In a significant ruling on false-promise-of-marriage cases, the Allahabad High Court has discharged accused Saurabh Pal Singh of rape and related charges, holding that a long, continuous, and consensual physical relationship cannot be recast as rape after the relationship ends.
Justice Santosh Rai allowed two connected criminal appeals and set aside the orders of the Special Judge (SC/ST Act), Prayagraj, which had rejected the discharge application and framed charges, according to LiveLaw. The case is reported as Saurabh Pal Singh vs State of UP and others — 2026 LiveLaw (AB) 403.
Background: How We Got Here
An FIR was lodged in October 2020 by the informant, a Scheduled Caste woman pursuing a PhD at Allahabad University. She alleged that the accused developed a close relationship with her, promised to marry her, and on that false assurance established physical relations with her over a prolonged period, according to LiveLaw.
The case carried serious charges under multiple statutes. The accused faced prosecution before the Special Judge (SC/ST Act), Prayagraj, who rejected the discharge application and formally framed charges. Saurabh Pal Singh then challenged those orders before the High Court in two connected criminal appeals.
- The physical relationship reportedly dates back to 2014, per the informant’s own statement recorded under Section 161 CrPC before the police, as noted by the court according to LiveLaw.
- In her subsequent Section 164 CrPC statement before a Magistrate, the informant admitted there was no romantic relationship between the parties — describing them instead as friends or acquaintances — though physical relations had existed.
- A financial dispute involving Rs. 15,00,000 allegedly given for running a business also formed part of the complaint. The court observed the informant never initiated proceedings under Section 138 of the Negotiable Instruments Act despite alleged dishonour of high-value cheques, as reported by LiveLaw.
The Ruling — Key Findings
Justice Santosh Rai discharged the accused of all charges under Sections 376 (rape), 420 (cheating), 406 (criminal breach of trust), 504 (intentional insult), and 506 (criminal intimidation) of the IPC, as well as Section 3(2)(v) of the SC/ST (Prevention of Atrocities) Act, according to LiveLaw.
The court was direct on the financial dimension of the dispute, observing: “The record, on the contrary, indicates that the dispute is predominantly civil and financial in nature.” — Justice Santosh Rai, Allahabad High Court.
On the rape charge specifically, the court held: “The essential ingredients of Section 376 IPC… are not made out even on a prima facie appraisal of the material as it stands.”
The bench relied on three Supreme Court precedents to anchor its reasoning. These were Deepak Gulati v. State of Haryana (2013), Pramod Suryabhan Pawar v. State of Maharashtra (2019), and Yedla Srinivasa Rao v. State of AP (2006). Per those precedents, a false promise of marriage must be proven to have been false at the very time it was made and given in bad faith, as reported by LiveLaw.
The court also addressed the SC/ST Act charge separately. It held that an offence under the Act is not made out merely because the victim belongs to a Scheduled Caste. The prosecution must demonstrate that the offence was committed specifically on the ground of the victim’s caste identity, per LiveLaw.
Critically, the High Court found that the trial court had acted mechanically and without proper application of judicial mind in rejecting the discharge application and framing charges, according to LiveLaw.
Reactions & What’s Next
No formal reactions from counsel or the State of Uttar Pradesh were reported in the available sources at the time of publication. The matter is concluded at the High Court level, with the discharge order now in effect.
The ruling adds to a growing line of judicial precedents cautioning against the use of rape provisions to resolve what are, in substance, civil or financial disputes arising out of consensual adult relationships, as noted across coverage by Lawbeat and LawyerEnews.
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What charges did the Allahabad High Court discharge Saurabh Pal Singh of?
The court discharged him of Sections 376, 420, 406, 504, and 506 of the IPC, as well as Section 3(2)(v) of the SC/ST (Prevention of Atrocities) Act, according to LiveLaw.
Why did the Allahabad High Court hold that rape under Section 376 IPC was not made out?
The court found the physical relationship was long, continuous, and consensual — beginning as far back as 2014 per the informant’s own police statement. The informant’s Section 164 CrPC statement also described the parties as friends rather than in a romantic relationship. The court held there was no prima facie proof of a false promise of marriage made in bad faith from the outset, relying on Supreme Court precedents in Deepak Gulati (2013), Pramod Suryabhan Pawar (2019), and Yedla Srinivasa Rao (2006), per LiveLaw.
Why was the SC/ST Act charge set aside by the Allahabad High Court?
The court held that an offence under the SC/ST (Prevention of Atrocities) Act is not established merely because the victim belongs to a Scheduled Caste. The prosecution must show the offence was committed specifically because of the victim’s caste identity, which was not demonstrated here, according to LiveLaw.
What was the financial dispute involved in this case?
The informant’s complaint included an allegation that Rs. 15,00,000 was given for running a business. The court noted she never initiated proceedings under Section 138 of the Negotiable Instruments Act despite alleged dishonour of high-value cheques, reinforcing its finding that the dispute was predominantly civil and financial in nature, per LiveLaw.
Disclaimer
Disclaimer: This article is for general information only and does not constitute legal advice. Laws may change or vary by case — consult a qualified lawyer before acting. The Courtroom is not liable for any reliance on this content.
