A Consensual Relationship Turning Sour Is Not Ground for Criminal Prosecution: Supreme Court Quashes Rape Case in Amol Nehul Judgment

Case Summary

• Case Name: Amol Bhagwan Nehul v. The State of Maharashtra & Anr.

• Date of Judgment: 26 May 2025

• Coram: Hon’ble Justice B.V. Nagarathna and Hon’ble Justice Satish Chandra Sharma

• Appellant’s Counsel: Mr. Nishant Ramakantrao Katneshwarkar

• Respondents’ Counsel: Mr. Sachin Patil, Additional Advocate General for the State of Maharashtra

• Acts & Sections Involved:

  • Indian Penal Code, 1860 – Sections 376, 376(2)(n), 377, 504 & 506

  • Code of Criminal Procedure, 1973 – Section 482

• Cited Judgments:

  • State of Haryana v. Bhajan Lal (1992 Supp (1) SCC 335)

  • Naim Ahmed v. State (NCT) of Delhi (2023 SCC OnLine SC 89)

Introduction

In a crucial reaffirmation of the boundary between consensual relationships and criminal culpability, the Supreme Court in Amol Bhagwan Nehul v. The State of Maharashtra & Anr. delivered a judgment that continues the judiciary's cautious approach in dealing with allegations of rape premised on promises to marry. This judgment not only emphasises judicial scrutiny of factual matrices in such cases but also underscores the inherent powers under Section 482 of the CrPC to prevent abuse of the legal process.

The Factual Contours

The Appellant, a 23-year-old agriculture student residing in Karad, Maharashtra, was accused by the Respondent No. 2 of repeatedly engaging in non-consensual sexual relations under the pretext of a promise to marry her. The relationship, which spanned over a year, included multiple instances of alleged sexual intercourse and unnatural sex, accompanied by financial assistance and usage of the complainant’s car. Importantly, the complainant was a divorced mother residing with her child.

The FIR dated 31 July 2023 alleged offences under Sections 376, 376(2)(n), 377, 504 and 506 IPC. The Appellant moved the Bombay High Court under Section 482 CrPC for quashing the FIR and the subsequent proceedings, which was dismissed. The present appeal before the Apex Court arose from that dismissal.

Key Observations of the Hon’ble Supreme Court

The Bench, comprising Hon’ble Justice Satish Chandra Sharma and Hon’ble Justice B.V. Nagarathna, undertook a meticulous examination of the complaint, the charge-sheet, and the parties' conduct throughout their relationship. The key takeaway from their findings lies in their cautious disentanglement of emotional breakdown from criminal culpability.

1. No Misconception of Fact:

“Even if the allegations in the FIR are taken as a true and correct depiction of circumstances, it does not appear from the record that the consent of the Complainant/Respondent No. 2 was obtained against her will and merely on an assurance to marry.”

The Court ruled that the consent was not vitiated by any “misconception of fact” under Section 90 IPC. The complainant, a major and educated woman, continued her relationship voluntarily for over a year, including visits to lodges and giving personal loans. This long-standing association diluted any presumption of coercion or deception.

2. Delay in Filing FIR:

Another crucial factor was the unexplained delay of over 13 months from the first alleged incident. This cast doubt on the credibility of the complaint and suggested an element of afterthought or personal vengeance.

3. Behavioural Inconsistencies:

The Court pointed out inconsistencies in the complainant’s behaviour. Despite claiming rape, she maintained frequent contact with the appellant, even accompanying him to public spaces and staying in hotels.

“The narrative of the Complainant does not corroborate with her conduct.”

This insight aligned with the judicial view that conduct inconsistent with the gravity of the alleged offence undermines the veracity of the allegations.

Jurisprudential Reinforcement: Bhajan Lal Guidelines

The judgment is strongly anchored in the State of Haryana v. Bhajan Lal decision, especially paragraphs 102(5) and 102(7), which detail scenarios justifying quashing of proceedings under Section 482 CrPC.

“The present case squarely falls under categories enumerated in Para 102(5) & 102(7) as identified by this Court in State of Haryana v. Bhajan Lal….”

The Court ruled that the case was not only manifestly attended with mala fide but also inherently improbable on the face of the allegations.

The Question of ‘False Promise to Marry’

Indian courts have frequently grappled with the criminalisation of sexual relationships that later deteriorate. In distinguishing between a false promise and a failed relationship, the Court leaned on its ruling in Naim Ahmed v. State (NCT) of Delhi, where it had warned against blanket criminalisation of failed romantic engagements.

“A consensual relationship turning sour or partners becoming distant cannot be a ground for invoking criminal machinery of the State.”

This statement forms the moral and legal crux of the judgment—an acknowledgment that criminal law must not be weaponised in private relational disputes, especially when the prosecutrix is an adult capable of independent decisions.

Broader Implications for the Legal Community

This judgment reiterates vital doctrines that legal professionals and judicial officers must remain vigilant about:

• Prima facie scrutiny: Courts should not shy away from quashing proceedings where the FIR lacks foundational evidence of coercion or deception.

• Protection of liberty: Criminal trials, particularly under grave offences like rape, impose significant reputational and psychological burdens on the accused. Thus, pre-trial scrutiny is essential.

• Gender justice balance: While the judiciary continues to be empathetic to genuine cases of sexual violence, it remains cautious not to let the law become a tool for vindictive prosecution.

Discharge and Quashing

In conclusion, the Hon’ble Supreme Court quashed the FIR dated 31.07.2023 and the proceedings in RCC No. 378/2023 pending before the Additional Sessions Judge, Karad, observing:

“Taking into consideration that the Appellant is just 25 years of age, and has a lifetime ahead of him, it would be in the interest of justice that he does not suffer an impending trial…”

By setting aside the Bombay High Court’s dismissal and invoking its inherent powers, the Supreme Court shielded a young citizen from the potentially ruinous impact of a drawn-out trial on shaky factual ground.

Conclusion

The decision in Amol Bhagwan Nehul is a judicial reaffirmation that not every romantic fallout must be criminally litigated. It places emphasis on evidence-backed allegations, behavioural consistency, and the proportionality of criminal law’s invocation. Legal practitioners must note the evolving standards of consent, credibility, and prosecutorial discretion while dealing with cases of this nature.

In a justice system overburdened by frivolous or vengeful litigation, such judgments serve not only to protect individual liberty but also to remind the legal fraternity of its responsibility in upholding judicial economy and fairness.