Supreme Court Quashes FIR Under Section 69 BNS, Holds No Deceitful Conduct in Broken Marriage Promise

Case Snapshot

• Case Name: Kunal Rameshbhai Kalyani v. The State of Gujarat & Anr.

• Citation: 2026 INSC 987 (Reportable)

• Bench: Justice J.B. Pardiwala and Justice K. Vinod Chandran

• Date of Judgment: September 7, 2026

• Area of Law: Criminal Law, Bhartiya Nyaya Sanhita, Promise to Marry, Deceitful Conduct, Quashing of FIR

The Judgment in One Line

Supreme Court quashes FIR under Section 69 BNS, holding that a broken promise to marry due to parental opposition does not constitute deceitful conduct.

Why This Judgment Matters

This judgment is a significant clarification on the scope of Section 69 of the Bhartiya Nyaya Sanhita, which criminalizes deceitful conduct in sexual relations under the pretext of marriage. The Court establishes that the offence requires proof that the accused had no intention of fulfilling the promise from the very beginning. A promise made with good intention but later broken due to unavoidable circumstances does not attract criminal liability. The ruling protects individuals from prosecution for consensual relationships that later break down.

Background

The appellant and the complainant met through a digital platform, and their friendship deve

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