Criminal Prosecution Cannot Be Used to Compel Marriage: Supreme Court Quashes Case Arising from Three-Year Consensual Relationship, Finds No Deception at Inception
Case Name: Martanda Singh v. State of Chhattisgarh and Another.
Date of Judgment: 1 October 2026.
Citation: 2026 INSC 1081.
Bench: Justice J.B. Pardiwala and Justice K. Vinod Chandran.
Held: The Supreme Court held that consent obtained through fear or misconception cannot be loosely inferred merely because a consensual relationship ends without marriage. Applying Deepak Gulati v. State of Haryana, (2013) 7 , the Court reiterated that criminal liability based on a false promise of marriage requires adequate evidence that the accused had no intention of fulfilling the promise from the beginning. On the complaint before it, the Court found neither coercion nor misrepresentation vitiating consent. It further held that criminal prosecution cannot be reduced to a means of compelling a person to marry.
Summary: The Supreme Court quashed criminal proceedings against Martanda Singh arising from allegations that he sexually exploited the complainant on the pretext of marriage and subsequently refused to marry her. FIR was registered at Sirgitti Police Station, Bilaspur, following the complainant’s first information statement.
The complainant, an engineering graduate preparing for competitive examinations, met the appellant at an academy where both were enrolled. They developed a romantic relationship, and their families discussed marriage. According to the complaint, the appellant visited her home, where she lived with her mother and brother, and the couple entered into a physical relationship that continued for approximately three years. They subsequently separated, and the marriage proposal did not materialise.
The complainant also relied on an undertaking allegedly given by the appellant at the Mahila Thana Counselling Centre, Bilaspur, agreeing to marry her. The Court considered that undertaking unenforceable and observed that it would have been made under the threat of criminal prosecution. In any event, it followed the three-year relationship and could not establish that the earlier consent had been procured through a deceptive promise.
Relying on Deepak Gulati, the Court distinguished a promise made without any intention of fulfilment from a relationship in which contemplated marriage ultimately does not occur. The relevant inquiry was whether deception existed at the initial stage, rather than whether the parties later failed to marry.
On a bare reading of the complaint, the Court found no clear assurance or promise establishing the alleged deception. It characterised the claim that the relationship had continued under the pretext of marriage as an afterthought and concluded that the consent disclosed by the allegations was neither coerced nor obtained through misrepresentation.
The Court also noted the complainant’s categorical statement that she would drop the charge if the appellant married her. Rejecting the use of prosecution as leverage to secure marriage, it observed that a criminal case cannot become a “strong-arm tactic”. Its conclusion rested on the particular complaint and circumstances before it, including the absence of material showing a dishonest intention from the outset.
Decision: The Supreme Court allowed the appeal and quashed Chargesheet No. 199 of 2025 dated 17 June 2025.