High Court

ā€œMarriage Promise Made By Underage Man Has ā€˜Nil’ Evidentiary Valueā€: Gujarat High Court Acquits Him In Promise-To-Marry Case

A woman filed a rape case over an alleged false promise of marriage just one day after cancelling a live-in agreement. Why did the Gujarat High Court uphold the man's acquittal after examining two crucial documents?

ā€œMarriage Promise Made By Underage Man Has ā€˜Nil’ Evidentiary Valueā€: Gujarat High Court Acquits Him In Promise-To-Marry Case
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ā€œMarriage Promise Made By Underage Man Has ā€˜Nil’ Evidentiary Valueā€: Gujarat High Court Acquits Him In Promise-To-Marry Case

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GUJARAT: The Gujarat High Court has upheld the acquittal of a man accused of rape on the false promise of marriage, holding that a marriage promise made when he was below the legal marriageable age had no evidentiary value as a valid marriage commitment.

Read Also:- False Marriage Promise Rape Case | ā€œRelationship Consensual For Years, Then Criminal After Breakup?ā€: Supreme Court Quashes Case And Frees Man

On October 21, 2026, a Division Bench of Justice Ilesh J. Vora and Justice R. T. Vachhani dismissed the appeal against the man's acquittal, finding no grounds to interfere with the trial court's decision. The Court observed that a dispute between romantic partners ā€œcannot be given colour of a criminal prosecutionā€.

The complainant, a college student, claimed that she had been in a relationship with the accused for nearly a year. On August 13, 2019, she went to his house after he allegedly promised to marry her once she attained the legal marriageable age of 21.

The couple later signed a Maitri Karar (live-in relationship agreement) in late 2019, agreeing to live together. At that time, neither had attained the legal marriageable age.

The woman alleged that the accused later forced her into sexual relations, physically assaulted her and demanded money. On January 29, 2020, the couple signed another document cancelling their earlier agreement. She claimed that the cancellation happened under threats.

Read Also;- Failed Promise To Marry Doesn’t Make A Man Guilty Of Cheating: Orissa High Court Sets Aside Section 417 IPC Conviction

On January 30, 2020, just one day after cancelling the live-in agreement, the woman registered an FIR alleging rape and other offences. The accused denied the allegations and maintained that the criminal case was false.

The trial court acquitted the accused, granting him the benefit of doubt. The complainant challenged the acquittal, claiming that the agreement was cancelled through ā€œdeception and threatsā€ and that her testimony and medical evidence were not properly considered.

However, the Gujarat High Court found serious weaknesses in the prosecution's evidence.

The woman's earlier medical history recorded a romantic relationship and cohabitation but ā€œdoes not describe force, coercion or deceitā€. Her father and uncle admitted that she had voluntarily accompanied the accused. An independent landlord also stated that she had never complained of harassment.

The prosecution relied on the two agreements but failed to seize their originals. The Court described this as ā€œa serious omissionā€.

Read Also:- Prosecutrix Voluntarily Married Accused In Interfaith Relationship, Later Shifted Blame Due To Social And Family Pressure: Delhi High Court Acquits Man In False Rape Case

The Court also noted that the cancellation deed contained ā€œno recital of any beating, any threat to die, or any forcible intercourseā€.

Examining the alleged false promise of marriage, the High Court noted that the accused was only 20 when the agreement was signed. It held that the ā€œprobative value of such a documentā€, involving ā€œa person who was not competentā€ to marry, was ā€œnilā€.

The Court further held that

ā€œthe present case is not one of a promise to marry made with a dishonest intention from the very inception, so as to obtain sexual favours under the guise of such a promiseā€.

Regarding consensual live-in relationships, the High Court observed that where adults voluntarily live together for a substantial period, ā€œa presumption would arise that they voluntarily chose that kind of relationship being fully aware and conversant of its consequences.ā€

The Court also clarified that medical and investigative evidence ā€œcan show that an incident took place or that certain steps were taken; they cannot take the place of reliable evidence of the accused’s involvementā€.

The Bench further observed,

ā€œNowadays, it is common that women are financially independent and have the capacity to take conscious decisions of charting their life on their own terms,ā€

adding that a relationship dispute cannot be given the colour of a criminal prosecution.

Referring to Supreme Court principles governing appeals against acquittal, the High Court reiterated that interference is justified only ā€œwhere there are compelling circumstances, and the judgment under appeal is found to be perverseā€.

Finding ā€œno perversity or legal infirmity in the appreciation of evidence,ā€ the Gujarat High Court dismissed the appeal and upheld the man's acquittal in the rape case.

EXPLANATORY TABLE OF LAWS AND SECTIONS

Law / ProvisionWhat It MeansApplication In This Case
Section 375 IPCDefines rape, including circumstances involving consent obtained under a misconception of fact.The prosecution alleged sexual relations based on a false promise of marriage.
Section 376 IPCPrescribes punishment for rape.The man's acquittal on the rape charge was upheld.
Section 90 IPCExplains when consent given under fear or misconception of fact is not legally valid.Relevant to whether the alleged marriage promise affected consent.
Prohibition of Child Marriage Act, 2006Generally sets the minimum marriage age at 21 for men and 18 for women.The accused was 20 when the agreement was signed.
Indian Evidence Act, 1872Governs the admissibility and assessment of evidence.The Court examined testimony, medical history and the two agreements.
Criminal appellate principlesGovern judicial interference with an acquittal.The High Court found insufficient grounds to overturn the acquittal.

CASE DETAILS

ParticularDetails
CourtGujarat High Court, Ahmedabad
Case TitleXYZ Victim v. State of Gujarat & Anr.
Case NumberR/Criminal Appeal (Against Acquittal) No. 2273 of 2026
BenchJustice Ilesh J. Vora and Justice R. T. Vachhani
Judgment Delivered ByJustice R. T. Vachhani
Judgment DateOctober 21, 2026
High Court Case Identifier (CNR)GJHC240527372026
AppellantXYZ Victim (Original Complainant)
Respondent No. 1State of Gujarat
Respondent No. 2Accused Man (Acquitted)
Appellant's CounselAdvocate Rishabh R. Jain
State's CounselAdditional Public Prosecutor L. B. Dabhi
Original FIR NumberFirst C.R. No. 11191023200089 of 2020
Trial CourtAdditional Sessions Judge, Court No. 7, City Civil and Sessions Court, Ahmedabad
Trial Court Case NumberSessions Case No. 457 of 2021
Final DecisionAppeal dismissed; man's acquittal upheld

KEY TAKEAWAYS

  • Underage Man’s Marriage Promise Has ā€˜Nil’ Value: A 20-year-old man’s promise to marry cannot automatically establish criminal liability.
  • Broken Marriage Promise Is Not Rape: A man cannot be convicted merely because a relationship failed. Dishonest intention from the beginning must be proved.
  • Consensual Relationship Cannot Automatically Become Rape: The Court considered the couple’s voluntary live-in relationship while examining the allegations.
  • Allegations Alone Cannot Convict A Man: Missing original documents and weak supporting evidence raised serious doubts about the prosecution's case.
  • Man’s Acquittal Upheld By Gujarat High Court: A failed relationship cannot, by itself, justify criminal prosecution for rape.
XYZ Victim v. The State Of Gujarat And Anr..pdf

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