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Supreme Court of India· 07 September 2026

Does a prosecution for a false promise of marriage require evidence that the accused had no intention, from the very beginning, of keeping the promise?

Kunal Rameshbhai Kalyani v. The State of Gujarat & Anr
2026 INSC 987
Coram: Justice J. B. Pardiwala · Justice K. Vinod Chandran
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Answer

A prosecution for a false promise of marriage requires evidence that the accused had no intention, from the very beginning, of keeping the promise.

Yes. There must be adequate evidence to show that at the relevant time, that is, at the initial stage itself, the accused had no intention whatsoever of keeping his promise to marry; a person having the best of intentions who is later unable to marry owing to unavoidable circumstances does not thereby commit deceitful conduct.

Headnote

Bharatiya Nyaya Sanhita, 2023 — s.69 — False promise of marriage — Quashing of FIR — Bharatiya Nyaya Sanhita, 2023 — s.69 — Intention from the very beginning — Held: A prosecution for a false promise of marriage requires evidence that the accused had no intention, from the very beginning, of keeping the promise. (¶3, 4) Bharatiya Nyaya Sanhita, 2023 — s.69 — Consensual relationship — No deceitful inducement — Held further: Where the complaint discloses a consensual relationship with no deceitful inducement, there is no reason to allow continuation of the proceedings; FIR quashed. (¶5, 7)

Headnote

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In the Court's own words
Paragraph 3The High Court while declining the prayer for quashing specifically referred to the judgment of this Court in Deepak Gulati v. State of Haryana[^1] of which paragraph 24 is extracted hereunder :
Acts & Sections
s.69 Bharatiya Nyaya Sanhita, 2023

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Also decided in this judgment
Does Section 69 of the Bharatiya Nyaya Sanhita, 2023 (BNS) require the promise to marry to have been made without any intention of fulfilling it?
Plain-language answer prepared by the LexStreak Editorial Desk — verify against the judgment. Source: Supreme Court of India. Corrections