Shiv Pratap Singh Rana vs. State of Madhya Pradesh [July 08, 2024]

15 Jun 2025 --
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Citation: [2024] 7 S.C.R. 8; 2024 INSC 481; Criminal Appeal No. 1552 of 2023

Background and Facts
The appellant, Shiv Pratap Singh Rana, was accused of rape and criminal intimidation under Sections 376(2)(n) and 506 of the Indian Penal Code (IPC) following an FIR lodged by the prosecutrix in September 2018. The allegations centered on claims that the appellant had established a physical relationship with the prosecutrix under the false promise of marriage and had threatened to make her private photographs public if she did not comply with his demands. The trial court framed charges and the High Court dismissed the appellant’s challenge to the same, leading to the present appeal before the Supreme Court.

Key Issues
Whether the relationship between the appellant and the prosecutrix was consensual or constituted rape under a false promise of marriage.

Whether the evidence presented justified the continuation of criminal proceedings against the appellant.

Arguments
Appellant:

Argued that the relationship was consensual and that the FIR was lodged only after the relationship soured and marriage did not materialize.

Pointed to significant contradictions in the prosecutrix’s statements under Sections 161 and 164 CrPC, recorded within a span of 24 hours.

Highlighted the delay of two years in lodging the FIR and the absence of recovery of the alleged incriminating photographs or jewelry.

Respondent (Prosecutrix/State):

Claimed that the appellant had blackmailed her using private photographs and coerced her into a physical relationship, promising marriage but later reneging on that promise.

Asserted that the appellant’s threats and conduct amounted to rape and criminal intimidation.

Supreme Court’s Analysis and Findings
The Court found that the prosecutrix’s statements were not only inconsistent with each other but also internally contradictory, undermining the credibility of the prosecution’s case.

The two-year delay in lodging the FIR, coupled with evidence of ongoing talks between the parties and their families regarding marriage, indicated a consensual relationship that later deteriorated.

The Court noted that both the appellant and the prosecutrix were educated adults, and their conduct—including traveling together and the prosecutrix changing clothes in the appellant’s presence—did not suggest coercion or lack of consent.

The alleged photographs and jewelry were never recovered, further weakening the prosecution’s case.

The Supreme Court concluded that compelling the appellant to face trial on such materials would amount to an abuse of the process of law, as there was hardly any possibility of conviction.

Conclusion and Significance
The Supreme Court quashed the criminal proceedings against the appellant, holding that the case was essentially one of a consensual relationship that went sour, not a case of rape or criminal intimidation.

The judgment reaffirmed that consent, for the purposes of Section 375 IPC, requires an active and voluntary understanding of the circumstances, and that relationships ending in disappointment or acrimony do not ipso facto constitute criminal offenses.

The ruling underscores the need for courts to scrutinize the material on record, especially in cases involving allegations of rape on the pretext of marriage, and to guard against misuse of criminal law in the context of failed relationships.

Appearance:

Appellant: Abhinav Ramkrishna (AOR), Amit Lahoti (Advocate)

Respondents: Harmeet Ruprah (DAG), Yashraj Singh Bundela (AOR), Pratima Singh (Advocate), Gp. Capt. Karan Singh Bhati (AOR).