Legal Review and Analysis of Samadhan S/o Sitatram Manmothe vs State of Maharashtra & Another 2025 INSC 1351

In-Short

Case: Samadhan Sitatram Manmothe vs State of Maharashtra & Anr. (2025 INSC 1351)
The Supreme Court quashed rape charges, ruling that a long-term consensual relationship cannot be criminally prosecuted as rape under Section 376(2)(n) IPC merely because it fails to lead to marriage. Converting a sour relationship into a rape case amounts to an abuse of the process of the court.

1. Heading of the Judgment

Case Title: Samadhan S/o Sitatram Manmothe vs State of Maharashtra & Another
Citation: 2025 INSC 1351
Court: Supreme Court of India
Jurisdiction: Criminal Appellate Jurisdiction
Criminal Appeal No.: 5001 of 2025 (Arising out of SLP (Crl.) No. 6906 of 2025)
Judges: Justice B.V. Nagarathna and Justice R. Mahadevan
Date of Judgment: November 24, 2025

2. Related Laws and Sections

This judgment interprets and applies the following legal provisions:

• Indian Penal Code, 1860 (IPC):
  Section 375: Defines the offence of Rape.
  Section 376: Prescribes punishment for rape.
  Section 376(2)(n): Prescribes enhanced punishment for whoever "commits rape repeatedly on the same woman".
  Section 507: Prescribes punishment for Criminal intimidation by an anonymous communication.

• Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS):
  Section 528: Corresponds to Section 482 of the CrPC, 1973. It preserves the inherent powers of the High Court to make such orders as may be necessary to prevent abuse of the process of any court or otherwise to secure the ends of justice.

3. Basic Judgment Details

• Appellant: Samadhan Sitatram Manmothe (An Advocate accused in the FIR)

• Respondents: State of Maharashtra & The Complainant (Respondent No. 2)

• Origin of the Case: The appellant, an advocate, was handling the maintenance case of Respondent No. 2. They developed a close relationship which involved physical intimacy over approximately three years (2022-2024). When the relationship soured and the appellant refused to pay a demanded sum of money, Respondent No. 2 filed an FIR alleging rape based on a false promise of marriage.

• FIR Details: FIR No. 294 of 2024 dated 31.08.2024 for offences under Sections 376, 376(2)(n), and 507 of the IPC.

• Lower Court Proceedings:
  Trial Court: The appellant was granted anticipatory bail. A chargesheet was subsequently filed.
  High Court: The Bombay High Court at Aurangabad dismissed the appellant's petition under Section 528 of the BNSS seeking quashing of the FIR, stating that the matter required a trial.

• Path to Supreme Court: The appellant challenged the High Court's order before the Supreme Court.

4. Core Legal Principles and Judicial Analysis

The Central Issue

The core legal issue before the Supreme Court was whether a long-term, seemingly consensual physical relationship between two adults can be retroactively classified as rape under Section 376(2)(n) of the IPC merely because the relationship did not culminate in marriage, or whether such a case represents an abuse of the process of the court.

The Supreme Court's Analysis and Reasoning

The Court's analysis was a meticulous application of settled legal principles to the specific facts of the case, leading to a robust judgment that distinguishes between a genuine offence and a vindictive complaint.

A. Distinguishing Consensual Relationships from "Rape Repeatedly" under Section 376(2)(n) IPC

The Court began by analyzing the gravamen of Section 376(2)(n), which mandates a minimum of ten years of imprisonment for committing rape "repeatedly on the same woman". It emphasized that the term "repeatedly" contemplates a series of distinct, non-consensual acts of sexual assault, often under circumstances of fear, pressure, captivity, or continued deceit. The provision is designed for aggravated instances of sexual violence where the victim is rendered vulnerable and unable to escape.

• Application to Facts: The Court found the present case to be the complete antithesis of this legal conception. The relationship spanned three years, involved voluntary meetings at hotels, and continued even after the complainant initially refused the marriage proposal. There was no allegation of force, threat, or captivity at the time of the incidents. The Court held that physical intimacy within a protracted, functioning relationship cannot be branded as "rape repeatedly" simply because the relationship eventually broke down.

B. The Legal Test for "False Promise of Marriage" Vitiating Consent

A significant part of the judgment was dedicated to the doctrine of "consent vitiated by a misconception of fact" arising from a false promise of marriage. The Court, relying on its precedents in Mahesh Damu vs. State of Maharashtra, (2024) 11 SCC 398 and Deepak Gulati vs. State of Haryana, (2013) 7 SCC 675, laid down the following crucial principles:

• The promise must be false to the knowledge of the accused at the very inception of the relationship.

• It must be made with a clandestine motive and no intention of being fulfilled, solely to exploit the woman.

• The physical relationship must be directly and solely traceable to this false promise, and not influenced by other considerations like love, passion, or personal liking.

• A mere breach of a promise to marry due to unforeseen circumstances is distinct from a false promise made in bad faith from the beginning and constitutes a civil wrong, not a crime.

• Application to Facts: The Supreme Court found that the complainant's own narrative defeated her case. She had initially opposed the idea of marriage, yet continued the physical relationship. The relationship endured for a long period, and the FIR was lodged only after a monetary demand was refused. The Court found no evidence that the appellant had a mala fide intention and never intended to marry her from the very beginning.

C. Condemnation of the Criminalization of Failed Relationships

The Court expressed profound concern over the growing trend of converting sour relationships into criminal cases of rape. It observed, citing Prashant vs. State of NCT of Delhi, (2025) 5 SCC 764, that "what was a consensual relationship between the parties at the initial stages cannot be given a colour of criminality when the said relationship does not fructify into a marriage." The Court warned that such misuse trivializes the grave offence of rape, inflicts an indelible stigma on the accused, and clogs the criminal justice system, amounting to a gross abuse of the process of law.

5. Final Outcome and Supreme Court's Directions

The Supreme Court allowed the appeal and set aside the impugned order of the Bombay High Court. It issued the following final direction:

• The FIR No. 294 of 2024 dated 31.08.2024, registered with City Chowk Police Station, and the consequent Chargesheet No. 143 of 2024 dated 25.10.2024, were quashed.

6. (MCQs) Based on the Judgment

Question 1: According to the Supreme Court's judgment in Samadhan Manmothe, for a 'false promise of marriage' to vitiate consent and constitute rape, what is a crucial determining factor?
(a) The relationship must have lasted for at least one year.
(b) The accused must have made the promise in writing.
(c) The false promise must have been made with a mala fide intention and no intention to marry from the very inception of the relationship.
(d) The complainant must be unmarried at the time of the relationship.

Question 2: The Supreme Court quashed the FIR in this case primarily on the grounds that?
(a) The appellant was an advocate and deserved immunity.
(b) The complainant was already married to someone else.
(c) The facts unmistakably indicated a protracted consensual relationship, and pursuing criminal charges in such a scenario was an abuse of the process of law.
(d) The police investigation was conducted improperly.