The Madhya Pradesh High Court observed that the prosecutrix, being an educated, financially independent woman working as a bank manager, does not, by itself, determine whether her consent was allegedly obtained through deception. [2026 LiveLaw (MP) 435]

The court further elucidated that the fact that matrimonial negotiations had taken place between the parties also cannot conclusively establish the absence of dishonest intentions. 

Emphasizing that the court cannot, under inherent jurisdiction, examine whether such conduct demonstrates a genuine intention, the bench of Justice Himanshu Joshi rejected the accused man's plea seeking quashing of the FIR under Section 69 of BNS (sexual intercourse where consent is obtained by deception or false promise to marry).

"The fact that the prosecutrix is an educated and financially independent bank manager also does not, by itself, determine whether her consent was allegedly obtained by deception. Likewise, the fact that matrimonial negotiations took place cannot conclusively establish absence of dishonest intention. Whether such conduct demonstrates a genuine intention to marry throughout the relevant period is a matter for appreciation of evidence. This Court, while exercising inherent jurisdiction, cannot conduct a mini-trial or undertake a comparative assessment of the rival versions". 

Per the prosecution's case, the prosecutrix was working as Manager of SBI and was acquainted with the applicant, who was also working as Manager there. They developed a friendship and remained in contact. On January 23, 2023, while she was posted in Gwalior, the applicant came there and established a physical relationship with her. She claimed that she insisted on marriage before such a relationship, but the applicant assured her that he would marry her. 

Thereafter, the applicant spoke to the prosecutrix and requested her to approach his family regarding marriage. Marriage negotiations took place, but the applicant's mother declined the proposal. The prosecutrix alleged that the applicant kept assuring her that he would convince his family and established physical relations with her on several occasions. 

It was further claimed that in November 2025, the applicant informed her that his family had selected another girl for him to marry and he would proceed with the decision. Despite her attempt to persuade him, he refused. Thus, she filed an FIR on January 17, 2026. 

The counsel for the applicant claimed that the FIR was a counterblast and that he never gave any false promise to marry. It was argued that the applicant himself asked the prosecutrix to approach his family for marriage negotiations. 

The government advocate for the State argued that the FIR contained specific allegations against the applicant. Further, it was argued that whether the applicant's intentions were dishonest from the start or not ought to be examined at trial.

The court noted that the FIR contained specific and detailed allegations against the applicant. The FIR also referred to particular instances where physical relations were established. Thus, the case cannot be said to "be vague or bereft of material allegations".

However, the court reiterated that every failure to fulfill a promise of marriage does not constitute a false promise or criminal liability. It was stated that the prosecution needs to show that the promise was false when made and that the maker had no intention of fulfilling it at that time, and that such a false promise has a direct nexus with the consent to sexual acts. 

In the present case, the court noted that the FIR, at its face value, prima facie has the ingredients of the offence alleged. 

Noting that the chargesheet has been filed and trial is pending before a competent court, the court refused the relief sought by the applicant and dismissed the petition. 

For Applicant: Advocate Ravi Shankar Yadav

For State: Government Advocate Raghuvar Prajapati

For Prosecutrix/respondent no 2: Advocate Shankar Dayal Mishra