Summary and Analysis of Amol Bhagwan Nehul vs. State of Maharashtra (2025 INSC 782)
Case Details
Citation: 2025 INSC 782
Court: Supreme Court of India
Judges: Justices B.V. Nagarathna and Satish Chandra Sharma
Appellant: Amol Bhagwan Nehul
Respondents: State of Maharashtra & Anr.
Key Legal Provisions:
Sections 376 (rape), 376(2)(n) (repeated rape), 377 (unnatural sex), 504 (intentional insult), and 506 (criminal intimidation) of the Indian Penal Code (IPC).
Section 482 of the Code of Criminal Procedure (CrPC) (inherent powers of the High Court to quash proceedings).
Background and Issues
Factual Background:
The complainant (Respondent No. 2), a divorced woman with a 4-year-old child, alleged that the appellant, a 23-year-old student, repeatedly had sexual intercourse with her between June 2022 and July 2023 under the false promise of marriage.
She claimed the appellant forcibly engaged in sexual acts, including unnatural sex, and later avoided her after borrowing money and using her car.
The FIR was filed on 31.07.2023, 23 days after the last alleged incident and 13 months after the first incident.
The appellant denied the allegations, asserting the relationship was consensual and that the complainant harassed him after he refused marriage.
Procedural History:
The appellant was granted anticipatory bail by the Additional Sessions Judge, Karad, who noted the complainant’s consensual participation in the relationship.
The High Court dismissed the appellant’s petition under Section 482 CrPC to quash the FIR, leading to this appeal.
Key Issues:
Whether the complainant’s consent was vitiated by a false promise of marriage, constituting rape under Section 376 IPC.
Whether the FIR and chargesheet disclosed prima facie offences or were abuse of process under State of Haryana v. Bhajan Lal (1992).
Supreme Court’s Analysis
Consent and False Promise of Marriage:
The Court emphasized that consensual relationships between adults do not amount to rape merely because the promise of marriage is unfulfilled (Naim Ahmed v. State (NCT) of Delhi, 2023).
The complainant’s conduct—maintaining the relationship for over a year, visiting lodges, and delaying the FIR—contradicted her claim of forcible intercourse.
Absence of Misconception of Fact (Section 90 IPC):
No evidence showed the appellant never intended to marry her. The complainant was already married (until December 2022) and knew the appellant’s promise was legally unenforceable.
Delay and Mala Fide Intent:
The 13-month delay in reporting, coupled with the complainant’s unilateral visit to the appellant’s family, suggested ulterior motives and disgruntlement.
Medical and Corroborative Evidence:
No medical proof supported allegations of forcible or unnatural sex.
The chargesheet relied solely on the complainant’s uncorroborated testimony.
Abuse of Process (Bhajan Lal Guidelines):
The FIR fell under Categories 5 and 7 of Bhajan Lal:
Inherently improbable allegations (no prudent person would believe the complainant’s version).
Malicious prosecution due to personal vendetta after the relationship soured.
Judgment and Directions
Quashing of Proceedings:
The Supreme Court allowed the appeal, quashing the FIR (C.R. No. 490/2023) and subsequent proceedings (RCC No. 378/2023).
The Court held the case was a clear misuse of criminal machinery to settle personal grievances.
Key Observations:
Consensual relationships cannot be criminalized retrospectively due to broken promises.
Courts must scrutinize delayed complaints to prevent frivolous prosecutions under Section 376 IPC.
The appellant, a young student, was spared a lengthy trial that would have unjustly stigmatized him.
Final Outcome:
FIR and proceedings quashed; appellant discharged.
Conclusion
The judgment reaffirms the principle that breach of a promise to marry does not automatically constitute rape unless consent was vitiated by fraudulent intent at the outset.
It cautions against weaponizing sexual offence laws to harass partners after consensual relationships end.
The ruling aligns with precedents protecting individuals from malicious prosecutions while upholding the sanctity of genuine rape cases.
Blog Posts
