Consensual Relationship Turning Sour Is Not a False Promise of Marriage, Rules Karnataka High Court in Dr. Ramdas @ Ramdas Patil v. State of Karnataka
Case: Dr. Ramdas @ Ramdas Patil v. State of Karnataka and Another
Date of Judgment: 16 October 2026
Court: High Court of Karnataka
Coram: Justice M. Nagaprasanna
Proceedings: Criminal Petition No. 10701 of 2025
Court Observation
“The subject case becomes a classic illustration of abuse and misuse of Section 69 of the BNS which are now mushrooming in courts.”
Summary
The Karnataka High Court has quashed criminal proceedings against a doctor who was accused of sexual intercourse on a false promise of marriage, holding that a consensual relationship that turns sour does not by itself amount to an offence under Section 69 of the Bharatiya Nyaya Sanhita, 2023. The court held that, even accepting the complainant’s allegations as stated, they did not disclose an offence under Section 69 or under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989.
For a false promise of marriage to constitute an offence, the court explained, the promise must have been made with no intention of fulfilling it from the very beginning. The fact that a relationship ends without marriage, or ends because of other considerations, is not by itself sufficient to establish criminal liability. The intention behind the alleged promise is the key consideration, and it must be judged from the outset rather than from the fact that the relationship later broke down.
The court also observed that consensual acts between individuals over several years are increasingly being projected as ingredients of Section 69, and warned against using criminal law to punish a person merely because a consensual relationship ends without marriage. The allegations in this case remain untested on their merits, and the court expressed no view on the truth of the underlying relationship beyond holding that the allegations, even if accepted, disclosed no offence.
Key Holdings
- A consensual relationship that turns sour does not, by itself, amount to a false promise of marriage under Section 69 of the Bharatiya Nyaya Sanhita, 2023.
- For Section 69 to apply, the promise of marriage must have been made with no intention of fulfilling it from the very beginning; a later breakdown of the relationship is not sufficient.
- Where the allegations, even if accepted as stated, do not disclose the ingredients of the offence, continuation of the proceedings would be an abuse of the process of law.
- Criminal law cannot be used to punish a person merely because a consensual relationship ends without marriage.
Directions Issued
- The criminal proceedings and the charge-sheet against the petitioner are quashed.
Background
The petitioner and the complainant had a relationship between 2019 and 2023 while both were pursuing medical courses. A case was registered on 15 March 2025 at the Mangaluru Women police station, and a charge-sheet followed, invoking Section 69 of the Bharatiya Nyaya Sanhita and provisions of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act. The petitioner contended that the relationship was never entered into on a promise of marriage or by deceitful means, and that a further trial would be an abuse of the process of law. The High Court, which had reserved the matter on 16 July 2026, accepted that contention and quashed the proceedings.
Related Articles
- Married Woman Wilfully Cohabitating With Another Man Can’t Prosecute Him For Rape Under False Promise Of Marriage: Telangana High Court
- Supreme Court Clarifies: Promise to Marry and Consensual Relationship Based on Consent Do Not Amount to Rape—POCSO Case Quashed
- No Allegation That Promise To Marry Was False At The Inception: Supreme Court Quashes Rape Case
Disclaimer: This is a summary prepared for informational purposes only and does not constitute legal advice. Readers should refer to the official judgment for the authoritative text.
