Summary of the Judgment
Case Name: Lalu Yadav vs. The State of Uttar Pradesh & Ors.
Date: 16th October 2024
Judges: Honorable Justice C.T. Ravikumar, Honorable Justice Rajesh Bindal
Advocates:
Dr. Aditya Sondhi (for the Appellant),
Mr. Siddharth Dharmadhikari (for the Respondent)
Acts and Sections:
Indian Penal Code (IPC) - Sections 376 (rape), 313 (causing miscarriage)
Cited Judgments:
Pepsi Foods Ltd. v. Special Judicial Magistrate, (1998) 5 SCC 749
Ajit Singh @ Muraha v. State of U.P., 2006 (56) ACC 433
State of Haryana v. Bhajan Lal, AIR 1992 SC 604
Shivashankar alias Shiva v. State of Karnataka, (2019) 18 SCC 204
Naim Ahamed v. State (NCT of Delhi), 2023 SCC OnLine SC 89
XXXX v. State of Madhya Pradesh, (2024) 3 SCC 496
Introduction
The Supreme Court of India recently delivered a landmark judgment in Lalu Yadav vs. State of Uttar Pradesh & Ors., addressing complex issues of consent, false promises of marriage, and long-term relationships under the purview of Section 376 (rape) of the Indian Penal Code (IPC). This judgment provides essential guidance on how courts interpret long-term consensual relationships and allegations of rape under the misconception of marriage promises.
The appellant, Lalu Yadav, had been accused of establishing a physical relationship with the complainant under the false promise of marriage, which spanned over several years. The case’s complexity stemmed from the interplay between consent, time lapse, and the eventual refusal to marry, raising important questions about the legal boundaries of such accusations.
Background and Facts of the Case
The relationship between the appellant and the complainant began in 2013, when the complainant was a high school student. Lalu Yadav allegedly promised to marry her and established a physical relationship based on this assurance. The couple lived together for five years, with the complainant's family being aware of the relationship, and she regarded him as her husband.
However, the appellant later refused to marry the complainant after securing employment. The complainant alleged that he not only deceived her but also forced her to undergo abortions on multiple occasions. On 21st February 2018, she filed an FIR under Sections 376 (rape) and 313 (causing miscarriage without a woman’s consent) of the IPC.
The matter escalated to the Allahabad High Court, which refused to quash the FIR. The appellant approached the Supreme Court, seeking quashing of the charges, particularly in light of the long-term consensual relationship and the time delay in filing the FIR.
Key Legal Issues Addressed
Consent and False Promise of Marriage A core issue was whether the consent for the physical relationship was vitiated by the appellant's false promise to marry. The complainant argued that her consent was obtained under the misconception that the appellant would marry her. However, as noted by the Honorable Supreme Court, the complainant lived with the appellant as his wife for an extended period, with the knowledge of her family, which complicated the allegation of rape.
The Court drew upon several precedents, including Shivashankar alias Shiva v. State of Karnataka, where it was held that long-term consensual relationships could not easily be categorized as rape simply due to a subsequent refusal to marry.
Delay in Filing the FIR Another crucial factor was the significant delay of more than five years between the commencement of the relationship and the filing of the FIR. The Court acknowledged that while delay in such cases might not be fatal, it does require careful scrutiny. In the present case, the delay raised doubts about the veracity of the complainant's claims and the genuineness of her consent.
Application of Section 313 (Causing Miscarriage) Initially, the complainant accused the appellant of forcing her to undergo abortions, invoking Section 313 of the IPC. However, during the investigation, the prosecution found no substantive evidence to support this charge. The Honorable Court observed that the lack of medical evidence corroborating the allegation of forced abortions undermined this claim.
The Court cited State of Haryana v. Bhajan Lal, underscoring that inherent powers under Section 482 CrPC should be invoked to prevent the abuse of the legal process when no prima facie case is made out.
Quashing of the FIR The crux of the appeal was the appellant’s plea to quash the FIR. The Supreme Court referred to the State of Haryana v. Bhajan Lal case, which lays down specific grounds for quashing an FIR. The Court found that the allegations in the FIR did not prima facie disclose a case of rape or forced miscarriage. The long-term relationship, the delay in filing the complaint, and the lack of corroborative evidence led the Court to conclude that the High Court should have exercised its inherent powers to quash the FIR.
Conclusion
In its final decision, the Supreme Court quashed the FIR against Lalu Yadav, setting aside the Allahabad High Court's order. This judgment reinforces the principle that long-term consensual relationships, especially where both parties live together with mutual consent, cannot be construed as rape merely because the promise of marriage was not fulfilled.
The Court highlighted the need for careful scrutiny in cases involving delayed FIRs and consent obtained under the alleged misconception of marriage. The judgment sets a significant precedent, clarifying the boundaries of consent in long-term relationships under Indian law.
This case serves as a reminder for legal professionals to assess the nuances of consent, the delay in reporting, and the broader context of relationships before invoking criminal charges under Sections 376 and 313 of the IPC. The judgment also underscores the judiciary's commitment to preventing the misuse of legal processes to settle personal grievances, particularly in the context of intimate relationships.
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