The Supreme Court Yesterday (24th Nov) ruled that a breakup between two consenting adults cannot be twisted into a rape case unless there was clear evidence of a false promise made only to exploit the woman. The Court quashed an FIR accusing an Aurangabad lawyer of rape, holding that the three-year relationship was voluntary and not criminal.
Break-Up Cannot Become Rape Case Against Man: The Supreme Court of India clearly said that a break-up of a consensual relationship between two adults cannot be treated as rape, and criminal law cannot be misused just because a relationship did not end in marriage. The ruling came in the case Samadhan vs. The State of Maharashtra & Anr., where a married woman had accused an Aurangabad lawyer of repeatedly raping her on the basis of a false promise of marriage.
A Bench of Justices BV Nagarathna and R. Mahadevan quashed the FIR and the chargesheet filed under Sections 376, 376(2)(n) and 507 IPC. The judges made it very clear that a consensual relationship lasting several years cannot later be painted as rape only because things did not work out.
The Court said:
“A mere break-up of a relationship between a consenting couple cannot result in initiation of criminal proceedings… What was a consensual relationship at the initial stages cannot be given a colour of criminality when the said relationship does not fructify into a marital relationship.”
The Bench further clarified the basic principle of law that consent and rape cannot be mixed up merely because marriage did not happen. As the Court explained:
“There is a clear distinction between rape and consensual sex. The court must carefully examine whether the accused had actually wanted to marry the victim or had made a false promise only to satisfy his lust.”
Case Background
As per the FIR, the complainant was a married woman living separately from her husband since 2020. She met the lawyer-appellant in 2022 when he was helping her in her maintenance case. Over time, they developed closeness and started meeting frequently. Physical relations continued for three years, and she became pregnant multiple times, which were terminated with mutual consent.
The FIR claimed that the lawyer had promised marriage but backed out later, and had also threatened her. However, the Supreme Court pointed out that throughout the three-year relationship, she never filed any complaint of sexual assault, and the case was filed only in August 2024 after he allegedly refused to pay her ₹1.5 lakh.
The FIR itself mentioned that when she became pregnant the first time, she told him:
“You live your life and I will live my life”.
Court’s Legal Analysis
The Supreme Court studied the entire record and found no evidence of coercion, deceit, or force during any of the meetings. The relationship included regular communication, repeated meetings and voluntary physical intimacy. The Court highlighted that sexual relations in a long, emotional, voluntary relationship cannot later be treated as rape:
“The present case is not one where the appellant lured the complainant solely for physical pleasure and then vanished. The relationship continued for three long years, which is a considerable period of time.”
The judges also warned against the rising trend of misusing rape laws after failed relationships:
“To convert every sour relationship into an offence of rape not only trivialises the seriousness of the offence but also inflicts upon the accused indelible stigma and grave injustice. Such misuse of the criminal justice machinery is a matter of profound concern.”
The Court further stressed that the complainant was an adult, educated woman who consciously chose to maintain the relationship even though her own marriage had not ended legally. There was no sign of fear, pressure or deception.
The judgment concluded that the case fit within what the Court has repeatedly called misuse of rape provisions in disputes arising from broken relationships, not ME.
It finally held:
“The acts complained of occurred within the contours of a relationship that was voluntary and willing. The continuation of the prosecution in such facts would be nothing short of an abuse of court machinery.”
Final Order
The Supreme Court allowed the appeal, quashed FIR No. 294/2024 and Chargesheet No. 143/2024, and set aside the Bombay High Court’s refusal to quash.
Explanatory Table Of All Laws & Sections Mentioned In The Case
| Law / Section | What It Means | How It Applies In This Case |
| Section 376 IPC (Punishment for Rape) | Covers punishment for rape; minimum 10 years which may extend to life imprisonment. | FIR accused the lawyer of rape. Supreme Court held that the physical relationship was consensual, so Section 376 does not apply. |
| Section 376(2)(n) IPC (Repeated Rape on Same Woman) | Applies when a man repeatedly rapes the same woman through force, threat, coercion, or deceit. | The Court said “repeated sexual relations in a voluntary relationship cannot be called repeated rape”. No force, threat, or deception existed. |
| Section 507 IPC (Criminal Intimidation by Anonymous Communication) | Deals with threatening a person through anonymous messages or disguised identity. | FIR claimed the lawyer threatened her, but no reliable evidence or specific incident was shown. |
| Section 375 IPC (Definition of Rape) | Defines what constitutes rape — absence of consent, coercion, fraud, or force. | The Court found no lack of consent; the relationship was voluntary over three years. |
| Section 528 BNSS (Earlier Section 482 CrPC – Quashing Powers) | Allows High Court to quash FIRs to prevent abuse of legal process. | High Court refused to quash; Supreme Court exercised this power and quashed FIR + chargesheet. |
| Section 19, Indian Contract Act, 1872 (Voidable Contract by Misrepresentation) | If consent is obtained by fraud/misrepresentation, the agreement becomes voidable. | The Court held there was no misrepresentation or false promise from the beginning; consent was voluntary. |
| Precedent: Mahesh Damu Khare vs State of Maharashtra (2024) | Says physical relationship must be directly traceable to a false promise of marriage. | SC applied this to say the woman had many other reasons to continue the relationship. |
| Precedent: Prashant vs State of NCT of Delhi (2025) | A breakup cannot be turned into a rape complaint. | SC quoted this heavily to quash FIR. |
| Precedent: Bhajan Lal Case (1992) | Lays down conditions for quashing FIR when allegations do not show any offence. | SC used this principle to hold FIR = abuse of process. |
Case Summary
- Case Title
- Samadhan S/o Sitaram Manmothe vs State of Maharashtra & Another
- CRIMINAL APPEAL NO. 5001 OF 2025
- (Arising out of SLP (Crl.) No. 6906/2025)
- Bench (Judges)
- Justice B.V. Nagarathna
- Justice R. Mahadevan
- Appellant (Accused)
- Samadhan S/o Sitaram Manmothe — Advocate from Aurangabad
- Respondents
- State of Maharashtra
- Complainant woman (Respondent No. 2) – Not appearing despite notice
FIR Details
- FIR No.: 294/2024
- Date: 31.08.2024
- Police Station: City Chowk Police Station, Chhatrapati Sambhajinagar City
- Charges:
- Section 376 IPC
- Section 376(2)(n) IPC
- Section 507 IPC
Chargesheet Details
- Chargesheet No.: 143/2024
- Date: 25.10.2024
- Filed before: 3rd Judicial Magistrate First Class, Aurangabad
Key Dates
| Event | Date |
| Complainant meets lawyer | 27.01.2022 |
| First alleged intimacy | 12.03.2022 |
| Pregnancies/abortions | Sept 2022, July 2023, May 2024 |
| Last physical meeting | 20.05.2024 |
| FIR lodged | 31.08.2024 |
| Anticipatory bail granted | 19.09.2024 |
| Chargesheet filed | 25.10.2024 |
| High Court rejected quashing | 06.03.2025 |
| Supreme Court judgment | 24 November 2025 |
Counsels
- For the Appellant (Lawyer Accused):
- Sneha Sanjay Botwe
- Bharat S. Doifode
- Siddharth S. Chapalgaonkar
- Akash Tripathi
- Ashraf Patel
- For Respondents:
- Aaditya Aniruddha Pande
- Siddharth Dharmadhikari
- Shrirang B. Varma
- Bharat Bagla
- Sourav Singh
- Aditya Krishna
- Adarsh Dubey
- Chitransha Singh Sikarwar
- Radhika Gautam (also appointed Amicus Curiae for R-2)
Key Findings of the Supreme Court
- Relationship was fully consensual
- Woman is educated, major, voluntarily met the man
- No allegations of force for 3 years
- FIR filed only after he refused to pay ₹1.5 lakh
- Break-up ≠ Rape
- FIR & chargesheet quashed as abuse of law
This Could Change Your Case-Get FREE Legal Advice-Click Here!
Disclaimer: The views and opinions expressed in this article are those of the Indian courts and do not necessarily reflect the official policy or position of “ShoneeKapoor.com” or its affiliates. This article is intended for informational and educational purposes only. The content provided is not legal advice, and viewers should not act upon this information without seeking professional counsel. Viewer discretion is advised.