Jaspal Singh Kaural vs The State of NCT of Delhi 2025: Supreme Court Case

Jaspal Singh Kaural vs The State of NCT of Delhi 2025 drew attention as it revisited the sensitive issue of false promise to marry as a ground for rape. It highlighted the distinction between a false promise made with dishonest intent and failed relationship due to changed circumstances. The Supreme Court criticized the Delhi High Court for overreaching its revisional powers by interfering with a discharge order on prima facie assessment. Discover more in-depth analyses of important Supreme Court decisions by exploring Recent Judgements of Supreme Court.

Jaspal Singh Kaural vs The State of NCT of Delhi 2025 Introduction

The case of Jaspal Singh Kaural vs The State of NCT of Delhi 2025 revolves around serious allegations of rape and criminal intimidation. The case stemmed from a long standing romantic relationship. The Prosecutrix claimed that the accused, Jaspal Singh Kaural engaged in sexual relations with her under a false promise of marriage. The dispute centred around whether this promise was genuinely made or was a deceitful tactic to exploit her consent.

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The case at hand centres around allegations of rape and criminal intimidation under Section 376 and Section 506 of Indian Penal Code. It involves a conflict originated from a long standing relationship between Appellant and Complainant. The Complainant contended that the Appellant engaged in sexual relations with her on the false promise of marriage. The following are the brief facts of Jaspal Singh Kaural vs The State of NCT of Delhi -

Challenge to High Court Order

Aggrieved by the order of the Delhi High Court the Appellant has approached the Supreme Court. The High Court of Delhi had set aside the discharge order passed by the Trial Court which had discharged the Appellant in FIR registered under Section 376 and Section 506 of Indian Penal Code at Police Station Sagarpur.

Background of First Information Report

The First Information Report was registered based on a complaint made by Respondent No. 2 i.e., Complainant. She contended that the Appellant engaged in physical relations with her on the false assurance that he would marry her and take care of her children. The Complainant stated that she had known the Appellant since 2011 prior to their respective marriages. Their relationship rekindled in 2016 when both were experiencing trouble in their marital lives.

Allegations of False Promise and Coercion

According to the Complainant, the Appellant who was then residing in Canada visited India and met her on 5th February, 2017 at his brother’s rented house in Dwarka. There he allegedly engaged in sexual relations with her and promised to marry her after divorcing his wife. She also contended that the Appellant pressured her into divorcing her own husband and even spoke to him directly and assured that he would marry her and care for her and her children.

Breakdown of the Relationship and Threats

The Complainant alleged that the Appellant lived with her for 25 days and during that time and sexually harassed her. He threatened that he would not marry her if she declined to have sexual relations with him. The Complainant obtained a divorce in 2019. However, on 20th May, 2021, the Appellant backed out of his promise to marry her and even threatened to kill her children.

Filing of First Information Report and Investigation

When the Appellant failed to attend counselling and mediation at the Mahila Police Station, the Complainant lodged a formal complaint, which led to the registration of FIR No. 281/2021 on 05.06.2021. During the investigation, the Appellant admitted to having a physical relationship with the Complainant and purchasing a mangalsutra engraved with his initials “Jas.” The police subsequently filed a charge sheet against him on 15.05.2022 under Sections 376 and 506 IPC.

6. Discharge by Sessions Court

The Appellant filed an application under Section 227 of Code of Criminal Procedure, 1973 and sought discharge. On 8th June 2023, the lower court permitted the application and discharged the Appellant. The Court noted that the Complainant had given her consent for the sexual relationship with full awareness and not due to any misconception of fact.

High Court Reversal of Discharge

The Respondent No. 2 challenged the discharge order before the Delhi High Court. On 3rd January, 2024, the High Court allowed the revision and held that prima facie evidence existed to show that the Appellant had sexual relations with the Complainant on a false promise of marriage. The Court ordered that charges under Section 376 and Section 506 of Indian Penal Code be framed against the Appellant.

The following issues were addressed in Jaspal Singh Kaural vs The State of NCT of Delhi 2025 -

1. Whether the Sessions Court was justified in discharging the Appellant under Section 376 and Section 506 of Indian Penal Code?

The main issue was whether there was sufficient material on record for the Sessions Court to discharge the accused for the alleged offences of rape and criminal intimidation based on the FIR and charge sheet.

2. Whether a prolonged consensual sexual relationship based on a promise to marry amounts to rape?

The Supreme Court in Jaspal Singh Kaural vs The State of NCT of Delhi examined whether the consent of the Prosecutrix for sexual intercourse was obtained under a false promise of marriage.

3. Whether the promise to marry was false from the beginning or a case of mere breach of promise?

The Court had to examine whether the Appellant never intended to marry the Prosecutrix from the beginning which would indicate a false promise or if the relationship failed due to circumstances which arose later amounts to a breach of promise.

Jaspal Singh Kaural vs The State of NCT of Delhi 2025 Legal Provisions

Section 376 and Section 506 of Indian Penal Code played an important role in Jaspal Singh Kaural vs The State of NCT of Delhi 2025. The following are analysis of these provisions 

• Section 376 of Indian Penal Code: Punishment for Rape
  Section 376 (Now Section 64 of Bharatiya Nyaya Sanhita, 2023) prescribes punishment for committing rape. The main question was whether the alleged sexual intercourse between Appellant and Prosecutrix was non-consensual due to a false promise of marriage.
• Section 506 of Indian Penal Code: Criminal Intimidation
  Section 506 (Now Section 351 of Bharatiya Nyaya Sanhita, 2023) deals with punishment for threatening another person to cause alarm. The Prosecutrix contended that the Appellant threatened her with dire consequences to maintain silence.

Jaspal Singh Kaural vs The State of NCT of Delhi 2025 Judgment and Impact

On 7th April, 2025, the 2-Judge Bench of the Supreme Court comprising Justice B V Nagarathna and Justice Satish Chandra Sharma in Jaspal Singh Kaural vs The State of NCT of Delhi allowed the appeal and reversed the order of Delhi High Court. It upheld the decision of Session Court which had discharged the Appellant from offences under Section 376 and Section 506 of Indian Penal Code. The Court noted that the material on record did not substantiate the allegations of rape or criminal intimidation.

The Supreme Court held that the Prosecutrix had willingly entered into a long-term consensual relationship with the Appellant even when she remained married to another person. It found that the promise to marry was not false from the outset and that the Appellant had acted on this promise as evidenced by his conduct and actions including preparing a mangalsutra with the initials of Prosecutrix. 

The Court highlighted in Jaspal Singh Kaural vs The State of NCT of Delhi that a mere breach of promise does not amounts to rape unless it is proven that the accused never intended to marry from the beginning and used the promise solely to obtain consent for sexual relations.

The Supreme Court condemned the Delhi High Court for overstepping its revisional jurisdiction by conducting a detailed analysis at the stage of framing charges. It reiterated that at such a stage the courts must only examine whether the materials on record disclose a prima facie case. It noted that the FIR and chargesheet did not reveal the essential ingredients of rape or criminal intimidation the Court deemed the discharge order by the Sessions Court legally justified.

Thus, the Supreme Court in Jaspal Singh Kaural vs The State of NCT of Delhi ordered the termination of all criminal proceedings under Sections 376 and 506 of Indian Penal Code against the Appellant. 

Conclusion

In Jaspal Singh Kaural vs The State of NCT of Delhi 2025 the Supreme Court on 7th April, 2025 set aside the decision of Delhi High Court and upheld the Sessions Court order to discharge the Appellant. It held that the evidence did not support the allegations of rape or criminal intimidation. The Court explained that a consensual relationship does not amount to rape unless it is proven that the promise to marry was false from the beginning.