A consensual relationship that later failed was converted into criminal prosecution under Section 69 BNS, but the Telangana High Court intervened and quashed the FIR after parties settled the dispute. The ruling raises critical questions on misuse of promise-to-marry provisions and highlights how criminal law can impact men even in consensual relationships.
False Promise of Marriage: Justice Tirumala Devi Eada of the Telangana High Court has quashed criminal proceedings arising out of allegations of a physical relationship on the promise of marriage, holding that continuation of the case would amount to abuse of process of law.
The complaint was filed by a 28-year-old housemaid who stated that she was in love with the man and entered into a physical relationship, believing that he would marry her. According to her, both families had initially agreed to the engagement, but later the man’s parents refused to proceed, after which she approached the police, and a case was registered under sections 69 and 318(4) of BNS.
During the hearing, it was brought to the Court’s notice that the parties had entered into a Memorandum of Understanding and decided to settle the dispute. It was also submitted that the woman does not intend to prosecute the accused and that she is now getting married, and continuation of the case would affect her future marital life.
The Court noted that the respondent is an illiterate person working as a housemaid and that she did not know the legal consequences or the marriageable age issues involved. Taking into account her present stand and the settlement between the parties, the Court observed:
“No purpose would be served if this is going to be the evidence of the de facto complainant-respondent No.2.”
While considering whether to continue the proceedings, the Court referred to the legal principles laid down by the Supreme Court in State of Madhya Pradesh v. Laxmi Narayan and in Madhukar & Ors. v. The State of Maharashtra & Anr.
Referring to the settled position that courts may exercise inherent powers in appropriate cases where disputes are amicably resolved, the Court further observed:
“The continuation of the trial would not serve any meaningful purpose and it would only prolong distress for all concerned, especially the complainant and burden the courts without the likelihood of a productive outcome.”
In view of the facts of the case and the law laid down by the Supreme Court in the above judgments, Justice Tirumala Devi Eada held that “continuance of proceedings against the petitioners herein would be abuse of process of law” and accordingly quashed the criminal proceedings against all the accused.
Explanatory Table: Laws And Provisions Involved
| Law / Provision | Purpose | How applied in this case |
| Bharatiya Nyaya Sanhita, 2023 – Section 69 | Addresses sexual relations obtained through false promise of marriage affecting consent | FIR alleged physical relationship on promise of marriage; court examined allegations in light of settlement |
| Bharatiya Nyaya Sanhita, 2023 – Section 318(4) | Relates to cheating or deception causing harm or wrongful loss | Included in FIR as supporting offence based on complainant’s allegations |
| Inherent powers of High Court (quashing jurisdiction) | Prevent abuse of process and secure ends of justice by quashing proceedings | Court exercised quashing powers after noting settlement and lack of intent to prosecute |
| Supreme Court precedent – State of Madhya Pradesh vs Laxmi Narayan | Lays guidelines on quashing non-compoundable offences despite compromise | Court considered limitations while evaluating compromise petition |
| Supreme Court precedent – Madhukar & Ors. vs State of Maharashtra & Anr. | Permits quashing where parties amicably resolve dispute and trial would be futile | Relied upon to hold continuation of trial would serve no meaningful purpose |
Case Details
- Case Title: Petitioner Vs. Respondent
- Case No.: Criminal Petition No.12373 of 2025
- Court: Telangana High Court
- Bench: Justice Tirumala Devi Eada
- Date of Order: November 04, 2025
- Counsels:
- For Petitioners: Sri Mohd. Arif
- For State: Sri Jithender Rao Veeramalla, Additional Public Prosecutor
- For Respondent No.2: Not specified in the order text
Key Takeaways
- Not every failed relationship or broken engagement is a criminal offence; consent and mutual understanding matter.
- False promise of marriage allegations must be tested carefully, especially when both adults were in a consensual relationship.
- Criminal law should not be used as a pressure tool after emotional fallout or family disagreements.
- If parties settle amicably and there is no real intention to prosecute, forcing a trial only misuses the system.
- Law must protect genuine victims, but it must equally safeguard individuals from exaggerated or retaliatory criminal complaints.
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