Case commentary on: Uday v state of Karnataka

The case of Uday v. State of Karnataka is a landmark judgment by the Supreme Court of India that examines the legal contours of consent in the context of sexual relationships based on a promise of marriage. The Court addressed whether consent obtained under such a promise, when unfulfilled, could vitiate the act of sexual intercourse and constitute rape under Sections 375 and 90 of the Indian Penal Code. The judgment clarified that consent cannot be considered invalid merely due to a subsequent breach of promise unless it is proven that the promise was false and fraudulent from the outset. By acquitting the accused, the Court drew a critical distinction between a genuine relationship that fails, and one induced by deceit. Under the Bharatiya Nyaya Sanhita, 2023, this principle finds legislative expression in Section 69, which explicitly criminalizes sexual intercourse obtained through deceitful means, including a false promise of marriage made without intent to fulfill it. This development bridges the gap identified in earlier jurisprudence, ensuring accountability for deceptive conduct while preventing misuse of rape laws. The case continues to hold significant value in shaping judicial and legislative understanding of consent, deception, and sexual autonomy in Indian criminal law.