant approached the Supreme Court.
Issue(s)
- Whether sexual relations between two consenting adults can be classified as rape under Section 376(2)(n) of the IPC if the relationship was based on a promise of marriage that was legally impossible to fulfill.
- Whether the criminal proceedings against the appellant should be quashed to prevent an abuse of the judicial process.
Decision of the Supreme Court
The Supreme Court allowed the appeal and set aside the High Court’s order. The Court directed that the FIR, the subsequent chargesheet, and all related criminal proceedings against the appellant be quashed.
Reason for the Decision
The Court’s reasoning was based on several key legal and factual points:
- Legal Impossibility of Marriage: Under the Hindu Marriage Act, 1955, and the Special Marriage Act, 1954, a person cannot legally marry if they already have a living spouse. Since the complainant was still legally married when the alleged “promise” was made, such a promise was neither enforceable nor capable of being acted upon.
- Awareness of the Complainant: The Court noted that the complainant is an advocate and a mature adult. Given her profession, she was expected to understand that she was legally ineligible to marry the appellant while her first marriage still subsisted; therefore, she could not claim to have been “duped” or “misled” into a misconception of fact.
- Consensual Nature of the Relationship: The evidence suggested a consensual relationship that became bitter over time. The Court emphasized that a failed relationship or a “break-up” should not be given a “colour of criminality”.
- Distinction Between False Promise and Breach of Promise: The Court clarified that for a “false promise” to constitute rape, there must be a deceptive intent from the very beginning. In this case, the legal bar to marriage meant the allegations did not meet the threshold for criminal prosecution.
Conclusion
The Court concluded that the allegations, even if accepted as true, did not prima facie constitute the offence of rape. It held that continuing the prosecution would be an unjust use of the legal machinery for what was essentially a private dispute following a consensual relationship.
Official Judgment : Pramod Kumar Navratna v. State of Chhattisgarh & Others, 2026 INSC 124.
