In a significant judgment clarifying the boundaries between a failed romantic relationship and criminal conduct, the Delhi High Court has quashed an FIR registered against a doctor for alleged rape and offences under the SC/ST Act. The Court, presided over by Hon’ble Dr. Justice Swarana Kanta Sharma, observed that the criminal justice system cannot be used to settle scores in a relationship that was entered into voluntarily by two consenting adults.

The judgment in the case of Dr. Avadesh Kumar vs. State NCT of Delhi & Anr (CRL.M.C. 3/2025) serves as a crucial reminder of the legal distinction between a "breach of promise to marry" and "rape on the pretext of marriage."

The case began when an FIR was registered at Police Station Wazirabad, Delhi, following a complaint by a woman (the prosecutrix). She alleged that the petitioner, a doctor, had established a physical relationship with her under the false promise of marriage. She further claimed that the petitioner was aware of her caste and had later refused to marry her, leading to allegations under Section 376 (Rape) of the Indian Penal Code (IPC) and relevant sections of the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act.

The petitioner, however, moved the High Court seeking to quash the FIR. He argued that the relationship was entirely consensual, long-term, and that the allegations were only made after the relationship ended.

The High Court meticulously examined the evidence, including the history of the relationship and contemporaneous records. A central piece of evidence that shaped the Court's decision was the extensive WhatsApp conversations between the parties.

The Court noted that the parties were in a relationship for a significant period. The communications suggested a high level of intimacy, mutual affection, and voluntary participation. Justice Swarana Kanta Sharma pointed out that:

No Immediate Protest: There was a significant delay in filing the FIR. The alleged "forced" incidents were not reported for a long time, during which the parties continued to interact normally.
Maturity of the Parties: Both the petitioner and the complainant were educated adults capable of understanding the consequences of their actions.
Nature of Consent: The Court found that the consent for physical intimacy was not obtained through "misconception of fact" (a false promise from the very beginning) but was part of a voluntary romantic engagement.

The judgment delves deep into the "Pretext of Marriage" doctrine. Under Indian law, sex obtained by a false promise of marriage is considered rape because the consent is seen as vitiated by a "misconception of fact."

However, the Delhi High Court highlighted a vital distinction:

False Promise: When the accused had no intention of marrying the woman from the very first day and used the promise only as a tool to obtain sexual favors.
Breach of Promise: When a person enters a relationship with the genuine intention of marriage, but due to unforeseen circumstances, family opposition, or personality clashes, the marriage does not eventually take place.

In this case, the Court found no evidence of a "dishonest intention at the inception." The WhatsApp chats did not reflect a man who was deceiving a woman; rather, they showed two people in a complicated, evolving relationship.

One of the most critical aspects of this judgment is the Court's handling of the charges under the SC/ST Act. The complainant had alleged that the petitioner refused marriage because of her caste.

Justice Swarana Kanta Sharma reiterated the settled legal position: To attract the provisions of the SC/ST Act, the offence must have been committed on the ground that the person belongs to a Scheduled Caste or Tribe.

Upon reviewing the verified material, the Court found:

The chats did not contain any caste-based slurs or insults.
There was no evidence that the petitioner’s actions were motivated by the complainant’s caste identity.
The mere fact that the complainant belongs to a Scheduled Caste does not automatically make every dispute with her an "SC/ST Act offence."

The Court observed that invoking the rigors of the SC/ST Act without specific evidence of caste-based motivation is an abuse of the law.

The Court exercised its inherent powers under Section 482 of the Cr.P.C. (now Section 528 of the Bharatiya Nagarik Suraksha Sanhita). This power is used to "prevent the abuse of the process of any court" and to "secure the ends of justice."

The Court concluded that:

Continuing the trial would be an exercise in futility. Since the evidence clearly pointed toward a consensual relationship, the chances of conviction were almost non-existent.
Protection of Liberty: Forcing a professional (in this case, a doctor) to undergo a grueling criminal trial for a failed relationship would lead to grave injustice.
No Criminality: The dispute was essentially private and personal in nature, lacking the "criminal intent" required to sustain a rape charge.

The judgment is notable for its "humanized" tone. It acknowledges that while heartbreak and the end of a relationship are painful, they do not always constitute a crime. The Court observed that "the law cannot be used as a weapon to punish a former partner when a relationship fails to result in marriage."

Justice Swarana Kanta Sharma’s findings emphasize that the integrity of the law against sexual violence must be protected by ensuring it is not used in cases where consent was clearly present.

The Delhi High Court's decision to quash the FIR against Dr. Avadesh Kumar sets a strong precedent in matrimonial and relationship-based criminal jurisprudence.

Key takeaway points from the judgment include:

Consent is key: If an adult woman enters a physical relationship over a long period without protest, the burden of proving "pretext of marriage" is very high.
WhatsApp as Evidence: Modern digital communications are vital in determining the true nature of a relationship.
SC/ST Act Rigor: The Act requires a "caste-based motive" and cannot be tagged onto a rape case simply because of the victim's background.
Judicial Intervention: High Courts will not hesitate to quash FIRs in consensual cases to save the parties from the trauma of a meritless trial.

This judgment reinforces the philosophy that the criminal law should be reserved for actual perpetrators of violence, and not for the adjudication of broken hearts in consensual adult lives.

Case Details:

Case Title: Dr. Avadesh Kumar vs. State NCT of Delhi & Anr.
Case Number: CRL.M.C. 3/2025
Court: High Court of Delhi
Date of Judgment: January 12, 2026
Bench: Hon’ble Dr. Justice Swarana Kanta Sharma