Jahanvi Agarwal
In a significant judgment addressing the misuse of law, the Madras High Court ruled on June 21, 2024, that a woman who knew the accused was married with a child cannot claim that her consent was obtained under false pretenses of marriage. Justice M. Dhandapani, highlighted the dual responsibility of courts to protect women from exploitation while ensuring laws are not misused against men.
Justice Dhandapani noted, “While dealing with such cases, courts have a two-fold duty – firstly, to see that women are not misused, and secondly, that the law is not misused against the male folk.” He emphasized that although courts should consider a woman’s testimony with empathy, they must also ensure innocent men are not unjustly persecuted.
The case involved a criminal appeal under Section 374(2) Cr.P.C. against a conviction and sentence from the Mahila Fast Track Court in Villupuram, which had sentenced the appellant Rahul Gandhi to 10 years of rigorous imprisonment and a fine of Rs. 25,000 for offenses under Sections 375 and 376 read with Sections 90 and 417 IPC. The High Court found that since the victim knew about the accused’s marital status before their sexual relationship, her consent could not have been based on a false promise of marriage.
Justice Dhandapani stated, “In cases of such nature, the duty cast on the court is two-fold, not only to see that women are not misused but equally, the law is not misused against the male folk as well.” He added that while women’s claims of sexual assault are often treated as credible, courts must carefully scrutinize evidence to avoid unjust persecution of men.
The High Court concluded that there was no evidence to suggest the victim’s consent was obtained through deception. It emphasized that when the victim was aware of the accused’s marital status, there could be no misconception about the promise of marriage. Consequently, the court quashed the conviction and acquitted Rahul Gandhi.
Justice Dhandapani’s judgment underscored, “The courts have to separate the grain from the chaff while analyzing the evidence placed before it so that just and proper justice is rendered to the innocent person.” This ruling highlights the delicate balance courts must maintain in cases involving allegations of sexual exploitation.
Case Name: Rahul Gandhi v. The State
Dairy Number: 548/2021
Bench: Justice M. Dhandapani