“Nefarious Practice”: Supreme Court Slams Use of Criminal Case By Woman to Extort Money in Marriage-Promise Dispute

The Supreme Court recently emphasised that criminal law should not be used as an instrument of undue pressure to facilitate extortion or illegal enrichment, stressing that courts must act to preserve the integrity of the criminal justice system against misuse of the process in matrimonial disputes.

A Bench of Justices J B Pardiwala and K Vinod Chandran deprecated the initiation of criminal proceedings on the pretext of marriage for extortion purposes and upheld the unenforceability of a settlement reached in such circumstances.

Court was dealing with a plea filed by a woman challenging the Punjab and Haryana High Court's December 2, 2025 judgment.

"We are of the opinion the high court's order is perfectly in order, especially considering the manner in which allegations are made of molestation and sexual intercourse on the promise of marriage, which are then later settled, by the sheer coercion exerted on such criminal proceedings being initiated and continued. However, we intend to slightly modify the directions issued," the Bench said.

The petitioner, a 31-year-old woman, had registered an FIR on January 12, 2024, alleging that while she was tending to her brother, who was admitted to a hospital, the respondent offered his assistance. She alleged that on that pretext, he became intimate with her and coerced her into sexual intercourse.

However, Court noted that even according to the petitioner, she had willingly complied, believing that the respondent would marry her, as he had promised.

She further alleged that the respondent's parents had met her and that a sort of ceremony had also been conducted, following which she was abandoned.

Subsequently, the parties arrived at a settlement under which the respondent agreed to pay her Rs 9,25,000. Of this amount, Rs 4,50,000 was paid.

The high court found that a prima facie perusal of the record revealed a mala fide case, particularly since the petitioner was a mature woman who was fully conscious of her acts and conduct.

The high court observed that by making allegations of sexual harassment on the pretext of marriage, the petitioner had set the criminal justice machinery in motion, which, according to the court, undermined the sanctity of the legal process.

It further observed that courts should not become instruments of undue pressure, leading to extortion from one party and illegal enrichment of another.

To preserve the integrity of the criminal justice system, the high court set aside the settlement and made it unenforceable with respect to the balance amount payable to the petitioner.

Agreeing with the high court, the Supreme Court said such "nefarious practices" that undermine the judicial system must be deprecated in the strongest terms.

" We are perfectly in agreement with the high court that such nefarious practices undermining the judicial system has to be deprecated in the strongest of terms. Only in the facts and circumstances of the case, we modify the order to the extent of deleting the penalty imposed on the petitioner; but cautioning her in the strongest of terms from indulging in such activities hereinafter," the Bench ordered.

The Supreme Court, however, deleted the penalty of Rs. 5,00,000 imposed on the petitioner by the high court, while cautioning her in the strongest terms against indulging in such activities in future.

As regards the settlement, the Bench confirmed the high court's order making it unenforceable against the respondent.

Case Title: Pooja Rani Vs State of Haryana & Anr

Bench: Justices J B Pardiwala and K Vinod Chandran

Date of Judgment: September 28, 2026