Supreme Court Quashes Rape Conviction After Appellant Marries Complainant, Invokes Article 142

The Supreme Court has quashed the conviction and sentence of a man sentenced to ten years of rigorous imprisonment for rape after noting that the appellant and the complainant married each other during the pendency of proceedings following the court’s intervention.

A Bench of Justices B V Nagarathna and Satish Chandra Sharma exercised the Supreme Court’s extraordinary powers under Article 142 of the Constitution of India to do complete justice in the matter. The Court held that the interest of justice would be served by quashing the FIR, conviction, and sentence imposed on the appellant.

The appellant had been convicted under Sections 376(2)(n) and 417 of the Indian Penal Code by the I Additional Sessions Judge, Sagar, and sentenced to ten years of rigorous imprisonment along with a fine of Rs 50,000 for the rape charge, and two years of rigorous imprisonment with a fine of Rs 5,000 for cheating. The conviction was recorded on April 12, 2024.

Aggrieved by the conviction, the appellant approached the Madhya Pradesh High Court at Jabalpur and sought suspension of sentence. The High Court rejected the plea for suspension on September 5, 2024. The appellant then approached the Supreme Court challenging the rejection of suspension of sentence.

During the hearing before the Supreme Court, the Bench observed that, based on the facts of the case, there was a possibility that the appellant and the prosecutrix could reconcile if they chose to marry each other. The Court recorded that it had suggested to the counsel appearing for both parties to seek instructions from their clients.

Subsequently, both the appellant and the complainant appeared before the Supreme Court along with their parents. The Bench interacted with them in chambers and was informed that both parties were willing to marry each other. Following this interaction, the Court granted interim bail to the appellant.

The marriage between the appellant and the complainant took place on July 22, 2025. The Court noted that the couple had been residing together since the marriage and that their parents were satisfied with the development.

Taking note of these developments, the Supreme Court observed that the case appeared to be one where a consensual relationship was given a criminal colour due to a misunderstanding between the parties. The Bench held that the relationship was converted into an allegation of false promise of marriage even though both parties intended to marry each other.

The Court further noted that the appellant’s request to postpone the date of marriage may have caused insecurity in the mind of the complainant, which led to the filing of the criminal complaint.

As per the facts placed before the Court, the appellant and the complainant met in 2015 through a social media platform and developed a close relationship. They later entered into a consensual physical relationship. The complainant subsequently alleged that the relationship was based on a false promise of marriage and lodged an FIR on November 2, 2021, at the Women Police Station, District Sagar, under Sections 376 and 376(2)(n) of the IPC. A chargesheet was filed on February 8, 2022.

Invoking its powers under Article 142, the Supreme Court quashed the FIR dated November 2, 2021, the judgment of the I Additional Sessions Judge, Sagar, and the conviction and sentence passed against the appellant.

The Court also allowed the appellant’s plea seeking revocation of his suspension from service, which had been imposed due to the criminal proceedings and conviction. It directed the State Government to ensure that all arrears payable to the appellant are released within two months, noting that he had already rejoined service following the revocation of suspension.

In view of the Supreme Court’s decision, the pending appeal before the Madhya Pradesh High Court was rendered infructuous.

Case Title: Sandeep Singh Thakur v. State of Madhya Pradesh and Another

Bench: Justices B V Nagarathna and Satish Chandra Sharma

Date: February 6, 2026