Kundali Mismatch’ No Excuse for Breaking Marriage Promise: Delhi High Court Ruling
In a society where traditional beliefs often intersect with modern legal frameworks, the Delhi High Court has delivered a definitive ruling on the legal consequences of backing out of a marriage promise. In the case of Jayant Vats v. State (NCT of Delhi) [BAIL APPLN. 422/2026], the court addressed whether a mismatch in horoscopes (Kundalis) can serve as a valid defense against allegations of obtaining sexual consent through a false promise of marriage.
Background of the Case
The matter arose from an FIR registered by a woman (the prosecutrix) who alleged that the accused, Jayant Vats, had been in a relationship with her since 2018. According to the complainant:
The accused repeatedly promised to marry her and established physical relations based on that assurance.
He introduced her to his family, exchanged rings, and treated her as his fiancée in social circles.
Later, the accused backed out of the marriage, citing that their 'Kundalis' (birth charts) did not match.
The victim further alleged that she had withdrawn a previous police complaint only after the accused and his family gave fresh assurances of marriage, which they ultimately failed to honor.
The Legal Dispute: Breach of Promise vs. False Promise
The primary legal question was whether this was a simple "breach of promise" (where a person genuinely intends to marry but cannot due to unforeseen circumstances) or a "false promise from inception" (where the intent to marry was never there, and the promise was used only to obtain sexual consent).
The prosecution argued that the conduct of the accused fell under Section 69 of the Bharatiya Nyaya Sanhita (BNS), which criminalizes sexual intercourse by "deceitful means" or a false promise of marriage.
Key Observations by the Delhi High Court
Justice Swarana Kanta Sharma, while dismissing the bail application of the accused, made several critical observations:
The "Threshold" Argument: The Court noted that if horoscope matching was of "determinative importance" to the accused and his family, it should have been verified at the threshold (the very beginning) of the relationship, before establishing physical intimacy.
Convenient Pretext: The Court observed that using a Kundali mismatch after years of intimacy and explicit promises (including WhatsApp messages stating they would marry the next day) appeared to be a "convenient pretext" to escape the obligation of marriage.
Application of BNS Section 69: The Court emphasized that the new legal framework under the BNS specifically targets instances where consent is obtained through deceit. The court found that the accused’s actions—repeatedly renewing the promise to have a previous complaint withdrawn—indicated a lack of bona fide intent.
No Shield for Deceit: The judgment clarified that traditional or cultural beliefs like astrology cannot be used as a legal "shield" to justify deceitful conduct or to validate a breach of trust after exploiting a person's emotions and body.
Conclusion
This judgment serves as a stern warning that the law will not overlook the exploitation of a person’s trust under the guise of traditional incompatibility. By holding that a Kundali mismatch is not a valid excuse to back out of a long-standing marriage promise after physical relations, the Delhi High Court has reinforced the protection of women against "deceitful consent."
The ruling highlights that while the law does not criminalize every broken relationship, it will intervene when a promise of marriage is used as a tool for deception.
Case Details:
Case Title: Jayant Vats v. State (NCT of Delhi)
Case No: BAIL APPLN. 422/2026
Date of Order: 17.02.2026
Presiding Judge: Hon’ble Justice Swarana Kanta Sharma
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