Navigating the delicate terrain of false rape charges demands a nuanced understanding of legal intricacies. In this context, the landmark judgment in the case of Naim Ahmed v. State (NCT of Delhi) emerges as a guiding light. Delivered on 23rd January 2023, this pivotal decision provides a significant precedent for those ensnared in the complexities of false rape allegations. Offering a beacon of clarity, this judgment becomes a crucial reference point for individuals grappling with the repercussions of baseless accusations. This article sheds light on the profound implications of this landmark ruling, providing insights and guidance for those facing the challenging landscape of false rape charges.
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Case Title– Naim Ahmed V. State (NCT of Delhi),23/1/2023
Facts:
- The prosecutrix, living in Delhi with her husband and three children, developed a romantic relationship with Naim Ahmed over time.
- Convinced by the accused, she left her husband and children with the promise that they would marry after her divorce.
- The accused later refused to marry her and relocated to his native place, despite her pleas during her visit to his hometown.
- The prosecutrix filed an FIR under Section 376 of IPC 1860, alleging a breach of promise and a fake marriage proposal.
- The police compiled evidence, leading to the submission of a charge sheet, and the trial court deemed it a case of rape and breach of promise.
- The accused, dissatisfied with the trial court’s decision, appealed to the high court, challenging the verdict.
- The high court reduced the sentence from 10 to 7 years, but the accused remained discontent and approached the Supreme Court.
- The accused argued in the Supreme Court that the relationship was consensual, and there was no rape or false promise of marriage.
Supreme court Analysis
After examining the past judgment of the session court, It relied upon the following cases:
- ‘Uday Vs: state of Karnataka,19 Feb; 2003
- Deepak Gulati Ve. state of Haryana (30 May, 2018)
- Dhruvaram murlidhas sonar Vs. The state of Maharashtra,22 November
Supreme Court stated that there should be a clear differentiation between consensual relationship and rape.If one is a partner in relation has a clear intention that he/she will not marry the other partner from the very first day only then it will be considered rape and fake marriage promises,
Supreme Court findings-
Supreme court analyses Sec 375, IPC, 1860 which, is the definition of rape, and Sec 90, IPC, 1860 which is the misconception of fact, and stated that the Lady was mature enough and married and it was a consentful relationship.
The SC noticed that the prosecutrix was aware that the accused was a married person and having children and that she had also met his wife at his house.
Judgment-
In this case, the Supreme Court stated that if one partner has no intention of marrying the other partner from the very first day then it will be a false promise or if one partner cannot fulfill his/her promise. of marriage because of some reasons then it will not be considered rape supreme court also gave a clear differentiation between breach of promise and not fulfilling the promise with this. Finally, the supreme court acquit the rape convict on the accused by stating that it was a content relationship and the prosecutrix was married and mature enough and also knows the consequences of that relationship so it can be a case of not fulfilling the promise but not of rape.
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