False Rape Case| Woman Voluntarily Had Sex & Travelled With Man, Then Accused Him Of Rape: Uttarakhand HC Quashes Proceedings Against Man

UTTARAKHAND: The Uttarakhand High Court has quashed rape proceedings against a man, ruling that the failure of a consensual relationship does not automatically amount to a criminal offence.

Justice Alok Mahra, in a judgment dated October 9, 2026, allowed a criminal revision filed by the accused man against the Pauri Garhwal District and Sessions Court's order dated April 22, 2025, which had rejected his discharge application in a case registered under Section 376 of the Indian Penal Code (IPC).

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The case involved a man and a woman who met through a matrimonial website in April 2023. Their families subsequently interacted, and the two developed a close relationship.

According to the FIR, the man's mother opposed their marriage because of the woman's dark complexion. However, the man allegedly assured the woman that he would marry her despite his family's objections.

Both were working in Bengaluru. The woman alleged that they travelled together to Rishikesh, stayed at a resort and established physical relations.

She further stated that they later travelled to Coorg with two common friends, where physical relations were again established on August 15, 2023.

Their relationship continued, but according to the complaint, the man began avoiding her video calls and messages from October 2023.

In December 2023, the woman filed a complaint seeking action under Section 12 of the Protection of Women from Domestic Violence Act, 2005. This complaint later formed the basis of an FIR under Section 376 IPC.

The accused approached the trial court seeking discharge, arguing that the allegations did not establish the offence of rape.

However, the trial court rejected his application and directed that a rape charge be framed against him. The man subsequently challenged this decision before the Uttarakhand High Court.

His counsel argued that two educated and mature adults voluntarily entered into physical relations. He submitted that the alleged incidents occurred during trips taken together and that the complaint was filed months later, after their relationship had deteriorated.

The State opposed the criminal revision, arguing that at the stage of framing charges, the court should only examine whether a prima facie case exists without conducting a detailed trial.

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After examining the FIR, allegations and circumstances of the relationship, the High Court observed:

“Be that as it may, it is apparent from the record that the parties are educated adults, who entered into a relationship voluntarily after meeting on a matrimonial website and they were mature enough to understand the consequences of their action and were possessed of sufficient understanding, maturity, and discernment to comprehend the nature and consequences of their actions.

An educated and independent adult, upon entering into a consensual relationship, must also recognise that the law cannot be invoked to criminalize the mere failure of a relationship. The dissolution of a relationship, by itself, does not give rise to criminal liability.”

The Court specifically considered that the alleged physical relations occurred while the parties were travelling together to Rishikesh and Coorg. It also noted that the complainant did not raise any immediate protest or take prompt legal action after the incidents.

Considering these circumstances, the High Court held that the criminal proceedings could not continue against the accused man.

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Accordingly, the Uttarakhand High Court set aside the trial court's April 22, 2025 order and quashed the entire criminal proceedings in Sessions Trial No. 19 of 2024 against the man.

EXPLANATORY TABLE OF LAWS AND SECTIONS

CASE DETAILS

KEY TAKEAWAYS

• Failed Relationship Is Not Rape: The High Court ruled that the breakdown of a consensual relationship does not automatically create criminal liability.
• Consent Cannot Be Ignored: The Court considered that both parties were educated adults who voluntarily entered into a relationship.
• Man Faced Serious Criminal Proceedings: A failed matrimonial relationship led to a rape prosecution under Section 376 IPC.
• Criminal Law Cannot Punish Every Breakup: The Court stressed that the mere dissolution of a relationship cannot be criminalised.
• Major Relief For The Accused Man: The High Court quashed the rape proceedings, reinforcing the need to distinguish genuine criminal offences from failed consensual relationships.