Behind the case of MCRC-22093-2026, AAM v. State of Madhya Pradesh, there is a deeply human story: two educated professionals, both managers in the same bank, who travelled from friendship and social-media conversations to intimacy, family meetings, and ultimately to a police complaint and criminal courtroom. It is a story of trust, hope, and hurt, and it now has a legal chapter. The Madhya Pradesh High Court, through Justice Himanshu Joshi, refused to quash an FIR filed under Section 69 of the Bharatiya Nyaya Sanhita (BNS) against the male bank manager. That provision criminalises sexual intercourse secured by deceitful means, including by making a promise of marriage without any real intention of fulfilling it. The woman, aged about 32, had accused him of repeatedly establishing physical relations with her on the assurance that he would marry her. The applicant asked the High Court to kill the criminal case at its threshold, arguing that the relationship was fully consensual and that no false promise was ever made. But the Court declined. It said that the allegations in the FIR, on their face, do disclose the ingredients of the offence, and that the true question—whether he genuinely intended to marry her or simply used the promise as a key to obtain her consent—is precisely the kind of dispute that must be resolved by trial, not by a quick reading of papers in the High Court’s extraordinary jurisdiction.
At the heart of the woman’s complaint is a timeline that reads like the slow crumbling of a dream. The two were acquainted through a common friend and stayed in touch through social media and phone calls. She said that from September 2022, the applicant repeatedly expressed his intention to marry her. On 23 January 2023, when she was posted at Gwalior, he visited her and established physical relations. She said she had insisted on marriage before consenting to intimacy, but he reassured her. On 1 February 2023, he even asked her mother to approach his family with a formal marriage proposal. Her mother went to his house, but his mother declined the proposal. The woman’s complaint then describes a pattern: despite that refusal, the applicant continued to assure her that he would convince his family and would eventually marry her. Trusting those assurances, she remained in the relationship. Physical relations happened again, she says, in Bhopal and during trips to places like Darjeeling. Then came a more painful turn: in 2025, after her mother suffered a paralytic stroke, the applicant told her that if she continued “behaving in that manner,” he would not marry her. On 23 October 2025, she alleged, he once again physically possessed her in his car near NH-30 in Mandla. In November 2025, he told her the news she had feared: his family had chosen another woman, and he would not marry her. When she tried to persuade him, he did not change his mind. She approached the police on 17 January 2026, after learning that he was going to marry someone else. An FIR was registered at the Mahila Police Station in Mandla under Section 69 BNS.
The man’s version, however, is quite different. Through his counsel, he told the Court that this complaint was a counterblast to his decision to move on with his life and marry another woman. He argued that both partners were mature, educated, and financially independent bank employees. They had a voluntary relationship for a considerable period. There was never a false promise of marriage, he insisted. According to him, matrimonial negotiations did genuinely take place between the two families and were initiated at his own request. He also claimed that he had honestly told her about his family circumstances and had made it clear that marriage would depend on resolving those circumstances and obtaining his family’s consent. He further said that eventually both of them mutually agreed to discontinue the relationship and go their separate ways. He emphasised that he had informed her about his proposed engagement to another woman and had even shared photographs and details with her. To support his case, he relied on a legal notice he sent on 10 January 2026, a complaint filed by his father on the same date, medical documents relating to his father, and statements recorded during the police investigation. These materials, he argued, showed that there had been genuine matrimonial negotiations and that there was no dishonest intention from the beginning. The State and the woman opposed the petition. Their counsel argued that the FIR was specific: the applicant had promised marriage, used that promise to obtain physical intimacy, and only after years of assurances had admitted that he would marry someone else. Whether his intention was dishonest, they said, could only be tested after evidence.
The legal principle at the centre of the case is as important as the facts. The High Court carefully explained that not every failure to marry after a sexual relationship is a crime. If a man promises marriage sincerely at the time, but later circumstances change, or his family refuses, or he genuinely changes his mind, the law will not automatically turn him into a criminal. A broken promise is not necessarily a false promise. To attract liability under Section 69 BNS, the promise must have been false from the very beginning; the person making it must have had no intention of fulfilling it at the moment it was made; and that false promise must have been directly connected to the woman’s consent to the sexual act. In other words, the consent must have been obtained by deception. The Court said, in plain terms: “A subsequent refusal or inability to marry, by itself, is not sufficient.” This is an important safeguard. It prevents criminal law from being used to punish ordinary relationship failures or broken engagements. It also protects women who have been deceived, because it recognises that consent given on the basis of a lie—especially a lie about marriage—is not true consent at all. The problem is that intent is invisible. It lives inside a person’s mind. So how does a court know whether a promise was false? It must look at conduct, communication, timing, family involvement, and all surrounding facts. And that is why the High Court in this case refused to dismiss the proceedings at the stage of quashing.
Applying that principle, the Court found that the woman’s complaint was not vague. It gave a specific background, a specific date on which the physical relationship allegedly began, repeated assurances, and later incidents with dates and places. The Court noted that the prosecution case could not be described as lacking material allegations. Whether those allegations were true, and whether the applicant’s mental state was dishonest when he made the promises, were matters that could only be assessed by appreciating the whole evidence at trial. The High Court also addressed the applicant’s reliance on the matrimonial negotiations, WhatsApp conversations, the legal notice, his subsequent engagement, and the statements recorded during investigation. These materials, the Court accepted, may be useful for his defence. But their evidentiary value cannot be conclusively decided in an application under Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), which is the successor provision to the old Section 482 of the Code of Criminal Procedure. In exercising its inherent powers, the High Court does not conduct a mini-trial. It does not weigh the competing versions like a trial judge would. It only asks whether the allegations and the material collected so far disclose a prima facie case. On that standard, the Court found no ground to intervene.
The Court also rejected two other arguments made by the applicant. First, the fact that the woman was educated and financially independent did not, by itself, prove that she could not have been deceived. A woman can be a successful bank manager and still be vulnerable to emotional manipulation and false assurances of marriage. Financial independence does not make a person immune to trust, love, or betrayal. Second, the fact that matrimonial negotiations had taken place between the families did not conclusively prove the absence of dishonesty. A man may go through the motions of family talks while never truly intending to marry, or he may genuinely try but later abandon the attempt. All of this needed evidence. The applicant also pointed to the timing: his legal notice was dated 10 January 2026, his engagement on 11 January 2026, and the FIR on 17 January 2026. For him, this showed that the woman had filed the case out of spite after losing him. The Court, however, said that this sequence did not, by itself, make the FIR malicious. The legal notice and the father’s complaint could be relevant, but their proximity in time to the FIR was not enough to terminate a criminal prosecution at the threshold. Since the investigation had already ended in a charge sheet, and Sessions Trial No. 24/2026 was pending before the Third Sessions Judge, Mandla, the Court looked at whether the material collected disclosed a prima facie case. It did.
In the end, the Madhya Pradesh High Court dismissed the application to quash the FIR and the consequential criminal proceedings. That means the trial will go ahead. But it would be wrong to read this decision as a judgment of guilt. The applicant remains entitled to prove his innocence. He can show during the trial that the relationship was genuinely consensual, that he never made a false promise, that the family negotiations were real, and that his intentions throughout were honest. The Court has simply refused to shut the door before the woman has had a chance to present her side in full. For her, this is a victory of sorts: she will now have her day in court. For him, it is the beginning of a difficult legal battle, with reputation, career, and personal life all under strain. Beneath the legal terminology and procedural technicalities, this case is ultimately about something profoundly human. Two people who once shared jokes, dreams, and intimacy are now separated by an FIR, a trial, and the irreversible weight of what happened between them. The law’s task is not to decide who is more sympathetic, but to determine whether a promise was ever real. That question, as the High Court rightly observed, cannot be answered on paper. It must be answered in the presence of witnesses, in the light of evidence, and in the open court, where truth has the chance to emerge. Until then, the matter remains alive, and the relationship that once seemed so full of love has become a legal reminder of how easily trust can turn into accusation.