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Supreme Court Verdict on Consensual Relationships: Manish Yadav Case Summary

Supreme Court Ruling on Consensual Relationships: Manish Yadav Vs State of Uttar Pradesh

The Supreme Court delivered a significant judgment in the case of Manish Yadav Vs State of Uttar Pradesh & Anr, Criminal Appeal of 2025, stemming from SLP(Crl.) No(s). 15882 of 2024, as cited in Neutral Citation No.: 2025 INSC 151, pronounced on January 22, 2025. This verdict quashed summons issued against an individual in a rape case characterized by a consensual relationship. The Court emphasized that, although the case presented issues of a breach of promise, it did not equate to a fundamentally false promise of marriage.

Background of the Case

The appellant had established a close relationship with the complainant via Instagram before engaging politically. The Allahabad High Court previously quashed summons for the appellant’s father, Rajnath Yadav, on August 30, 2024, but upheld the proceedings against the appellant, prompting the current appeal.

Supreme Court Findings

  1. Nature of the Appeal: In paragraph 3, the Supreme Court made it clear that the appellant was contesting the August 30, 2024 order of the Allahabad High Court, which partially allowed the Criminal Appeal No. 227/2024, questioned the validity of a August 24, 2023 order from the Special Judge, SC/ST Act, Gazipur. The courts had summoned both the appellant and his father under various sections of the Indian Penal Code, 1860 (IPC) and the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989.

  2. High Court's Rationale: The High Court's order only quashed the summons against Rajnath Yadav while maintaining them against the appellant (para 4).

  3. Complaint Details: The prosecution claimed that the appellant promised to marry the complainant, leading to a physical relationship that resulted in pregnancy and alleged abortion (para 6). There were also accusations of assault and derogatory remarks based on caste.

  4. Consent and Breach of Promise: The Supreme Court underscored in paragraphs 14 and 18 that both parties were adults capable of rational decisions. Initially, their physical relationship was consensual and not predicated on a false promise of marriage. Thus, the case illustrated a breach of promise rather than a false commitment.

Key Legal Principles

The Court referenced precedents in criminal jurisprudence related to consent in sexual relationships. In particular:

  • Uday v. State of Karnataka stressed that true consent, informed and voluntary, negated claims of coercion.
  • Deepak Gulati v. State of Haryana distinguished between mere breaches of promise and false promises.
  • Deelip Singh v. State of Bihar reiterated that not all breaches of promise constitute false promises to marry.

Conclusion of the Judgment

The Supreme Court ruled that

  • The appellant's actions did not support the prosecution’s claims under the SC/ST Act, as there was no evidence of caste-based abuse (para 21).
  • The relationship, having turned sour due to intervening circumstances, should not invoke the penal law concerning rape (para 22).

The Court ordered the quashing of all related summons and proceedings against the appellant (para 23) and allowed the appeal in full (para 24). The judgment concludes by stressing the importance of clear distinctions in law surrounding consensual relationships to prevent misuse of legal provisions by individuals post-consensual interactions.

Implications

This landmark ruling urges other courts to align with the Supreme Court's stance to prevent the misuse of rape laws against men involved in consensual relationships that later turn contentious. It highlights the necessity for legislative reform to protect against fraudulent use of legal statutes. The legal community is encouraged to support amendments ensuring equitable justice delivery in similar cases, thus reducing wrongful prosecution based on consensual encounters that soured.