Supreme Court Quashes Rape Conviction After Marriage, Citing Complete Justice

The Supreme Court of India has quashed a rape conviction after taking note that the complainant and the accused had married each other before sentencing, holding that continuing the criminal proceedings would result in “jeopardy” and would not serve the ends of justice.

In its judgment dated December 28, 2025, a bench comprising Justices S. Narasimha and V. Ramasubramanian invoked the Court’s inherent powers to do “complete justice”. The Court observed that the case arose from a consensual relationship that had been characterised as rape on the ground of a broken promise to marry, a characterisation that, in the Court’s view, no longer warranted penal consequences once the parties had married and were living together.

The ruling, which has drawn attention for its unusual factual matrix, revisits the complex intersection of criminal law, consent, and matrimonial developments.

Facts Leading to the Appeal

The case concerned a conviction under Section 375 of the Indian Penal Code, specifically clause 2(n), which deals with repeated sexual intercourse with the same woman under certain circumstances. The prosecution case was that the accused had engaged in a sexual relationship with the complainant on the promise of marriage, which was later not honoured, leading to the registration of a rape case.

The trial court had convicted the accused, and the matter reached the Supreme Court after the conviction but before sentencing. During this period, a significant development took place. The complainant and the accused entered into marriage and began cohabiting as husband and wife.

It was this subsequent development that formed the basis of the appeal before the Supreme Court, seeking quashing of the conviction itself.

The Court’s Use of Inherent Powers

While considering the appeal, the Supreme Court emphasised that it was exercising its extraordinary jurisdiction to do complete justice between the parties. The bench noted that the power to do complete justice is meant to address situations where strict adherence to procedural outcomes may result in injustice.

The Court observed that the continuation of criminal proceedings, despite the marriage and reconciliation between the parties, would amount to subjecting the accused to jeopardy without any corresponding benefit to the complainant, who had herself chosen to settle into a matrimonial relationship with him.

The judgment makes it clear that the Court was not laying down a general rule, but was deciding the case on its specific facts.

Consent, Promise to Marry, and Criminal Prosecution

A central aspect of the case was the nature of consent in relationships that subsequently break down. Indian courts have repeatedly held that a false promise to marry, made with no intention of being fulfilled, can vitiate consent and amount to rape.

However, the Supreme Court noted that in the present case, the relationship ultimately culminated in marriage. The Court took the view that once the complainant voluntarily married the accused, the premise that the sexual relationship was based on deception lost its force.

The Court described the prosecution as one where a consensual relationship had been “mischaracterized” as rape due to the breakdown of a promise that was eventually fulfilled.

“Complete Justice” and the Question of Jeopardy

The bench repeatedly referred to the concept of complete justice, stating that criminal law should not be applied mechanically in situations where the factual circumstances have fundamentally changed.

The Court held that continuing the prosecution, even after conviction, would amount to jeopardy, as it would punish the accused despite the complainant’s clear decision to move forward with the relationship through marriage.

This reasoning marked a departure from the usual approach where post-conviction developments do not ordinarily erase criminal liability. The Court treated the marriage not merely as a compromise, but as a material change affecting the very basis of the conviction.

Timing of the Marriage and Its Legal Significance

An important factual aspect noted by the Court was the timing of the marriage. The marriage took place after conviction but before sentencing. This sequence allowed the Supreme Court to examine whether the conviction itself should stand in light of the changed circumstances.

The Court distinguished this situation from cases where compromise or settlement is attempted after finality of proceedings. Here, the criminal process was still ongoing, and the Court considered itself empowered to intervene to prevent what it viewed as an unjust outcome.

The judgment underscores that the timing of reconciliation played a crucial role in the Court’s decision.

Balancing Criminal Law and Personal Autonomy

Throughout the judgment, the Court acknowledged the importance of strict enforcement of sexual offence laws. At the same time, it recognised the personal autonomy of the complainant, who had consciously chosen to marry the accused.

The bench took the view that criminal law exists to protect victims, not to override their agency once they have made an informed decision regarding their personal lives. The Court observed that imposing penal consequences in such a scenario would not advance the interests of justice.

This balance between the objectives of criminal law and respect for individual choice formed a key part of the Court’s reasoning.

A Fact-Specific and Contested Ruling

The Supreme Court was careful to note that its decision was based on the unique facts of the case. The judgment does not suggest that marriage can automatically nullify a rape conviction, nor does it dilute the offence of rape under the IPC.

Instead, the Court framed the ruling as an exception justified by the specific sequence of events, the consensual nature of the relationship, and the voluntary reconciliation between the parties.

Despite these caveats, the ruling has attracted attention because of the broader debates it touches upon regarding consent, compromise, and the role of criminal law in intimate relationships.

Reaction and Public Attention

The decision has sparked discussion due to its sensitive subject matter and the potential implications it carries for how courts view cases involving promises of marriage. While the judgment itself refrains from broad generalisations, it has highlighted an area of law that has long been contentious.

The case also reflects the Supreme Court’s willingness to intervene in criminal proceedings to achieve outcomes it perceives as equitable, even where such intervention departs from conventional outcomes.

What the Judgment Establishes

Based on the facts recorded in the judgment, the Supreme Court quashes rape conviction after marriage in circumstances where:

• The relationship was consensual in nature

• The prosecution arose from an alleged broken promise to marry

• The parties married each other before sentencing

• The complainant voluntarily chose reconciliation

The Court’s focus remained on preventing further harm through criminal punishment when the complainant herself no longer sought such an outcome.

Looking Ahead

The ruling adds to a growing body of jurisprudence dealing with consent, relationships, and criminal liability. While the Supreme Court has not altered the statutory framework of rape law, it has demonstrated how exceptional facts can lead to exceptional relief.

As similar cases come before courts in the future, the December 28 judgment will likely be examined closely for its emphasis on complete justice and factual context. For now, it stands as a notable instance of the Supreme Court exercising its extraordinary powers to resolve a deeply personal dispute within the framework of criminal law.