By Shazia Siddiqui

The Madras High Court recently rendered a significant judgment acquitting a man accused of rape under Sections 375 and 376 of the Indian Penal Code, as well as Sections 90 and 417, which stemmed from allegations that he had engaged in sexual intercourse with the victim under false promises of marriage. The case hinged on whether the sexual encounter was consensual and whether the promise of marriage constituted a misconception of fact under Section 90 of the IPC.

The court’s deliberations centered on the testimony of the prosecutrix, who asserted that she had consented to sexual relations with the accused based on his assurance of marriage. However, crucially, the court found that the prosecutrix was aware of the accused’s marital status at the time of the incident, thereby casting doubt on her claim that she had been misled by the promise of marriage.

The appellant vigorously contended that the sexual encounter was consensual and argued against the application of Section 90 of the IPC, which deals with consent obtained under misconception of fact. He maintained that the prosecutrix had willingly participated in the act with full knowledge of his marital status and without any fear or misconception induced by false promises.

In its detailed analysis, the court highlighted the legal definition of consent under Section 375 of the IPC, emphasizing that consent must be voluntary and based on a clear understanding of the nature and implications of the act. The judgment underscored that the prosecutrix’s consent did not hinge solely on the promise of marriage but was given with full awareness of the circumstances, including the appellant’s marital status and familial responsibilities.

Moreover, the court addressed broader issues regarding the misuse of rape laws and the need to safeguard both women from exploitation and men from unjust legal repercussions. It emphasized the judiciary’s dual responsibility to protect the integrity of the legal framework while ensuring fair and impartial justice in cases of sexual assault.

The court’s decision to acquit the appellant was grounded in its meticulous scrutiny of the evidence presented. It noted that the prosecutrix’s testimony and other evidence did not substantiate her claim that her consent was induced solely by the promise of marriage, which the court found did not constitute a misconception of fact given the circumstances known to her.

The judgment reflects the judiciary’s commitment to upholding the principles of justice and fairness in sensitive cases like sexual assault. It underscores the importance of distinguishing between genuine cases of coercion or deception and instances where consent, albeit regretted later, was given with full awareness of the relevant facts.

The Madras High Court’s ruling in this case serves as a reminder of the complexities involved in adjudicating sexual assault cases and the court’s duty to ensure that justice is rendered impartially and in accordance with the law. The judgment reaffirms the importance of evidence-based analysis and fair treatment of all parties involved, maintaining the integrity of the legal system and protecting the rights of both accusers and the accused in cases of sexual misconduct.

Case Title: Rahul Gandhi vs State

Citation: CRL.A. No.548/2021 

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