The High Court of Madhya Pradesh has declined to quash criminal proceedings initiated against a bank manager accused of sexual assault under the guise of a false promise of marriage. In a ruling delivered by Justice Himanshu Joshi, the court emphasized that the educational and financial background of a complainant does not automatically negate allegations that her consent was obtained through deception. The decision mandates that the trial must proceed, asserting that matters involving the veracity of personal representations and intent are best determined through the rigorous process of evidence appreciation at the trial stage rather than through preliminary quashing proceedings.

The case involves a 32-year-old manager employed at the State Bank of India who sought the quashment of an FIR registered at the Mahila Police Station in Mandla. The FIR , filed in early 2026 , invoked Section 69 of the Bharatiya Nyaya Sanhita , which addresses sexual intercourse through deceitful means, specifically including the promise of marriage without any genuine intention of fulfillment. The proceedings concern a long-standing relationship that began in 2022 between the applicant and the prosecutrix, both of whom held managerial roles within the same financial institution.

According to the details presented before the court, the acquaintance between the two professionals transitioned into a personal relationship, with the prosecutrix alleging that the applicant repeatedly represented his intention to marry her. These assurances were reportedly reaffirmed during visits to cities including Gwalior, Bhopal, and various tourist destinations such as Darjeeling. The complainant further contended that her insistence on formalizing the relationship was met with promises from the applicant, who even initiated discussions with her mother regarding potential marriage plans. However, the situation shifted when the applicant’s family purportedly declined the proposal, a rejection the applicant claimed he would overcome.

Tensions reportedly escalated in late 2025 following a medical crisis involving the prosecutrix's mother, which hindered the couple’s ability to interact. The prosecution alleged that the applicant’s commitment subsequently faltered, culminating in an encounter in his vehicle near NH-30 in Mandla in October 2025 . Shortly thereafter, the applicant allegedly informed the prosecutrix that his family had arranged a marriage with another woman and that he no longer intended to marry her. Attempts by the prosecutrix to resolve the matter, including a trip to the applicant's workplace in Rewa and further communication efforts, were ultimately unsuccessful, leading to the filing of the FIR in January 2026 .

Judicial Appraisal of Consensual Allegations

Counsel for the applicant argued that the criminal complaint was a retaliatory measure, or a "counterblast," following the applicant’s decision to pursue a separate matrimonial engagement. The defense maintained that both parties were mature, educated, and financially independent adults who had voluntarily engaged in a relationship. They asserted that the applicant never provided a false promise of marriage and that all family negotiations were conducted in good faith, with the applicant being transparent about his family’s conditional approval. To support this, the defense submitted various documents, including legal notices, medical records of the applicant’s father, and communication logs, contending that these proved the absence of any dishonest intent at the inception of the relationship.

In contrast, the state and the prosecutrix argued that the FIR provided specific instances and detailed allegations that could not be dismissed summarily. They maintained that the core issue—whether the applicant possessed a fraudulent intent from the very beginning—is a question of fact that requires a full trial. They insisted that the defense’s interpretation of evidence was premature and that the legal standards for quashing an FIR were not satisfied.

Addressing these contentions, the High Court observed that the judiciary must be cautious when examining the nuances of a relationship in a quashing petition. Justice Joshi remarked: "The fact that the prosecutrix is an educated and financially independent bank manager also does not, by itself, determine whether her consent was allegedly obtained by deception." The court further noted that the presence of matrimonial negotiations does not automatically absolve an individual of potential criminal liability, as the genuineness of such negotiations is itself a matter requiring deeper examination.

Limitations of Inherent Jurisdiction

The court clarified that it cannot perform the role of a trial court while acting under Section 528 of the Bharatiya Nagarik Suraksha Sanhita . The High Court stressed that a " mini-trial " is inappropriate at this stage, as the objective of the current proceedings is merely to determine if the FIR discloses a prima facie case. The ruling underscored: "This Court, while exercising inherent jurisdiction , cannot conduct a mini-trial or undertake a comparative assessment of the rival versions."

The judge held that while the applicant has the right to present his defense—including evidence of consensual conduct and the absence of malicious intent—these materials must be presented during the Sessions Trial . The court found that the chronological proximity of the applicant’s legal notice, his engagement, and the subsequent FIR did not establish, as a matter of law, that the criminal proceedings were fundamentally malicious or meritless.

The court's decision underscores the high threshold required to terminate criminal proceedings before they can reach the trial court. By refusing to intervene, the High Court has affirmed that allegations involving the sanctity of consent in intimate relationships are complex and demand a full adjudication of evidence. The application for quashing was consequently dismissed, leaving the parties to proceed with the trial in the Court of the Third Session Judge, Mandla , where the defense will have the opportunity to formally challenge the prosecution’s case through evidence and cross-examination .