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Supreme Court of India

A Promise-to-Marry Prosecution Was Quashed Where the FIR Itself Showed a Consensual Relationship and No Possible Deception

Citation: Ankit Tomar v. State of Haryana

Date: 26 Feb 2026

The Background

The appellant had been accused of rape on the allegation that he maintained a physical relationship with the complainant on a false promise of marriage. The High Court refused to quash the FIR, distinguishing an earlier Supreme Court decision on somewhat similar facts.

Why the Supreme Court Intervened

The Supreme Court found that the distinction drawn by the High Court did not hold. On the complainant's own version, the relationship continued over time and was consensual. The Court also considered the factual setting: the complainant was herself married and a mother of two children, which made the allegation of being lured into the relationship by a realistic promise of marriage legally and factually unsustainable on the materials before it.

The Final Decision

The Court set aside the High Court's order and quashed the criminal proceedings in FIR No. 127 of 2024. It also cancelled the appellant's bail bonds as no further proceedings were to continue on that FIR.

Why This Judgment Matters

The judgment continues the Court's effort to separate genuine cases of vitiated consent from situations where the record itself shows a consensual relationship without the legal ingredients of deception or coercion. It shows that criminal law cannot be sustained where the basic theory of inducement collapses on the face of the FIR.