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Delhi High Court: The Delhi High Court has delivered a significant ruling on the misuse of criminal law in cases arising out of failed romantic relationships, observing that a consensual relationship which later turns bitter cannot be retrospectively labelled as rape. Emphasising the importance of consent and factual context, the Court quashed a First Information Report alleging rape and caste-based atrocity, holding that continuation of the criminal proceedings would amount to an abuse of the legal process.

Background of the Case and Judicial Approach

The matter was examined by a single-judge bench of Justice Swarana Kanta Sharma of the Delhi High Court, which carefully analysed the factual matrix and the material placed on record. The Court underlined that allegations emerging from broken relationships require heightened judicial scrutiny, especially when both parties are adults and have shared a prolonged association marked by voluntary intimacy.

According to the Court, criminal law cannot be permitted to become a tool for settling personal scores when emotional relationships fail. Such an approach, it warned, risks diluting the seriousness of sexual offence laws and undermining their intended purpose.

Findings on Consent and Nature of Relationship

A central aspect of the ruling was the Court’s analysis of consent. The judgment noted that the complainant and the accused had known each other for nearly four years and had remained in regular contact throughout this period. Their interactions included frequent meetings and extensive digital communication, which the Court found to be consistent with a consensual romantic relationship rather than a coercive or exploitative one.

The verified WhatsApp chats placed before the Court reflected mutual affection and normal exchanges between two consenting adults. Importantly, the Court observed that even after the date of the alleged incident, communication between the parties continued in a manner that did not suggest force, threat, or compulsion.

Delay in FIR and Evidentiary Gaps

While acknowledging that delay in reporting sexual offences is not uncommon and does not automatically weaken a prosecution, the Court held that such delay becomes relevant when assessed alongside other surrounding circumstances. In the present case, the FIR was lodged approximately five months after the alleged incident.

The Court noted that during this period, the complainant continued to remain in touch with the accused. When read cumulatively with the nature of the communications, this delay assumed significance and raised doubts about the narrative of non-consensual conduct.

Medical Evidence and Conduct of the Complainant

On the issue of medical evidence, the Court recorded that there were no injuries or corroborative medical findings to support the allegation of forcible sexual assault. While absence of injuries is not decisive in every case, the Court found that in the present factual scenario, it further weakened the prosecution’s case.

Additionally, the Court took note of the complainant’s failure to produce her mobile phone for examination despite a statutory notice. This non-compliance, the Court held, was a relevant factor in assessing the overall credibility of the allegations, particularly when digital communication formed a crucial part of the prosecution story.

Promise of Marriage and Legal Threshold

The complainant had also alleged sexual exploitation on the false promise of marriage. Rejecting this claim, the Court clarified that for such an allegation to sustain, there must be material indicating dishonest intent at the inception of the relationship.

In this case, the Court found no evidence suggesting that any promise of marriage was made with deceitful intent. The conversations between the parties did not reveal any assurance of marriage and instead pointed to a relationship that evolved gradually with the consent of both individuals.

SC/ST Act Allegations and Legal Clarification

Addressing the invocation of provisions under the SC/ST (Prevention of Atrocities) Act, the Court reiterated that such charges can be sustained only when an offence is committed on the ground of the victim’s caste identity. After examining the record, the Court found no contemporaneous material or verified communication indicating that the alleged acts were motivated by caste considerations.

In the absence of such foundational evidence, the Court held that the application of the caste-based offence provision was legally unsustainable.

Final Decision and Legal Significance

Concluding that the case squarely met the parameters for exercising inherent powers under Section 482 of the Criminal Procedure Code, the Court quashed the FIR along with all consequential proceedings. The ruling reinforces the principle that while allegations of sexual violence must be treated with utmost seriousness, the criminal justice system cannot be misused to criminalise consensual relationships that later fail.

This judgment is likely to have a wider impact on how courts approach similar allegations, reaffirming the need for careful evaluation of consent, intent, and surrounding circumstances before allowing criminal prosecution to proceed.