LAXMINARAYAN & ANR. V. SUMITRA BAI

CASE: LAXMINARAYAN & ANR. V. SUMITRA BAI[1]

DATE OF JUDGEMENT – 29th March 1994

PETITIONERS – Laxminarayan and others (Defendants)

RESPONDENT – Sumitra Bai (Original Plaintiff)

BENCH – Single Bench

HON’BLE JUDGES – M.V. Tamasker, J

OFFICIAL CITATION – AIR 1995 MP 86

IMPORTANT SECTIONS/ARTICLES – Section 73 and 65 Indian Contract Act, 1872[3], and, Principles from English law & Hindu contexts

FACTS OF THE CASE

Laxminarayan was a son of one Chandanlal. Chandanlal and Mehtar are residents of the same village. Laxminarayan was a student and living at Balaghat. Chandanlal came to the house of Mehtar and proposed the marriage between his son Laxminarayan with Sumitra Bai, daughter of Mehtar aged about 16 years. After the said proposal made to Mehtar, Laxminarayan started visiting the house of Mehtar and persuaded Sumitra Bai to co-habit with him as they were going to be married soon. A suit was filed on the allegation that on 15-4-1986 Mangni took place and the marriage ceremony was to be performed in April, 1987. After the engagement between the couple, the parties had sexual intercourse as a result of which the Sumitra Bai became pregnant. When the husband became aware of the situation, he refused to marry her. The defendants denied that there was any such Mangni or contract to marry and denied that there was any cohabitation by Laxminarayan with Sumitra Bai. Sumitra Bai delivered a still born child. A panchayat was held, a report was also lodged in the police station. In the Panchayat, the Sarpanch Chandanlal was present Sumitra Bai made allegations that she had become pregnant through Laxminarayan. Sumitra Bai believed that she was having a fair relation with Laxminarayan because of the Mangni whereas Laxminarayan had ulterior motive at the back of his mind and was merely taking advantage of the fact and ravishing the poor lady, who became pregnant before marriage, which does cast a stigma. It also makes the life of the workman miserable and it is also difficult to get married to a suitable match.

ISSUES INVOLVED

• Is a promise to marry, especially one made informally or verbally, legally enforceable under Indian contract law?
• Does breaking off an engagement or promise to marry amount to actionable civil wrong if it causes harm?
• Whether a woman can claim damages in tort and contract for breach of a promise to marry, where such promise led to sexual relations under false pretenses?

CONTENTION

Arguments from Original Petitioner’s side

The plaintiff, Sumitra Bai, contended that the defendant, Laxminarayan, had made a clear and deliberate promise to marry her, which was not merely verbal but had culminated in a formal engagement (Mangni), acknowledged by both families. Relying on this promise, she entered into a sexual relationship with him in good faith, believing that marriage would follow. She alleged that the promise to marry was made with fraudulent intent, as the defendant never intended to fulfil it and merely used it to exploit her trust and vulnerability. As a result, she suffered severe emotional trauma, reputational damage, and social ostracism especially within a conservative societal context that stigmatizes premarital intimacy for women. When the defendant later refused to marry her, she filed a civil suit seeking damages under tort law and Section 73 of the Indian Contract Act, arguing that the breach of promise caused her substantial non-pecuniary harm. She further maintained that the civil claim was maintainable despite the defendant’s earlier acquittal in a related criminal case, since the civil standard of proof preponderance of probabilities had been met, and the injury she suffered was genuine and compensable.

Arguments from Original Defendant’s side

In response, the defendants, Laxminarayan and another, denied the existence of any legally enforceable contract to marry. They contended that although there may have been a social understanding or engagement, it lacked the essential elements of a binding contract under Indian law, particularly the intention to create legal obligations. They asserted that the relationship between the parties was consensual and voluntary, and that the plaintiff was not induced into sexual relations through deception. Emphasizing their acquittal in the criminal trial, the defendants argued that the civil suit was an indirect attempt to reopen issues already adjudicated in their favour, and that the claims of harm were exaggerated and unsubstantiated. They further contended that the amount of damages awarded by the trial court was speculative, lacked any concrete basis, and was more a reflection of social sentiment than legal principle. Accordingly, they sought to have the decree set aside, arguing that no legal wrong had been committed which would justify the imposition of civil liability.

JUDGEMENT

The Madhya Pradesh High Court upheld the trial court’s decision and held that a deliberate breach of a promise to marry, especially after inducing the woman into a sexual relationship under false pretence, constituted a civil wrong warranting compensation. The Court acknowledged that while a promise to marry is not automatically a legally binding contract, in this case, there was sufficient evidence to show that the promise was definite, serious, and relied upon by the plaintiff to her detriment. The defendant’s engagement to the plaintiff and his conduct in establishing physical intimacy based on that promise demonstrated a clear misuse of trust and fraudulent inducement. Even though the defendant had been acquitted in the related criminal proceedings for rape, the Court emphasized that civil liability operates under a different standard of proof preponderance of probabilities which had been satisfied in this case. The Court further held that the emotional trauma, loss of reputation, and social stigma suffered by the plaintiff particularly within a conservative social milieu were real and compensable injuries, even in the absence of direct financial loss. Accordingly, the Court found that the plaintiff was entitled to damages under Section 73 of the Indian Contract Act, 1872, and also on principles of tort law for deceit and injury to dignity. The appeal was dismissed, and the award of ₹30,000 as damages was upheld.

PRINCIPLE INVOLVED

A contract is an agreement between two or more parties, wherein they abide by all the terms and conditions agreed upon; between them, orally or in writing. The terms and conditions are followed by the parties in the manner they are agreed and if any of the parties fail to comply with the conditions decided upon, then the defaulter party may be entitled to pay the compensations in the manner as may be described in the contract or decided by the parties prior to the contract. However, in the event the default is severe according to the nature of the contract, then the defaulting party may be ordered to pay the money as this mechanism allows the injured party to recover compensation for the loss suffered by them due to the breach of contract, from the party who causes the breach. These monetary payments are known as “Damages”.

The landmark case of Laxminarayan vs Sumitra Bai falls under the category of Exemplary Damages. Such damages are typically awarded in two specific situations –

• In cases involving a breach of promise to marry, as it often causes significant emotional distress and injury to the feelings of the aggrieved party.
• When a bank wrongfully dishonors a cheque, leading to reputational damage and loss of credibility to the account holder.

In the first category, which is relevant here, courts may award exemplary damages for emotional injury, humiliation, and the disappointment resulting from a broken promise to marry. In Laxminarayan vs Sumitra Bai, following their engagement, the couple engaged in sexual relations which led to the woman’s pregnancy. Upon learning of her condition, the man refused to marry her. The Hon’ble Madhya Pradesh High Court held that the woman was entitled to damages, considering not just the broken promise but also the severe social stigma and emotional trauma she suffered, which adversely affected her prospects of future marriage. The Court further clarified that the man’s acquittal in criminal proceedings did not absolve him of civil liability under tort law, and therefore, exemplary damages were rightly awarded. The principle primarily pertains to breaches of a promise to marry. However, when such a promise is misused to deceive a girl into a physical relationship, culminating in pregnancy, the nature and extent of damages must be assessed on multiple grounds, including physical suffering, emotional humiliation, diminished prospects of future marriage, and the accompanying social stigma.

CONCLUSION

 The decision of the Madhya Pradesh High Court in Laxminarayan & Anr. v. Sumitra Bai stands as a crucial juncture in Indian tort jurisprudence, particularly concerning the liability arising from personal promises and their breach in intimate relationships. In this case, the plaintiff, Sumitra Bai, was lured into a physical and emotional relationship on the assurance of marriage. The promise, however, turned out to be hollow, leaving her socially stigmatized, emotionally devastated, and legally wronged. The Court’s verdict, awarding damages for breach of promise to marry, is notable not merely for its outcome but for its recognition of emotional harm and social defamation as actionable injuries. It bridges a critical gap between private betrayal and public accountability, making it clear that the law does not turn a blind eye when trust is weaponized under the pretense of affection. Importantly, this case highlights the law’s evolving sensitivity to gendered power dynamics. It implicitly acknowledges that in a patriarchal society, a broken promise of marriage is not a private disappointment but a public injury especially for women, whose honour and reputation are often unfairly tied to notions of chastity and social status. By affirming the plaintiff’s right to claim compensation, the Court reinforced that emotional exploitation cloaked as romantic intent is neither trivial nor immune from judicial scrutiny. The ruling subtly expands the contours of tort law in India, encouraging future courts to view personal relationships not merely as emotional domains, but as spheres where duty, trust, and legal responsibility intersect. In essence, Laxminarayan v. Sumitra Bai is more than a case about a broken promise, it is a reflection of how the judiciary can become an agent of social redress and gender-sensitive justice, even within the often ambiguous terrain of personal relationships.

Reference(S):

[1] Laxminarayan & Anr. vs. Sumitra Bai AIR 1995 MP 86

[2] Final Year Law Student, New Law College

[3] Indian Contract Act 1872, ss 65, 73