Supreme Court Quashes Conviction After Parties Marry; Invokes Article 142 to Do Complete Justice

A bench of Justice B.V. Nagarathna and Justice Satish Chandra Sharma heard an appeal against the Madhya Pradesh High Court’s refusal to suspend sentence and the conviction imposed by the Sessions Court. The appeal assailed the rejection of an application for suspension of sentence and challenged convictions under Sections 376(2)(n) and 417 IPC arising from an alleged false promise of marriage.

The Court allowed the appeal in the interest of justice and quashed the FIR, the conviction and the sentence. The Court recorded that the parties had married and were living together, and it exercised its powers under Article 142 of the Constitution to “do complete justice in the matter.” The Court noted that its intervention during the hearing led to discussions in Chambers with the parties and their parents, which culminated in the marriage on 22.07.2025. The Court observed that it had, in effect, sought to reunite the parties: “we had a sixth sense that the appellant and the respondent prosecutrix could be brought together once again if they decided to marry each other.” The Court, in its reasoning, observed: “We think that owing to a misunderstanding the consensual relationship between the parties was given a criminal colour and converted into an offence of false promise of marriage whereas the parties, in fact, intended to marry each other. It was only owing to the appellant seeking postponement in the date of marriage which may have led to insecurity in the mind of the respondent prosecutrix and filing of the criminal complaint.” The Court further recorded that it had “invoked our powers under Article 142 of the Constitution of India to do complete justice in the matter by quashing the complaint as well as the conviction and sentence passed against the appellant herein.”

Background The appellant and the prosecutrix met in 2015 on a social media platform and entered into a consensual relationship. The prosecutrix alleged that she had acted on a false promise of marriage and lodged FIR No.29 of 2021 dated 02.11.2021 under Sections 376 and 376(2)(n) IPC. A chargesheet followed and the Additional Sessions Judge convicted the appellant under Sections 376(2)(n) and 417 IPC, sentencing him to rigorous imprisonment for ten years (with Rs.50,000 fine) for Section 376(2)(n) and two years (with Rs.5,000 fine) for Section 417. The appellant filed Criminal Regular Appeal CRA No.4869 of 2024 before the Madhya Pradesh High Court and sought suspension of sentence by I.A. No.9352 of 2024; the High Court rejected the suspension application by order dated 05.09.2024.

While the appeal was pending in this Court, the Supreme Court directed both parties to appear and permitted a meeting in Chambers with their parents and counsels. The parties informed the Court of their willingness to marry; interim bail and suspension of sentence were ordered to facilitate discussions. The parties married on 22.07.2025 and resided together thereafter. Taking these developments into account and the parties’ request that criminal proceedings not continue, the Court exercised its extraordinary jurisdiction under Article 142 to quash the FIR, the trial court’s judgment of conviction dated 12.04.2024 and the sentence. The Court also directed the State to revoke the appellant’s suspension from service and to pay arrears of salary within two months. CRA No.4869 of 2024 before the High Court was rendered infructuous and the appeal was disposed of accordingly. Pending applications stood disposed.

Case Details: Case No.: 2025 INSC 1499 (Criminal Appeal No. 5256 of 2025) Case Title: Sandeep Singh Thakur v. State of Madhya Pradesh & Another Appearances: For the Petitioner(s): [Names not indicated in the judgment] For the Respondent(s): [Names not indicated in the judgment]