- Case
- SANDEEP SINGH THAKUR v. THE STATE OF MADHYA PRADESH (Supreme Court of India, 05-12-2025)
- Law
- Constitution of India, Indian Penal Code, Code of Criminal Procedure.
Facts: The appellant and the second respondent (prosecutrix) met on social media in 2015 and developed a consensual relationship. Subsequently, the second respondent filed an FIR alleging a false promise of marriage, leading to charges under Sections 376 and 376(2)(n) of the Indian Penal Code (IPC). The appellant was convicted and sentenced.
Procedural Posture: The appellant appealed the conviction to the Madhya Pradesh High Court, seeking suspension of his sentence, which was rejected. He then appealed to the Supreme Court of India. During the pendency of the appeal, the Supreme Court explored the possibility of reconciliation between the parties.
Issue: Whether the criminal proceedings and conviction against the appellant should be quashed, considering the subsequent marriage between the appellant and the prosecutrix, and whether Article 142 of the Constitution of India can be invoked to do complete justice in the matter.
Holding: Yes, the Supreme Court quashed the FIR, the judgment of conviction, and the sentence passed against the appellant, invoking its powers under Article 142 of the Constitution of India.
Reasoning: The Court noted that the parties had married and were residing together. It considered that the criminal proceedings arose from a misunderstanding of their consensual relationship. In the interest of justice and to do complete justice, the Court invoked Article 142 to quash the proceedings, conviction, and sentence. The Court also directed the Chief Medical Officer to revoke the appellant's suspension from service and pay arrears of salary, as the appellant had rejoined duty following the revocation of his suspension. The Court stated, "we think interest of justice would be sub-served if the FIR No. 29 of 2021 dated 02.11.2021 lodged with Women Police Station, District Sagar and the judgment of the I Additional Sessions Judge, Sagar and the order of conviction and sentence passed dated12.04.2024 therein, stand quashed."
