The Supreme Court quashed criminal proceedings under Section 69 of the Bharatiya Nyaya Sanhita concerning an alleged promise to marry. In Kunal Rameshbhai Kalyani v. State of Gujarat & Anr., the complainant alleged that the accused established a physical relationship with her after expressing an intention to marry but later refused marriage because of opposition from his mother. The Court examined whether the allegations disclosed the deceitful conduct contemplated by Section 69 BNS. It reiterated that a promise to marry becomes criminally relevant only where it is established that the promise was false from the very beginning and was made without any intention of being fulfilled. A subsequent failure to marry does not, by itself, establish that the original promise was fraudulent. The Court found that the FIR described a relationship that developed through mutual interaction and that the accused's later refusal was attributed to his mother's objection. The allegations therefore did not establish the required initial fraudulent intent. The Supreme Court consequently allowed the appeal and quashed the FIR and proceedings.