False Promise to Marry: Meaning & Supreme Court Test

Understand the legal meaning of false promise to marry, its essential ingredients, Supreme Court principles, and its application under Section 69 BNS.

A relationship may end for many reasons. People fall in love, become engaged, make plans for marriage, and sometimes part ways because of family opposition, incompatibility, financial difficulties, or changed personal circumstances. The law recognises that not every failed relationship is a criminal offence.

However, Indian criminal law also recognises that a person may deliberately deceive another by making a promise of marriage that was never intended to be fulfilled. If such a false promise induces a woman to consent to a sexual relationship, the legal consequences can be severe.

This distinction lies at the heart of thousands of criminal cases filed across India every year. Courts are repeatedly called upon to answer a difficult question: Was the promise genuine when it was made, or was it a deceptive tool used only to obtain consent?

The answer determines whether the case involves:

a failed relationship,
a breach of promise,
or a criminal offence.

With the enactment of the Bharatiya Nyaya Sanhita, 2023 (BNS), Parliament introduced Section 69, creating a specific offence relating to sexual intercourse by employing deceitful means, including a false promise of marriage. Although the statutory framework has changed, the judicial principles developed by the Supreme Court over the past two decades continue to play a significant role in interpreting this provision.

This article explains the legal meaning of a false promise to marry, the essential ingredients recognised by Indian courts, the leading Supreme Court principles, and their relevance under Section 69 BNS.

Table of Contents

Why Understanding This Principle Matters

The phrase “false promise to marry” is frequently used in police complaints, media reports, and social discussions. Yet, it is also one of the most misunderstood concepts in criminal law.

Many people assume that:

every broken promise amounts to cheating;
every unsuccessful relationship automatically creates criminal liability; or
refusal to marry after a relationship is sufficient to establish an offence.

These assumptions are legally incorrect.

Indian courts have consistently held that criminal liability does not arise merely because a relationship ends without marriage. The prosecution must establish something more fundamental—a dishonest intention existing at the time the promise was made.

This principle serves two important purposes.

First, it protects women from genuine cases of deception where consent was obtained through a fraudulent promise of marriage.

Secondly, it prevents criminal law from being used to convert every failed romantic relationship into a prosecution merely because the relationship ultimately broke down.

The Supreme Court has repeatedly emphasised that criminal courts must carefully distinguish between:

a genuine promise that later became impossible to fulfil; and
a promise that was false from its inception.

This distinction forms the foundation of almost every leading judgment on the subject.

The Statutory Position Before and After Section 69 BNS

Before the Bharatiya Nyaya Sanhita came into force, allegations involving a false promise to marry were generally examined under the provisions relating to rape, particularly where the prosecution alleged that the woman’s consent had been obtained under a “misconception of fact”. Courts interpreted these cases through the combined operation of the relevant provisions of the Indian Penal Code and the principles laid down in Supreme Court judgments.

The enactment of Section 69 BNS represents a significant legislative development. Instead of requiring courts to fit every allegation within the earlier legal framework, Parliament has now created a specific offence dealing with sexual intercourse obtained through deceitful means, including a false promise of marriage.

While the statutory wording has changed, one question remains unchanged: When does a promise become legally “false”?

The Bharatiya Nyaya Sanhita does not define every factual situation in which a promise will be regarded as false. Consequently, courts are likely to continue relying upon the principles already developed by the Supreme Court while interpreting Section 69.

Understanding those judicial principles is therefore essential for:

complainants considering legal action;
accused persons defending criminal proceedings;
investigating officers conducting inquiries;
prosecutors evaluating evidence; and
defence lawyers advising clients.

What Is a False Promise to Marry in Law?

The expression “false promise to marry” does not simply mean that a person promised marriage and later failed to fulfil that promise. If that were the legal test, every broken engagement or unsuccessful relationship could potentially become a criminal case. Indian courts have consistently rejected such an approach.

Instead, the Supreme Court has developed a much narrower and more precise legal test. The focus is not on whether the marriage ultimately took place, but whether the promise was genuine when it was made.

A promise becomes legally significant when the prosecution can establish that:

the accused never intended to marry at the time the promise was made;
the promise was made only to obtain the woman’s consent for a sexual relationship; and
the woman’s consent was directly influenced by that false promise.

The crucial inquiry, therefore, concerns the state of mind of the accused at the inception of the relationship or at the time the promise was made. If the promise was honest at that stage but later circumstances prevented the marriage, criminal liability ordinarily does not arise merely because the relationship ended.

This principle forms the foundation of the Supreme Court’s jurisprudence on false promise to marry cases and continues to guide courts when interpreting allegations under Section 69 BNS.

The Essential Legal Ingredients

Although every case depends on its own facts, the judicial decisions reveal certain recurring elements that courts examine before concluding that a promise of marriage was false.

1. A Promise of Marriage

The prosecution must first establish that a promise to marry was actually made. Such a promise need not always be in writing or expressed in formal words. Courts may infer it from the conduct of the parties, their communications, engagement discussions, or other surrounding circumstances.

At the same time, courts are cautious not to infer a promise merely because the parties were in a romantic relationship. Love, affection, or discussions about the future do not automatically amount to a legally relevant promise of marriage.

2. The Promise Must Be False from the Beginning

This is the most important requirement recognised by the Supreme Court.

A promise becomes criminal only when it was false at its inception. In other words, the prosecution must establish that the accused had no genuine intention of marrying when the promise was made.

If the intention to marry genuinely existed but later changed because of unforeseen circumstances—such as family opposition, incompatibility, financial hardship, or other supervening events—the case ordinarily remains one of a failed relationship rather than criminal deception.

This distinction protects the boundary between civil, moral, and criminal liability.

3. The False Promise Must Induce Consent

The existence of a false promise alone is insufficient.

Courts also examine whether the woman’s consent to the sexual relationship was caused by that promise.

If the evidence shows that the parties voluntarily entered into a consensual relationship for reasons independent of the alleged promise, the necessary causal connection may be absent.

Accordingly, courts ask:

Would the woman have consented even without the promise?
Was marriage the principal reason for the consent?
Was the promise merely one of several factors influencing the relationship?

These questions are central to judicial analysis because criminal liability depends not only upon deception but also upon its effect on the complainant’s decision.

4. The Prosecution Must Prove These Ingredients

As in every criminal case, the burden rests on the prosecution to establish the ingredients of the offence.

The court does not presume that every failed promise was dishonest. Instead, the prosecution must place sufficient material before the court from which dishonest intention at the inception of the promise can reasonably be inferred.

This often requires a careful examination of the conduct of both parties throughout the relationship rather than focusing only on its eventual breakdown.

Breach of Promise vs. False Promise: The Most Important Distinction

One of the greatest contributions of the Supreme Court to this area of law has been the clear distinction between a breach of promise and a false promise.

Although these expressions are frequently used interchangeably in everyday conversation, they represent two very different legal concepts.

A breach of promise occurs when a person genuinely intended to marry but later failed to do so because circumstances changed. Human relationships are influenced by numerous factors—family objections, health concerns, employment issues, financial instability, or simply the gradual breakdown of the relationship. Such situations may involve emotional hardship, but they do not automatically establish criminal intent.

A false promise, on the other hand, involves deception from the very beginning. The promise is made not with the intention of honouring it but as a means to obtain consent that would otherwise not have been given.

This distinction explains why courts repeatedly caution against criminalising every failed relationship.

The criminal law is designed to punish fraudulent conduct, not unsuccessful relationships.

Recommending read: Breach of Promise vs. False Promise: Legal Difference Explained

How the Supreme Court Developed This Principle

The law did not evolve through a single judgment. Instead, it developed gradually as the Supreme Court considered different factual situations over more than two decades.

Early decisions recognised that consent obtained by deception may lose its legal validity. Subsequent judgments refined this principle by distinguishing genuine promises from dishonest ones and by emphasising the importance of examining the accused’s intention at the time the promise was made.

Later decisions further clarified that:

a subsequent refusal to marry does not by itself prove that the original promise was false;
every allegation must be assessed on its own evidence;
the entire conduct of the parties should be considered rather than isolated incidents; and
criminal courts must avoid substituting hindsight for proof of dishonest intention.

This body of jurisprudence now forms the interpretative framework that High Courts continue to apply while dealing with allegations involving false promises of marriage.

Key Takeaways

A false promise to marry is not the same as a broken promise to marry.
The decisive question is whether the accused intended to marry when the promise was made.
Courts examine whether the alleged promise directly induced the complainant’s consent.
Honest promises that later fail due to changed circumstances generally do not attract criminal liability.
The distinction between breach of promise and false promise is the cornerstone of Indian judicial jurisprudence in this area.

How the Law on False Promise to Marry Evolved – Supreme Court’s Judicial Journey

The legal principles governing false promise to marry cases did not emerge from a single judgment. Instead, they evolved over time as the Supreme Court considered different factual situations and refined the law.

While the facts of each case differed, one common thread runs through the Court’s jurisprudence:

The criminality of a promise depends on the intention with which it was made, not merely on the fact that the marriage did not take place.

The following judgments form the foundation of Indian law on this issue.

Recommended Reading: How Courts Determine Whether the Accused Never Intended to Marry

1. Uday v. State of Karnataka (2003)

The Issue Before the Supreme Court

Whether every promise of marriage that is subsequently not fulfilled makes the woman’s consent invalid and attracts criminal liability.

The Court’s Decision

The Supreme Court held that a promise to marry which could not ultimately be fulfilled is not, by itself, sufficient to establish that the woman’s consent was obtained under a misconception of fact.

The Court observed that relationships often develop over time and may fail for reasons that were never anticipated at the beginning. Therefore, merely because the parties did not marry does not permit the court to conclude that the original promise was dishonest.

Legal Principle Established

The Court recognised that:

a distinction must be drawn between a false promise and a genuine promise that later failed;
criminal liability cannot be based solely upon the subsequent failure of the relationship; and
courts must carefully examine the surrounding circumstances before treating consent as legally vitiated.

Although later decisions refined certain aspects of the reasoning, Uday laid the foundation for the modern judicial approach by rejecting the assumption that every broken promise constitutes a criminal offence.

2. Deelip Singh v. State of Bihar (2005)

The Issue Before the Supreme Court

Whether the accused’s promise was dishonest from the very beginning or whether the relationship later failed due to changing circumstances.

The Court’s Decision

The Supreme Court clarified that courts must distinguish between:

a promise honestly made but subsequently not performed; and
a promise that was never intended to be fulfilled.

The Court explained that the decisive question is the state of mind of the accused at the time the promise was made.

Legal Principle Established

This judgment strengthened the jurisprudence by recognising that:

dishonest intention at the inception is the essence of criminal liability;
subsequent events alone cannot retrospectively convert an honest promise into a false one; and
intention must ordinarily be inferred from the totality of the evidence rather than from a single circumstance.

This principle continues to be cited in later Supreme Court decisions.

3. Deepak Gulati v. State of Haryana (2013)

Among all the Supreme Court judgments, Deepak Gulati is one of the most influential because it explains how courts should analyse the factual circumstances of a relationship.

The Issue Before the Supreme Court

Whether prolonged consensual intimacy automatically establishes that consent was obtained through deception.

The Court’s Decision

The Supreme Court emphasised that every case depends upon its own facts.

The Court rejected any mechanical formula and held that judges must carefully examine:

the conduct of both parties;
the duration of the relationship;
the surrounding circumstances;
the communications between the parties; and
whether the accused genuinely intended to marry when the promise was made.

Legal Principle Established

The Court reiterated several important propositions:

every failed relationship is not a criminal offence;
courts must distinguish deception from genuine emotional relationships;
the prosecution must establish that the promise was false at its inception; and
intention cannot be inferred merely because the relationship ultimately ended.

This judgment remains one of the leading authorities frequently relied upon by High Courts while deciding bail applications, quashing petitions, and criminal trials.

4. Dr. Dhruvaram Murlidhar Sonar v. State of Maharashtra (2019)

This judgment consolidated the earlier decisions and removed much of the uncertainty that had developed in the lower courts.

The Issue Before the Supreme Court

How should courts distinguish between consensual relationships and relationships induced by deception?

The Court’s Decision

The Supreme Court reaffirmed that criminal liability cannot arise simply because a relationship failed.

Instead, the prosecution must establish that:

the promise was false from its inception; and
the accused never genuinely intended to marry.

The Court recognised that genuine relationships frequently end because of circumstances beyond the parties’ control.

Such situations may involve disappointment or emotional distress, but they do not necessarily amount to criminal deception.

Legal Principle Established

The judgment reaffirmed that:

a subsequent refusal to marry is not conclusive proof of initial dishonesty;
the accused’s intention at the time of making the promise remains the decisive consideration; and
courts must avoid evaluating earlier conduct solely through the lens of later events.

This decision has become one of the principal authorities cited across India.

A Common Theme Emerging from These Judgments

Although each of these cases involved different factual backgrounds, they collectively establish a consistent judicial approach.

The Supreme Court has repeatedly refused to adopt either of two extreme positions: The first extreme is to treat every broken promise as a criminal offence.

The second is to treat every consensual relationship as legally immune from criminal scrutiny.

Instead, the Court has adopted a balanced approach that focuses on evidence, intention, and causation.

This balance protects individuals from fraudulent conduct while ensuring that criminal law does not become a remedy for every failed relationship.

Key Takeaways

Uday introduced the distinction between a failed relationship and criminal deception.
Deelip Singh emphasised dishonest intention at the inception of the promise.
Deepak Gulati required courts to assess the entire factual matrix rather than relying on the eventual breakdown of the relationship.
Dr. Dhruvaram Murlidhar Sonar reaffirmed that a genuine promise which later fails does not automatically attract criminal liability.
Together, these judgments created the modern legal framework for analysing allegations of a false promise to marry.

Pramod Suryabhan Pawar: The Landmark Judgment That Settled the Law

Among the Supreme Court decisions on false promise to marry, Pramod Suryabhan Pawar v. State of Maharashtra(2019) occupies a special place. It did not create an entirely new legal principle; rather, it consolidated and clarified the principles emerging from earlier decisions such as Uday, Deelip Singh, Deepak Gulati, and Dhruvaram Murlidhar Sonar.

Today, this judgment is one of the most frequently cited authorities by High Courts across India while deciding petitions for quashing FIRs, anticipatory bail, regular bail, discharge, and criminal appeals.

The Issue Before the Supreme Court

The Supreme Court was required to determine: When does a promise to marry amount to a “false promise” capable of vitiating consent?

The Court recognised that relationships are often complex and cannot be analysed through rigid formulas. People may genuinely intend to marry when a relationship begins but later abandon that intention because of unforeseen developments.

Therefore, the Court held that the mere failure to marry cannot, by itself, establish criminal liability.

The Two-Part Judicial Test

One of the most significant contributions of Pramod Pawar is the formulation of a structured legal test.

The Supreme Court explained that for consent to be regarded as vitiated on account of a promise to marry, the prosecution must establish both of the following:

First Requirement: The Promise Must Be False at the Time It Was Made

The Court held that the promise must have been false from its inception. This means that, at the time the accused made the promise, he had no genuine intention of marrying.

If the intention to marry genuinely existed but was frustrated by later circumstances, the criminal law is ordinarily not attracted.

This requirement reflects the principle that criminal liability is founded upon deception, not upon the eventual failure of the relationship.

Second Requirement: The False Promise Must Have a Direct Nexus with Consent

The Court further clarified that it is not enough to prove that a false promise existed. The prosecution must also establish that the woman’s decision to engage in the sexual relationship was directly influenced by that promise.

In other words, the false promise must bear an immediate and proximate connection with the consent.

If the evidence indicates that the relationship was entered into voluntarily for multiple reasons independent of the alleged promise, the necessary legal nexus may be absent.

This aspect of the judgment is particularly important because it shifts the inquiry from the mere existence of a promise to its actual impact on the complainant’s decision.

Why Pramod Pawar Became the Leading Authority

The judgment is frequently cited because it brings together the principles developed in earlier cases into a coherent framework.

After this decision, courts generally analyse allegations by asking three central questions:

Was there a promise of marriage?
Was that promise false when it was made?
Did the promise directly induce the complainant’s consent?

These questions have become the starting point for judicial analysis in many subsequent cases.

How High Courts Have Applied These Principles

Since Pramod Pawar, High Courts have consistently relied upon the Supreme Court’s reasoning while dealing with a wide range of proceedings.

Although the factual circumstances differ from case to case, certain recurring themes can be identified.

1. High Courts Examine the Entire Course of the Relationship

Rather than focusing solely on the final refusal to marry, High Courts examine the entire relationship.

They frequently consider:

when the parties first met;
when the alleged promise was made;
how the relationship progressed;
whether families were informed;
whether marriage discussions actually took place;
whether engagement ceremonies or marriage preparations occurred; and
the conduct of both parties after disputes arose.

This chronological approach helps courts determine whether the promise appears to have been genuine or merely deceptive.

2. Digital Evidence Has Become Central

Modern false promise cases rarely depend only upon oral testimony.

High Courts increasingly examine:

WhatsApp conversations;
emails;
text messages;
call records;
photographs;
travel records;
hotel bookings;
financial transactions; and
social media communications.

Digital evidence often assists the court in understanding the intentions of the parties throughout the relationship.

However, courts also recognise that no single message or isolated conversation is decisive. Electronic evidence must be evaluated in the context of the relationship as a whole.

3. Duration of the Relationship Is Relevant but Not Conclusive

Many litigants mistakenly believe that a long relationship automatically proves either innocence or guilt. The judicial position is more nuanced. A prolonged relationship may support the inference that the parties were genuinely attempting to build a future together.

Equally, a long relationship does not by itself exclude the possibility that deception existed from the beginning.

Consequently, courts treat the duration of the relationship as one relevant circumstance, not as a determinative rule.

4. Subsequent Refusal to Marry Does Not Automatically Establish Criminal Intent

High Courts repeatedly emphasise that the refusal to marry at the end of the relationship is only one piece of evidence. The critical inquiry remains: What was the accused’s intention when the promise was originally made?

The prosecution cannot rely solely upon the eventual refusal to marry while ignoring the earlier history of the relationship.

The Significance of These Principles Under Section 69 BNS

Although Section 69 BNS introduces a specific statutory offence relating to sexual intercourse by employing deceitful means, including a false promise of marriage, the provision does not eliminate the need to determine whether the alleged promise was genuinely false.

Consequently, courts are likely to continue applying the principles developed by the Supreme Court while interpreting this new statutory framework.

In particular, the following questions remain central:

Was there deception?
Was the promise false from its inception?
Did the promise induce consent?
What evidence supports these allegations?

These judicial principles therefore continue to guide investigations, bail proceedings, quashing petitions, and criminal trials under the Bharatiya Nyaya Sanhita.

Practical Implications for Litigants

The Supreme Court’s jurisprudence has important practical consequences.

For the Complainant

A complaint should clearly explain:

when the promise was made;
how it influenced the decision to consent;
what conduct demonstrates that the promise was never genuine; and
what evidence supports these assertions.

A vague allegation that the accused later refused to marry may not, by itself, satisfy the legal requirements.

For the Accused

The defence generally focuses on demonstrating that:

the intention to marry genuinely existed;
the relationship developed voluntarily over time;
subsequent events prevented the marriage; or
the prosecution has failed to establish deception from the outset.

Each case ultimately depends upon its own evidence, chronology, and surrounding circumstances.

Key Takeaways

Pramod Suryabhan Pawar is the leading Supreme Court authority on false promise to marry.
The judgment established a two-part test: (i) the promise must be false when made, and (ii) it must directly induce the complainant’s consent.
High Courts apply these principles by examining the entire course of the relationship rather than only its eventual breakdown.
Digital evidence and chronology have become increasingly important in modern litigation.
These judicial principles continue to inform the interpretation and application of Section 69 BNS.

Recommended reading: Consent Under Misconception of Fact Explained

The Current Legal Position Under Section 69 BNS

The enactment of Section 69 of the Bharatiya Nyaya Sanhita, 2023 marks an important legislative development in Indian criminal law. Unlike the earlier legal framework, where allegations relating to a false promise to marry were primarily examined through judicial interpretation of the Indian Penal Code, Parliament has now created a specific offence dealing with sexual intercourse by employing deceitful means, including a false promise of marriage.

However, the introduction of Section 69 BNS does not mean that every allegation involving a failed relationship will automatically result in criminal liability.

The essential judicial questions remain substantially the same:

Was there a promise of marriage?
Was that promise false when it was made?
Did the accused genuinely intend to marry?
Did the alleged false promise directly influence the woman’s consent?
Is there reliable evidence supporting these allegations?

As High Courts continue to interpret Section 69 BNS, the principles developed by the Supreme Court in Uday, Deelip Singh, Deepak Gulati, Dhruvaram Murlidhar Sonar, and Pramod Suryabhan Pawar are likely to remain highly persuasive unless modified by future Supreme Court decisions or legislative amendments.

Common Misconceptions About False Promise to Marry Cases

Public perception often differs significantly from the legal position. Some common misconceptions deserve clarification.

Myth 1: Every Refusal to Marry Is a Criminal Offence

Reality: No.

The Supreme Court has repeatedly held that the refusal to marry, by itself, does not establish criminal liability. The decisive question is whether the promise was dishonest from the beginning.

Myth 2: A Long Relationship Automatically Proves Innocence

Reality: Not necessarily.

A long relationship may indicate that both parties genuinely intended to build a future together. However, duration alone neither proves nor disproves deception. Courts evaluate the entire factual matrix.

Myth 3: Pregnancy Automatically Proves a False Promise

Reality: No.

Pregnancy may be an important factual circumstance, but it does not, by itself, establish that the original promise was false. Courts still examine the accused’s intention when the promise was made.

Myth 4: WhatsApp Messages Alone Decide the Case

Reality: Electronic communications are important evidence, but courts do not decide cases based on isolated messages. Digital evidence is considered together with witness testimony, surrounding circumstances, chronology, and the conduct of both parties.

Related Guide: Police Investigation in Section 69 BNS Cases

Practical Guidance Under Section 69 BNS

For Complainants

A complainant should preserve all available evidence that may assist in establishing the chronology of the relationship, including communications, photographs, travel records, financial transactions, or any material demonstrating that the promise of marriage influenced the decision to consent.

The complaint should clearly explain:

when the promise was made;
how it affected the complainant’s decision;
why it is alleged that the promise was false from the outset; and
the evidence supporting these assertions.

For Accused Persons

An accused should avoid assuming that the mere existence of a consensual relationship is sufficient to defeat the allegations.

Instead, attention should be directed towards:

establishing the genuine nature of the relationship;
demonstrating sincere efforts towards marriage, where applicable;
explaining subsequent events that prevented the marriage; and
preserving electronic communications and other evidence relevant to the relationship.

Legal advice should be obtained at the earliest stage of the investigation.

For Investigating Officers

Investigating officers should avoid treating every failed relationship as a criminal offence.

The investigation should focus upon:

the chronology of events;
the circumstances in which the promise was made;
the conduct of both parties throughout the relationship;
digital and documentary evidence; and
whether there is material indicating dishonest intention at the inception.

A fair investigation protects both the complainant and the accused while ensuring that the statutory requirements are properly examined.

For Defence Lawyers and Prosecutors

The central issue is rarely whether the relationship existed.

The real controversy usually concerns:

intention;
causation;
credibility;
chronology; and
evidentiary consistency.

Successful prosecution or defence therefore depends less upon emotional allegations and more upon careful factual analysis supported by admissible evidence.

Related Guide: Can an FIR Under Section 69 BNS Be Quashed?

Frequently Asked Questions (FAQs)

1. Is every broken promise to marry a criminal offence?

No. Indian courts have consistently held that a mere failure to marry does not automatically constitute a criminal offence.

2. What is the most important legal question?

Whether the accused genuinely intended to marry when the promise was made.

3. Does Section 69 BNS criminalise every failed relationship?

No. Courts still examine whether the statutory ingredients are satisfied based on the evidence in each case.

4. What kind of evidence is important?

Courts commonly examine WhatsApp chats; emails; photographs; travel records; hotel bookings; financial transactions; witness statements; and the overall conduct of the parties. No single piece of evidence is conclusive.

5. Why is chronology so important?

Because intention cannot usually be proved directly. Courts infer intention from the sequence of events and the conduct of the parties throughout the relationship.

Key Takeaways

A false promise to marry is legally distinct from a mere breach of promise.
The Supreme Court has consistently held that the crucial inquiry is the accused’s intention at the time the promise was made.
A subsequent refusal to marry does not, by itself, establish criminal liability.
Courts evaluate the entire course of the relationship, not merely its final outcome.
Digital evidence, chronology, and surrounding circumstances often play a decisive role.
The judicial principles developed by the Supreme Court continue to provide important guidance for interpreting Section 69 BNS.

Conclusion

The expression “false promise to marry” is often used casually in public discourse, but Indian criminal law treats it with considerable precision.

The Supreme Court has carefully balanced two competing concerns. On one hand, the law must protect women from genuine deception where consent is obtained through a dishonest promise of marriage. On the other hand, it must ensure that criminal law is not invoked merely because a consensual relationship later breaks down.

This balance is reflected in a consistent judicial principle: The law punishes deception, not disappointment.

As litigation under Section 69 BNS continues to evolve, courts are expected to build upon the established jurisprudence developed under earlier Supreme Court decisions. For litigants, lawyers, and investigating agencies, understanding these principles is essential to appreciating the distinction between a failed relationship and a criminal offence.

This distinction is not merely academic—it lies at the heart of every investigation, bail application, trial, and appeal involving allegations of a false promise to marry.

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The information provided in this article is general in nature and should not be construed as legal advice. If you require further information or legal assistance, you may contact us at section69bns@gmail.com.