News Citation : 2026 LN (HC) 177 | 2026:CGHC:10683

March 02, 2026 : The High Court of Chhattisgarh has set aside a 2005 conviction in a rape case, ruling that the relationship between the complainant and the accused was consensual and that the prosecution failed to prove its case beyond reasonable doubt.

In a judgment delivered on March 2, 2026, Justice Narendra Kumar Vyas allowed the criminal appeal filed by Leela Ram, who had been convicted by a sessions court in Ambikapur under Section 376 of the Indian Penal Code and sentenced to seven years’ rigorous imprisonment along with a fine of ₹5,000.

According to the prosecution, the complainant, a Class 12 student at the time, alleged that the accused had developed a relationship with her while they were living in the same rented accommodation in Dhaurpur. She claimed that on September 8, 2000, he established physical relations with her on the assurance of marriage and continued to do so until April 2003. An FIR was eventually registered in December 2003.

The trial court had relied on the complainant’s testimony and circumstances such as the accused allegedly applying vermilion on her forehead, treating it as evidence supporting her claim that he had promised marriage. On that basis, the court convicted him of rape.

Challenging the conviction, the defence argued that the complainant was 26 years old at the time of the alleged incident and fully aware of the consequences of a sexual relationship. It was also pointed out that there was a delay of nearly three years in lodging the FIR and that medical evidence did not support the allegation of rape.

The medical officer had stated that the complainant was habitual to sexual intercourse and could not give a definite opinion regarding recent sexual activity. The forensic report was negative.

The defence relied on Supreme Court rulings to contend that a consensual relationship that later fails to culminate in marriage does not automatically amount to rape.

After reviewing the evidence, the High Court found inconsistencies in the complainant’s statements and noted that she had lived with the accused for extended periods without raising objections or filing complaints. The court observed that even when she stayed at his house for two months, she did not approach the police.

The court also took note of the three-year delay in filing the FIR, holding that such delay, in the absence of convincing explanation and corroborative evidence, weakened the prosecution’s case.

Referring to precedents including Prakash Chand v. State of Himachal Pradesh and Biswajyoti Chatterjee v. State of West Bengal, the court reiterated that not every sexual relationship based on an assurance of marriage amounts to rape, particularly when the parties are adults and the relationship appears voluntary.

The judge concluded that the prosecution had failed to establish beyond reasonable doubt that the physical relationship was non-consensual or that the promise of marriage was false from the outset.

Setting aside the trial court’s order, the High Court acquitted the appellant of the charge under Section 376 IPC. Since he was already on bail during the pendency of the appeal, the court directed that his bail bond would remain in force for six months in accordance with statutory provisions.

Case Reference : CRA No. 768 of 2005, Leela Ram v. State of Chhattisgarh; Counsel for the Appellant: Mr. Rahul Mishra, Advocate; Counsel for the State: Mr. Manish Kashyap, Panel Lawyer.