The Supreme Court of India has recently addressed several cases involving allegations of rape based on a promise of marriage, offering significant clarifications on the legal stance in such matters. The court has consistently held that a mere breach of a promise to marry does not automatically constitute rape. To establish rape, it must be proven that the accused never intended to marry the woman from the outset of the relationship and used this false promise to induce her into a sexual relationship.

In one case, the Supreme Court quashed a criminal proceeding against a man accused of sexually assaulting a woman with whom he had a 16-year consensual relationship, stating the relationship was based on a false promise of marriage. The court found it difficult to believe that a highly qualified woman would allow a man to sexually exploit her for such a long period based solely on a promise of marriage. The prolonged nature of the relationship, spanning 16 years with unabated sexual relations, suggested the absence of force or deceit. The court referenced previous judgments, such as Mahesh Damu Khare v. State of Maharashtra and Prashant v. State (NCT of Delhi), which established that a long-term consensual relationship cannot be considered rape unless the consent was vitiated by deceit from the beginning.

Similarly, the Supreme Court overturned a rape case filed by a married woman against a man, emphasizing that a married woman cannot accuse a man of rape based on a promise of marriage while her own marriage is still valid. The court highlighted inconsistencies in the woman's narrative, noting that she continued the relationship and visited the man even while still married. The court found it implausible that she would enter a physical relationship with the man based on a promise of marriage while still married, deeming such a promise illegal and unenforceable. The court also observed that the complaint appeared to have been filed after the man's graduation and subsequent return to his hometown, suggesting a motive unrelated to the initial promise.

In another instance, the Supreme Court quashed proceedings against a man accused of rape on the pretext of a false promise of marriage, stating the woman willingly engaged in intimate relations. The court noted that the complainant agreed to the relationship out of her own desires, not because of any false promise. The prosecution's claim that the man induced the woman into a physical relationship under a false promise was not supported by the evidence.

Furthermore, the Supreme Court quashed a rape case against a man, deeming it "unbelievable" that a married woman could be misled by a promise of marriage. The court observed that the woman was living separately from her husband and alleged that the accused engaged in sexual relations with her under the pretense of marriage; however, the court found this claim unconvincing, given her marital status and age. The court emphasized the absence of coercion or force, suggesting the relationship was consensual and the rape charge legally untenable.

These judgments highlight the Supreme Court's concern regarding the misuse of Section 376 IPC in cases involving failed relationships. The court has clarified that consensual physical relations between adults cannot be automatically classified as rape simply because the relationship ended or a marriage promise was not fulfilled. A crucial distinction is made between a breach of promise and a false promise made with malicious intent, with the latter being a necessary element to establish the offense of rape. The court has also stated that there needs to be inducement by the accused with a promise of marriage before the alleged crime for it to be considered rape.