Overlapping False Promise of Marriage Allegations Against Two Men: Delhi High Court Stays Rape Trial

In a development that throws a spotlight on the misuse of sexual offence laws, the Delhi High Court has stayed the trial of a man accused of rape on the false promise of marriage. Justice Prateek Jalan passed the interim order after noting that the complainant had levelled strikingly similar allegations against another individual covering the same time period, raising a prima facie doubt as to whether she could have simultaneously believed in marriage promises from two different men.

Background: A Pattern of Complaints

The case stems from FIR No. 489/2025 registered at Police Station Pahar Ganj, Delhi, under Sections 376 (rape), 313 (causing miscarriage without woman’s consent), and 506 (criminal intimidation) of the Indian Penal Code. The complainant alleged that Rohit Sehrawat, the petitioner, had established a physical relationship with her between 2018 and 2023 on the false pretext of marriage, and that she was forced to undergo an abortion.

However, Sehrawat’s legal team, led by Senior Advocate Nandita Rao, presented a chart showing that the same complainant had filed four separate complaints involving sexual allegations against different men between 2024 and 2025. Of these, two had resulted in closure reports filed by the police, and one ended through a settlement. Crucially, one of those earlier complaints, lodged in Jaipur against a man named Sagar Sharma, alleged rape on the false promise of marriage during the period 2018 to 2024 – substantially overlapping with the accusations against Sehrawat. That complaint also contained an allegation of forced abortion.

Arguments: Mala Fide Intent and Impossible Promises

Ms. Rao contended that the present FIR was vitiated by mala fides. She argued it was inconceivable that the complainant could have been induced into sexual relationships by false promises of marriage made by two different individuals at the same time. The petitioner also pointed to an earlier complaint filed by the same woman against him at the Women Police Station in Rewari, which had been settled. In a statement recorded on November 22, 2023, the complainant had undertaken to break off the relationship, not to communicate with Sehrawat, and not to file any further complaint against him. Yet, the present FIR was registered nearly two years later, in August 2025.

While the State and the complainant’s counsel Mr. Irfan Firdous accepted notice and opposed the stay, the High Court found sufficient ground to halt the trial at this stage.

Court’s Observations: Prima Facie Doubt and Legal Principles

Justice Prateek Jalan, in his order, directly addressed the overlapping nature of the allegations. He observed:

Prima facie, where allegations of this nature are made against two persons in respect of a sexual relationship which covers the same period, it raises a doubt as to whether the complainant could have been acting on the basis of the promise of marriage made by two different individuals.”

The court did not stop there. It invoked a series of recent Supreme Court decisions that have clarified the law on rape based on a false promise of marriage. In Mahesh Damu Khare v. State of Maharashtra (2024) and Samadhan v. State of Maharashtra (2025), the Apex Court held that every romantic relationship that turns sour does not automatically amount to rape, even if it initially involved a prospect of marriage. Further, in Prithvirajan v. The State Rep. by the Inspector of Police (2025), the Supreme Court laid down the essential ingredients for such an offence: the accused must have made the promise of marriage solely to obtain consent, without any intention of fulfilling it from the very outset, and the prosecutrix’s consent must have been directly influenced by that false promise.

Applying these principles, the Delhi High Court noted that the complainant’s parallel allegations against two individuals during the same period cast serious doubt on the credibility of the charge that she had consented to sex only because of Sehrawat’s alleged promise.

Decision: Stay of Trial

Consequently, the court directed that all proceedings before the Sessions Court in SC No. 347/2026 shall remain stayed until further orders. The stay is subject to final disposal of the main petition seeking quashing of the FIR. The matter has been listed for further hearing on October 5, 2026.

This interim order does not decide the case on merits, but it signals that courts are increasingly willing to scrutinise the factual matrix of such complaints where evidence of multiple, overlapping allegations surfaces. The decision underscores that while sexual offences must be taken seriously, the legal process also guards against the potential abuse of criminal machinery.

Implications: Scrutiny of Serial Complaints

The High Court’s intervention, though at an interim stage, highlights the need for judicial caution when a single complainant makes similar allegations against multiple accused covering the same timeframe. It reinforces the principle that a mere failure of a consensual relationship, even if accompanied by a broken promise of marriage, does not automatically satisfy the stringent requirements of Section 376 IPC. The order may well influence how trial courts assess applications for stay or quashing in cases with demonstrable patterns of repeated similar complaints.