New Delhi – In a big ruling on February 5, 2026, the Supreme Court of India quashed an FIR and all related proceedings in a rape case against a lawyer from Bilaspur, Chhattisgarh. The Court said that a physical relationship between two grown-up people — when the woman is already married — cannot be called rape just because the relationship ends badly.
The bench of Justice B.V. Nagarathna and Justice Ujjal Bhuyan allowed the appeal of Pramod Kumar Navratna. They set aside the Chhattisgarh High Court’s order of March 3, 2025, which had refused to quash the case. The FIR No. 213/2025 was filed on February 6, 2025 at Sarkanda Police Station under Section 376(2)(n) of the Indian Penal Code (now under Bharatiya Nyaya Sanhita). The chargesheet and the sessions case in Bilaspur court were also cancelled.
Background of the Case
The woman who filed the complaint is a 33-year-old lawyer. She married Mitendra Kumar Dhirde in 2011 and they have a son born in 2012. Their marriage had problems, so the husband filed for divorce in 2018. The family court dismissed that petition in November 2024. The husband’s appeal is still pending in the Chhattisgarh High Court.
At the time of the alleged incidents — from September 2022 to January 2025 — the woman was still legally married.
She met the accused, also a lawyer, at a social event on September 18, 2022. They became friends. He used to pick her up and drop her home. She told him about her pending divorce case.
What the FIR Alleged
On February 6, 2025, the woman lodged the FIR. She said that on the first day they met, the accused took her to a friend’s house on the excuse of picking up documents and raped her. When she protested, he promised to marry her and even put sindoor (vermilion) on her forehead.
After that, they had physical relations many times, with him repeatedly promising marriage. She said she became pregnant, but he refused to marry or accept the child and forced her to take abortion pills. On January 27, 2025, when she went to his house to talk, his family allegedly assaulted and threatened her.
On the same day, the accused also filed a complaint with the Superintendent of Police, saying the woman was harassing and blackmailing him and his family for marriage.
What Happened in Lower Courts
The accused got anticipatory bail from the Chhattisgarh High Court on March 3, 2025. But on the same day, the High Court dismissed his petition to quash the FIR. The judges said the allegations needed full investigation and consent issues could not be decided at that early stage.
Later, the police filed a chargesheet in April 2025 under Section 376(2)(n) IPC, and the case was numbered as Sessions Case No. 89/2025 in Bilaspur district court.
Supreme Court’s Decision and Key Observations
The Supreme Court looked at the FIR, the chargesheet, and all records. The judges said that even if everything in the FIR is taken as true, no offence of rape under Section 376(2)(n) is made out.
Important points from the judgment:
- The woman was already married. Under Section 5(i) of the Hindu Marriage Act, she could not marry anyone else while her first marriage was alive. So any promise of marriage by the accused was not legally possible.
- Both were lawyers. They knew the law well. The woman herself told the man early on that she was married and divorce proceedings were going on.
- The Court said: “It is difficult to believe that a married woman who is herself an advocate was induced into sexual relations on the false pretext of marriage… especially when both parties were fully aware of her subsisting marriage.”
- The judges quoted earlier cases like Naim Ahamed vs State (NCT of Delhi) 2023 and others. They said a mere break-up of a relationship cannot be turned into a rape case.
- The Court observed: “The facts clearly indicate a consensual relationship gone sour… both parties should have exercised restraint and refrained from involving the State in their personal matter.”
- They warned: “To convert every soured relationship into an offence of rape not only trivialises the seriousness of the offence but also causes grave injustice to the accused.”
Using the famous Bhajan Lal case guidelines (1992), the Supreme Court said continuing the case would be an abuse of the process of law. So they quashed everything.
Why This Judgment Matters
This ruling is important because many cases of “rape on false promise of marriage” come to courts every year. The Supreme Court has repeatedly said that not every broken promise is rape. The promise must be false from the very beginning, made only to get consent for sex, and the woman must have believed it and given consent only because of that promise.
In this case, since the woman could never legally marry the man, the promise could not be acted upon. So consent could not be called “obtained by misconception”.
Lawyers say this judgment will help protect innocent men from false or exaggerated complaints after consensual affairs end badly. At the same time, it does not dilute real rape cases.
Many women’s rights groups may worry that it could make genuine victims hesitant, but the Court has clearly said genuine cases where there was real deception will still be prosecuted.
Reactions and Expert Views
Senior lawyers welcomed the judgment. One senior advocate in Delhi said: “This is a balanced ruling. It protects the sanctity of rape law while stopping its misuse in personal disputes.”
Another lawyer from Chhattisgarh said: “Both parties were educated professionals. They knew what they were doing. Turning a failed relationship into a criminal case was not right.”
No official reaction has come yet from the woman or her side.
What Happens Next?
The entire case against Pramod Kumar Navratna is now closed. He is free from all charges. The police and trial court will have to close the file.
This judgment will be used as precedent in many similar cases across the country.
FAQs
Q1. Can a married woman ever file a rape case on false promise of marriage?
A: Yes, but only if she proves that the man made a false promise with bad intention from the start, and she gave consent only because she truly believed he would marry her. In this case, since she was already married, the promise could never be fulfilled, so the Court said consent was not vitiated.
Q2. What is Section 376(2)(n) IPC?
A: It is the section for punishment when a man commits rape repeatedly on the same woman. Punishment is minimum 10 years, up to life imprisonment.
Q3. Why did the Supreme Court say the relationship was consensual?
A: Because the woman continued the relationship for more than two years, she knew her own marital status, and both were aware of the legal position. It was not a one-time incident based on deception.
Q4. Will this judgment encourage misuse of relationships?
A: The Court has actually warned against misusing rape law. It said both men and women should be responsible in personal relationships and not drag the police and courts into every break-up.
Q5. Is this the first such judgment?
A: No. The Supreme Court has given similar rulings in many cases before, like Naim Ahamed (2023), but this one is very clear on the point when the woman is already married.
Q6. Can the woman now challenge this order?
A: Review petitions are rare and usually not successful in such matters. The judgment is final.