Delhi High Court Quashes Rape FIR, Emphasizes Failed Relationships Are Not Criminal Offences
In a significant ruling, the Delhi High Court has quashed a First Information Report (FIR) alleging rape and caste-based atrocity against a man, observing that a consensual relationship turning sour cannot be retrospectively branded as rape. The court stated that rape laws cannot be misused as a tool to criminalise a failed or broken relationship.
Court's Observations on Failed Relationships and Criminal Liability
Justice Swarana Kanta Sharma, while quashing the proceedings, noted that the present case is an example of a failed relationship. The decision of the man to withdraw from the relationship was not accepted, and the consequences of such breakdown were sought to be addressed through the initiation of criminal proceedings.
The court further emphasized that courts must carefully scrutinise sexual assault allegations emerging from failed relationships. This is especially crucial when the material indicates a long-standing consensual relationship between adults and where any promise of marriage was not demonstrably false at the outset.
Adult Awareness and Uncertainties in Romantic Relationships
The high court added that it cannot be overlooked that an adult—particularly an educated and independent one who voluntarily enters a romantic relationship after exercising free and conscious choice—must be aware of the uncertainties associated with such relationships. It is neither inevitable nor assured that every romantic relationship will result in marriage, the court said.
The dissolution of a relationship, by itself, does not give rise to criminal liability. The court cautioned against the growing tendency to convert failed relationships into criminal prosecutions, highlighting the need for judicial prudence in such matters.
Examination of Evidence and Communication Records
The court noted that the complainant and the accused had known each other for nearly four years and remained in continuous contact. This included frequent meetings and extensive WhatsApp communication. Upon reviewing the chat records, the court found that they reflected mutual affection and normal interaction even after the alleged incident.
There was no indication of coercion, force, or caste-based abuse in the communications. The court also considered the five-month delay in filing the FIR, saying it gained significance in light of the continued communication between the complainant and the accused after the alleged incident.
Medical Evidence and Credibility of Allegations
Medical evidence was cited as revealing no injuries or corroborative findings to support the allegation of forcible sexual assault. Additionally, the court noted that the woman did not produce her mobile phone despite a statutory notice, which was a relevant factor in assessing the credibility of her allegations.
Clarification on SC/ST (Prevention of Atrocities) Act Charge
Regarding the SC/ST (Prevention of Atrocities) Act charge, the high court clarified that the provision applies only when an offence is committed on the basis of the victim's caste identity. The court found no contemporaneous material or verified communication suggesting caste motivation, rendering the charge unsustainable.
This ruling underscores the importance of distinguishing between genuine criminal offences and the fallout of failed personal relationships, ensuring that legal provisions are not misapplied.
