Interpreting Section 69 BNS: Consensual Relationships and False Promises of Marriage in Quashing Proceedings

sketch of the Bombay High Court
Case
DR. GANESH HARIBHAU HOL v. THE STATE OF MAHARASHTRA AND ANOTHER (Bombay High Court, 04-09-2026)
Law
Bharatiya Nagarik Suraksha Sanhita, Bharatiya Nyaya Sanhita.

Highlights of the Judgment:

  • Detailed examination of Section 69 of the Bharatiya Nyaya Sanhita, 2023, concerning sexual intercourse under a false promise of marriage.
  • Judicial interpretation distinguishing between a genuine breach of a promise made in bad faith and a romantic failure of a consenting relationship.
  • Application of Section 528 of the BNSS for quashing criminal proceedings arising from prolonged consensual affairs.
  • Evidentiary reliance on digital chat transcripts to negate claims of deceit or coercion.
  • Assessment of unexplained delays in filing FIRs and their impact on allegations of criminal intimidation under Section 351(3) of the BNS.