The Supreme Court set aside a rape conviction after noting the case arose from a consensual relationship that later turned into marriage. Using Article 142, the Court quashed the FIR, conviction, sentence, and restored the man’s service benefits.
NEW DELHI: The Supreme Court of India has delivered a rare judgment where it not only suspended a sentence but completely quashed the conviction and criminal proceedings, after finding that a consensual relationship was wrongly given a criminal colour due to misunderstanding between the parties.
The case arose from Criminal Appeal No. 5256 of 2025 titled Sandeep Singh Thakur vs State of Madhya Pradesh & Another, decided on December 5, 2025.
The appeal was filed against the order dated 05.04.2024 passed by the Madhya Pradesh High Court, which had rejected the application for suspension of sentence. The appellant had been convicted under Sections 376(2)(n) and 417 of the IPC and sentenced to ten years of rigorous imprisonment. Being aggrieved by the rejection of suspension of sentence, the appellant approached the Supreme Court.
The Supreme Court observed at the outset that:
“This is one of those rare cases where on the intervention of this Court the appellant herein, who had applied to seek suspension of his sentence was ultimately benefitted by quashing of his conviction as well as the sentence.”
The Court explained that while examining the rejection of suspension of sentence, it felt there was a possibility of reconciliation between the parties. The judgment records that:
“We had a sixth sense that the appellant and the respondent prosecutrix could be brought together once again if they decided to marry each other.”
Based on this assessment, the Court suggested that the parties seek instructions. Both the appellant and the prosecutrix appeared before the Court along with their parents. The judges interacted with them in chambers, and it was conveyed that both were willing to marry. The Court then granted interim bail. The marriage between the parties took place on 22.07.2025, and the judgment notes that:
“The parties have been residing together since then. Their parents are happy by this development.”
In view of these developments, a bench comprising Justices B.V. Nagarathna and Satish Chandra Sharma exercised its extraordinary authority under Article 142 of the Constitution to ensure “complete justice” by setting aside the FIR, conviction, and sentence imposed on the appellant.
The Court clearly stated that:
“We have invoked our powers under Article 142 of the Constitution of India to do complete justice in the matter by quashing the complaint as well as the conviction and sentence passed against the appellant herein.”
The Court gave a crucial finding on the nature of the dispute, observing that:
“Owing to a misunderstanding the consensual relationship between the parties was given a criminal colour and converted into an offence of false promise of marriage whereas the parties, in fact, intended to marry each other.”
It further recorded that:
“It was only owing to the appellant seeking postponement in the date of marriage which may have led to insecurity in the mind of the respondent prosecutrix and filing of the criminal complaint.”
The factual background shows that the parties met in 2015 on a social media platform and developed a relationship. They entered into a consensual physical relationship. Later, an FIR was registered in 2021 under Sections 376 and 376(2)(n) IPC, alleging a false promise of marriage.
A chargesheet followed, and the trial court convicted the appellant, awarding severe punishment. His appeal before the High Court and the application for suspension of sentence were rejected, leading to the Supreme Court proceedings.
During the pendency of the appeal, the Supreme Court passed several interim orders. On 06.05.2025, it was recorded:
“The petitioner may be willing to marry the second respondent-Prosecutrix.”
The Court directed both parties to be produced before it. On 15.05.2025, after hearing the parties and their parents in chambers, the Court noted:
“The petitioner and respondent No.2 have unequivocally stated before us that they are willing to marry each other.”
The sentence was suspended and the appellant was released on bail.
After the marriage was solemnised, the Court recorded on 25.07.2025 that “their marriage took place on 22.07.2025 and they are living together.” The Court then stayed the conviction to enable the appellant to rejoin government service.
Subsequently, both parties informed the Court that they were living together as husband and wife and that the criminal proceedings should not continue. The prosecutrix herself expressed that the case may be quashed.
Taking note of these submissions, the Supreme Court held:
“Interest of justice would be sub-served if the FIR No. 29 of 2021 dated 02.11.2021 lodged with Women Police Station, District Sagar and the judgment of the I Additional Sessions Judge, Sagar and the order of conviction and sentence passed dated12.04.2024 therein, stand quashed.”
As a result, the criminal appeal pending before the High Court was rendered infructuous. The Court reiterated:
“We have invoked our powers under Article 142 of the Constitution of India, in the interest of justice and to do complete justice in the matter.”
The judgment also addressed the service consequences faced by the appellant. Since he was suspended due to the criminal case, the Court directed that the suspension be revoked and arrears of salary be paid. It ordered:
“The arrears shall be paid to the appellant within the period of two months from today.”
This judgment is significant as it highlights the Supreme Court’s willingness to look beyond rigid technicalities and examine the real nature of relationships, especially in cases alleging false promise of marriage.
It reinforces that consensual relationships, when later followed by marriage, cannot be mechanically treated as criminal offences, and that Article 142 can be used to undo grave injustice where criminal law has been misapplied.
Explanatory Table – Laws & Sections Involved In The Case
| Law / Provision | Section | Explanation | Application in This Case |
| Indian Penal Code, 1860 | Section 376 | Punishment for rape | FIR registered alleging rape on the ground of false promise of marriage |
| Indian Penal Code, 1860 | Section 376(2)(n) | Rape repeatedly on the same woman | Trial court convicted the appellant under this section and awarded 10 years RI |
| Indian Penal Code, 1860 | Section 417 | Punishment for cheating | Added on allegation of deception regarding marriage |
| Constitution of India | Article 142 | Power of Supreme Court to do complete justice | Used to quash FIR, conviction, sentence, and criminal proceedings |
| Code of Criminal Procedure | Suspension of sentence (procedural relief) | Temporary release during appeal | Initially denied by High Court, later granted by Supreme Court |
| Criminal Appeal | CRA No. 4869 of 2024 | Appeal before High Court | Rendered infructuous after Supreme Court quashed proceedings |
| FIR | FIR No. 29 of 2021 dated 02.11.2021 | First Information Report | Quashed by Supreme Court |
| Sessions Trial | ST No. 191 of 2022 | Trial before Sessions Court | Resulted in conviction later set aside |
Case Summary
- Case Title: Sandeep Singh Thakur vs State of Madhya Pradesh & Another
- Court: Supreme Court of India
- Jurisdiction: Criminal Appellate Jurisdiction
- Case Number: Criminal Appeal No. 5256 of 2025
- Neutral Citation: 2025 INSC 1499
- Date of Judgment: 5 December 2025
- Bench: Justice B.V. Nagarathna and Justice Satish Chandra Sharma
- Appellant: Sandeep Singh Thakur
- Respondents: State of Madhya Pradesh, Prosecutrix (Second Respondent)
Key Takeaways
- Consensual relationships cannot be criminalised merely because marriage is delayed or postponed; delay is not deception.
- False promise of marriage cases show how rape law is misused when relationships turn sour, destroying men’s careers and liberty.
- Courts must examine intent at the start of the relationship, not emotions after a breakup or misunderstanding.
- Article 142 remains the last shield for innocent men when lower courts mechanically apply gender-biased interpretations.
- Accountability for false accusations is essential; without consequences, criminal law will continue to be used as a tool of coercion rather than justice.
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