The biggest mistake people make about Section 69 BNS is assuming every case is the same.

The same allegation.

Completely different judicial responses.

That is the reality of Section 69 BNS litigation.

Recent reports reveal fresh criminal cases involving allegations of sexual exploitation on the false promise of marriage, including one against a government employee in Telangana and another concerning a professional cricketer following directions of the Calcutta High Court.

At the same time, two High Courts have highlighted an equally important legal principle.

The Uttarakhand High Court held that a consensual relationship initiated through Tinder, which later failed, could not by itself amount to rape in the absence of deception from the very beginning.

The Delhi High Court, while examining another matter, also raised prima facie doubts where allegations of false promises of marriage against two different men were said to overlap during the same period, emphasising that such factual issues require careful judicial scrutiny.

These developments underline an important litigation reality.

Section 69 BNS cases are rarely decided by the allegation alone.

They are decided by the surrounding facts.

Courts increasingly examine the chronology of the relationship, the conduct of both parties, digital communications, and whether the alleged promise was genuinely dishonest when it was made.

That is why two FIRs carrying similar allegations can travel in completely different legal directions.

The legal principle remains unchanged.

Section 69 BNS criminalises deception, not every relationship that ends without marriage.

Because in relationship-driven criminal litigation, the decisive question is rarely whether a promise was broken.

It is whether that promise was false from its inception.

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