SC Quashes Promise-to-Marry FIR: Relationship Was Consensual

Supreme Court Quashes False Promise of Marriage FIR: Complaint Showed a Consensual Relationship, No Deceitful Inducement

Published: 6 November 2026 · NyayVidhan · 3 min read

In N.J.T. v. State of Gujarat & Anr., the Supreme Court quashed an FIR alleging that the appellant had sexual relations with the complainant on a false promise of marriage. Holding the issue squarely covered by a coordinate Bench's order in Kunal Rameshbhai Kalyani v. State of Gujarat, it applied that order's observations: a complaint indicating a consensual relationship, with nothing to show deceitful inducement on a promise to marry, does not show such conduct. All consequential proceedings were terminated (paras 7-9).

Key holdings

The issue was held squarely covered by Kunal Rameshbhai Kalyani v. State of Gujarat, 2026 SCC Online SC 1818, whose observations the Court applied (paras 7-8).

The test, drawn from Deepak Gulati: the accused must have had no intention of keeping the promise at the initial stage itself; a good-faith promise later not kept is not a misconception of fact (para 8).

Section 69 of the BNS likewise targets a promise to marry made without any intention of fulfilling it (para 8).

The FIR and all consequential proceedings were quashed; the complainant, though served, did not appear (paras 2, 9).

Judgment digest by NyayVidhan: a summary of the court's judgment, not its text. The judgment itself is the authoritative version.

Brief Facts

The appellant and the complainant, respondent No. 2, came into contact through social-media messages, became friends and began to meet (para 4). Her FIR states that at one meeting he told her he was going to marry her and, giving that assurance, established physical relations; that the relations continued over the following years, by luring her with the promise of marriage; and that he later refused to marry her (para 4). Read plainly, the FIR shows a relationship of almost six years (para 5). On 15.07.2026 the High Court of Gujarat rejected his application to quash the FIR (para 3). The complainant, though served, did not appear before the Supreme Court (para 2).

Court's Findings

The Court read the FIR plainly: the parties had been in a relationship for almost six years, and the sum and substance of the accusation was that she maintained physical relations relying on his promise to marry her (para 5). The only question was whether the High Court erred in refusing to quash (para 6). The Court held that the issue stood squarely covered by a coordinate Bench's order in Kunal Rameshbhai Kalyani v. State of Gujarat, 2026 SCC Online SC 1818, and set out its observations as applicable to the facts (paras 7-8). Those observations, drawing on Deepak Gulati v. State of Haryana, require that the accused had no intention of keeping the promise at the initial stage itself; a promise made in good faith but not kept for unavoidable reasons is not a misconception of fact, and Section 69 of the BNS demands the same proof. They hold that where the complaint indicates a consensual relationship, nothing shows the deceitful conduct of inducing the complainant into intercourse that she agreed to only on the promise to marry (para 8). Adding no further reasons, the Court allowed the appeal and quashed the FIR (para 9).

Legal Principle

Following a coordinate Bench, the Court treated an FIR whose own allegations indicate a consensual relationship, with nothing to show deceitful inducement into intercourse on a promise to marry never meant to be kept, as one to be quashed together with all consequential proceedings (paras 5, 7-9).

NyayVidhan's view · Practice note

Why It Matters

The order turns on what the FIR itself says (para 5). In a quashing plea in a promise-to-marry case, it helps to show from the complaint's own words how long the relationship lasted and whether it reads as a consensual relationship rather than consent obtained by a promise never meant to be kept (paras 5, 8). The Court gave no reasons beyond applying the earlier order's observations, so the two should be read together (paras 7-9). For the test of intention at the initial stage, see Deepak Gulati v. State of Haryana; for another 2026 quashing on a false promise of marriage, Sachin Gupta v. State of Chhattisgarh and Anr.

Editorial comment by the NyayVidhan Editorial Desk. It is not part of the Court's judgment and is not legal advice.

Precedents Relied Upon

Kunal Rameshbhai Kalyani versus State of Gujarat and Another 2026 SCC Online SC 1818
Followed Discussed at ¶ 7, 8
Order of a coordinate Bench held to cover the issue squarely; its observations, set out as applicable to the facts, are that a false promise of marriage requires a promise given with no intention, from the start, of keeping it (Section 375 read with Section 90 IPC, now Section 69 BNS), and that a complaint indicating a consensual relationship, with nothing to show deceitful inducement into sexual intercourse only on the promise to marry, does not show such conduct. Followed to allow the appeal and quash the FIR.