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org © 2021 IJCRT | Volume 9, Issue 8 August 2021 | ISSN: 2320-2882

LIVE-IN – RELATIONSHIP: A STUDY ON

LEGAL ACTIONS

Ms. Anupama Yadav1, Dr. Anand kumar2

Research scholar, BPSMV1, Assistant professor, BPSMV2

Abstract: With the advancement of modernization, many foreign cultural trends have been incorporated into
India's traditional culture. The live-in relationship is one of these foreign cultures. A guy lives with a woman
under the same roof without being married in a live-in relationship. Live-in relationships are becoming more
common in India's metro areas, such as Mumbai, Delhi, and Bengaluru. Live-in partnerships are quite rare in
India's small towns. Most Indian families are very conservative and do not approve of live-in relationships.
Furthermore, a live-in relationship has no legal meaning. The majority of Indian families are opposed to this
kind of relationship. This study examines the official status of live-in relationships in India.

Keywords: Live-in relationship, Marriage, Institution, Law

1. INTRODUCTION

India is quickly opening its doors to Western concepts and lifestyles, and one of the significant of them is the
notion of live viewing someone. In legal words, a man's relationship with a woman is genuine if it is founded
on a valid marriage, and it is illegitimate if it is not founded on Marriage Laws. A live-in relationship is a
situation where two unmarried partner cohabitates for an extended period of time in what seems to be marriage. 1

The live-in relationship form is a defining characteristic and way of life for partners, mainly in urban areas. In
any event, the meaning and extent of a live-in relationship are very vague; there is no specific law on the issue
in India, and the rules are based on court judgments that vary from case to case. A woman's privilege in such a
relationship is likewise unclear; nevertheless, the Court has stepped in to recognize their rights. Even though
worldwide laws regulating live-in relationships are unclear, they are a frequent cause of inaccessibility and
delay in identifying such ties across nations. In the Indian context, it is critical to examine such a connection in

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the form of additional legislation that defines the scope of such a relationship and the parties' rights and
responsibilities.2

1.1 Meaning of live –In- Relationship

Live-in relation i.e. cohabitation is an arrangement whereby two people decide to live together on a long-term
or permanent basis in an emotionally and/or sexually intimate relationship. Typically, the phrase refers to
unmarried partners.3

Cohabitation is now a common occurrence in Western countries. Persons cohabit for a variety of motives. These
may comprise a desire to ascertain compatibility or financial security prior to marriage. It may be because they
cannot marry officially, because they're from the same gender; 4 for example, some multicultural or
interreligious marriages are illegal or prohibited. Other causes include premarital cohabitation to avoid divorce,
polygamists or polyamorists evading the law in order to evade the high amount paid for income taxes by some
two-earner married couples in the US, affects pension payments adversely (for the elderly), logical hostility to
the concept of marriage, and a desire to perceive little difference. Cohabitation is an option for individuals who
believe their relationships are personal and private and should be unregulated by governmental, patriarchal
institutions, or religious.

1.2 A live-in relationship is not an offence

In different judgments, the Apex Court has said that if a male and a female live together for a lengthy period
and have children, the courts would presume they are married. The same laws would apply to them and their
relationship. The Allahabad High Court acknowledged the idea of a live-in relationship in Payal Sharma vs.
Nari Niketan,4 where the Bench of Justice M. Katju and Justice R.B. Misra remarked, "In our view, unmarried
men and women may live together." Society may find this unethical, but it is legal. Law and morality are
different concepts." After that, the Supreme Court decided in S. Khushboo v. Kanniammal & Anr5 that a live-in
relationship between two individuals who are not legally married is not illegal. There was also no legislation
banning live-in relationships or premarital sex.

Life and personal liberty are protected as basic rights under Article 21 of the Indian Constitution. In Ramdev
Food Products (P) Ltd. v. Arvindbhai Rambhai Patel 6, the Court observed that two individuals in a live-in
relationship who are not legally married are not criminals. As a result, live-in relationships are permitted in
India.

1.3 Essential Factors to mark live-in relationship legal:

A “relationship in the nature of marriage” under the Protection of Women from Domestic Violence Act, 2005
must consent to some fundamental standards, which the Supreme Court stated in D Patchaiammal v. D
Velusamy7 and Indra Sarma v. V.K.V.Sarma8 case. Women in such relationships need to fulfil specific criteria
that will be beneficial under the Protection of Women from Domestic Violence Act, 2005, such as:
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I. Age:

Couples engaged must be of marriageable age, i.e., the couple should be significant according to Indian law. In
Payal Katara vs. Superintendent Nari Niketan Kandri Vihar Agra and Ors,9 the Allahabad High Court governed
that "a lady of 21 years, have the freedom to go anywhere and any man and woman, even if they are unmarried,
may live together if they want". Although in a recent judgment of Nandakumar vs. The State of Kerala9, the
Kerala High Court held that an adult couple could be in a live-in relationship even if they not attained the
corresponding legal ages for marriage. The man in this case was below 21, the legal age of marriage for men.

II. A significant period:

The declaration “at any point of time” is mentioned under section 2(f) PWDA, which means a significant or
relevant period to continue and maintain a relationship. Although depending upon the factual situation, it varies
from case to instance.

The relationship should not be taken for granted. There must be some sincerity and seriousness towards the
relationship to prove it legal. A week or a one-night stand can't be considered a domestic relationship. If the
live-in relationship is maintained over an extended period, it can't be described as a "walk-in and walk-out"
relationship. An assumption of marriage between the parties is stated in the Madan Mohan Singh v. Rajni Kant10.
This approach demonstrates the Court's preference for considering lengthy period living relationships as
marriages instead of a novel notion known as a live-in relationship.

The Supreme Court recognized a live-in relationship for the first time. It upheld the legal legitimacy of a couple's
fifty-year live-in relationship in Badri Prasad v. Deputy Director of Consolidation. Justice Krishna Iyer said that
when couples have lived with each other as husband and wife for a lengthy period, a strong assumption in favour
of marriage exists. Although the belief is rebuttable, whoever attempts to strip the relationship of its legal basis
has a high burden (Anuja Agrawal, 2012) 11.

III. The couple must have voluntarily cohabited:

Independent decision of the couple with a common intention to cohabit is an essential criterion of a live-in
relationship. It includes supporting each other, sharing their respective roles and responsibilities, financial
arrangements, socialization in public and so on to prove the loyalty and endurance of their relationship
(Auroshree, 2019).

Suppose a man uses his 'keep' primarily for sexual purposes or perhaps as a maid/slave and financially supports
her. In that case, this is not considered a marital or equal marriage relationship.

1.4 Issues and challenges of live-in relationship

Although the live-in relationship is lawful and numerous judgments favor it, many matters need a pivotal
discourse. Several of the more complex grey areas that remain unresolved amicably are described below:
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I. Societal and moral acceptance:
Though a live-in relationship is legal, it is still taboo in Indian society and morally and ethically wrong.
Indian culture is sceptical about live-in relationships; therefore, couples usually face multifold problems
like rejection from family, a problem in getting home for rent, refusal by society, negativity at the
workplace, etc.
II. Official documents
In India, for all official documents, there is still no column for a live-in relationship. The couple faces
problems in having joint accounts, nominees name, insurance, visas, etc.
III. Cultural issues
India is known for its diverse culture and religion. The impact of globalization on human relations in
our country has been unprecedented. The formally dominant family ties and values are witnessing
rampant changes. Every religion has its perspective towards a live-in relationship. Anti-religion marriage
remains a complicated subject that is permitted exclusively under the 1955 Special Marriage Act. A live-
in relationship is advancement, and Hinduism and Islam refuse the concept, although Christianity
somehow accepts it. In India, beliefs, customs, usages, and culture significantly impact people's mindsets
(Avantika Sarkar 2015)12. Subsequently, acceptance of new norms depends upon the prominence of their
belief rather than any law. The emphasis must be given to address the complications of anti-religion
live-in relationships, which is still a sensitive issue.

IV. LGBT couple

Commonly, society is indifferent towards providing reimbursements to the LGBT community and is
disinclined to admit their relationship. In fact in any laws and judgments of live-in relationship provision
or discussion about LGBT couple is lacking. The Supreme Court struck down Section 377 of the Indian
Penal Code 1861, decriminalizing consensual same-sex intercourse; nevertheless, India does not
recognize same-sex marriage or live-in partnerships. Regardless of such liberal interpretations by the
Honorable Courts in the recent past, the Indian framework still lacks any form of marriage law for the
LGBT population.
V. Property rights related to anti-religion and the LGBT community
The primary issue with live-in couples is succession and property rights. Only Hindu law now provides
property rights on children born out of a live-in relationship, and only on self-acquired property, not on
family property. Muslim law has its own system for property allocation, and it has made no attempt to
start any debates on time. There is no protection for the LGBT community, nor are there any provisions
regarding property rights. It is illegal for an LGBT couple to give or leave property to their livein partner.
Without properly resolving such upcoming issues and codifying relevant laws, there may be room for
fraud, cheating and it may give rise to criminal fights in families over property issues 13.
VI. Gender biased

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The 2005 Protection of Women from Domestic Violence Act recognises a woman as a wife if she has
shared an extended length of time with a man. Several conditions, including maintenance and property,
are also in her favour. Regrettably, it makes no provision for males or LGBT couples. Men are often
prosecuted for sexual assault and taking advantage of a woman by making a fake marriage vow. It may
be contradictory; there is no provision for men to be strengthened in such a case. Likewise, no protection
exists for the sexual abuse of a same-sex spouse. These delicate problems must be addressed
appropriately via the codification of specific laws governing live-in relationships.

2. OBJECTIVE OF RESEARCH

a. To define the concept of a Live-in –Relationship.

b. To Study the legal status of live-in relationships in India.

3. RESEARCH METHODOLOGY

The investigation was based on the doctrinal research method. The numerous laws cases, panel reports, and
preparations under numerous enactments related to living seeing somebody in India and the modern globe are
integrated as tools for achieving this investigation cum theory composing. As a result, the investigation activity
has incorporated clarifying and experimental approach in the creation and composition of the proposal.
Furthermore, the final result and suggestions are appraised using diagnostic and fundamental methods to
highlight inadequacies and errors in the legal framework. A comprehensive report will be written based on the
determinations, websites, diaries, articles, and books.

Sources

The doctrinal research approach was used in this study. This study has made use of primary, secondary, and
tertiary sources of information. The primary source of information used includes law, guidelines, notice, rules,
and board of trustees' report. Books, word references, reference books, journals, and papers are examples of
optional sources of knowledge. The sites are included in the tertiary sources.

4. LEGAL STATUS OF LIVE-IN RELATIONSHIP IN INDIA

In Lata Singh v. State of Uttar Pradesh,14 the Supreme Court governed that live-in relationships are allowed
between not married individuals of straight sex who are of legal age. When Lata Singh's brothers objected to
her marriage, they said she was psychologically ill. When doctors evaluated her, however, this was shown to be
inaccurate. A long-term live-in relationship can't be named a "walk in and walk out" relationship; marriage must
have a presumption.

In Gokal Chand v. Parvin Kumari,15 the Court informed the pair that their legitimacy would be questioned if
there was rebuttable proof that they were living together. These judgments aided in the legitimization of
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marriages that had been questioned owing to the existence of a long-term live-in relationship. On the other hand,
the courts didn't distinguish between live-in relationships and marriage formation, suggesting that the belief in
marriage was necessary.

In SPS. Balasubramanyam v. Suruttayan,16 the Supreme Court ruled that long-term cohabitation by a man and
woman in the same home, they believe they stay as spouse and wife under Section 114 of the Indian Evidence
Act, their children are not unlawful. This decision indicated that long-term live-in partnerships are legally
regarded the same as marriages. As this is still a matter of dispute, the courts may define live-in relationship to
entail "living together as husband and wife" in order to eradicate individuals who form a live-in relationship
"by choice" with no aim of marriage.

In Yamunabai Anantrao Adhav vs. Anantrao Shivram Adhav,17 the Supreme Court held that a man cannot marry
more than one woman. The “second wife” has no legal right to support under Section 125 of the Code of
Criminal Procedure, 1973, although she is unaware that he is already married. Even though their marriage had
been annulled, the Court refused to recognize that they had lived together. Even though he had neglected to
disclose his prior marriage, the guy was permitted to take advantage of it.

"Due to circumstance" the Supreme Court decided, a woman in a live-in relationship was denied any rights.18
The Allahabad High Court held in Malti v. State of Uttar Pradesh,20 that a woman who lives with a man cannot
be considered his "wife". The woman was the man's chef, lived with him, and was intimately connected. It was
also decided that "wife" should not be interpreted as including a live-in partner's support rights as defined in
Section 125 of the Code of Criminal Procedure, 1973. In Savitaben Somabhai Bhatiya v. the State of Gujarat21,
the Supreme Court went even farther, saying that the fact that the appellant was treated as the respondent's wife
was "really irrelevant since it is the legislature's purpose that is significant, not the party's attitude." When it
comes to using the estoppels theory to circumvent Section 125 of the Code of Criminal Procedure, 1973, even
the appellant's claim that she was unaware of the respondent's previous marriage is "of no use.". Consequently,
given Section 125's present criteria, it is impossible to avoid the end that the term "wife" exclusively denotes
the "lawfully wedded wife." As a consequence, rather than the second wife, the child got maintenance. Law
says a second wife whose marriage has been ruled null and void because the prior marriage has been continued
is an unlawfully wedded wife and thus is not permissible to support under this clause.

5. HOW LEGISLATION IS DEALING WITH LIVE-IN RELATIONSHIP

Live-in relationships are completely unrestricted in India. In the eyes of the law, a void marriage is not a
marriage. The connection that exists in a void and voidable marriage is contrasted to the bond that exists in a
live-in relationship in the conventional sense. As can be seen, several statutes address various rights resulting
from live-in relationships. It makes no difference whether the woman or the children born of that relationship
have the privilege. The different laws are as follows:

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I. Indian Evidence Act
Under Section 114 of the Indian Evidence Act, when a man and a woman have continued to live with each
other for a long time as a couple the Court can believe in any reality that it believes is likely to have
occurred, with respect to the natural course of events and human action in their relationship to the realities,
circumstances, and situation. There is a strong religious emphasis on marriage.
II. Domestic Violence Act 2005
Two people live or have lived with each other in a shared home at some point, whether they are connected
by consanguinity, marriage or by another relationship like marriage or adoption or relatives who live as a
joint family as mentioned in Section 2(f) of the Domestic Violence Act 2005.
When the Court broadly interprets the expression "relationship in the nature of marriage," which is
incorporated in the description of domestic relationship, it presumes that live-in relationships are included
within the field of the expression because the terms "nature of marriage" and "live in a relationship" are
synonymous in the Indian judiciary.
This Act has been extensively lauded as the primary legal mechanism for identifying the presence of adult
heterosexual relationships that are not marital. The Act defines an "aggrieved person" as "any woman who
is or was in a local relationship with the respondent and claims to have been subjected to physical or
psychological abuse at home."
III. Criminal Procedure Code 1973
According to the Justice Malimath Committee and the Indian Law Commission, a female who has been in
a live-in relationship for a long term should be entitled to the spouse's legal privileges. Similarly, the
Committee proposed modifying Section 125 of the Criminal Procedure Code's definition of "wife." The
word "wife" has been redefined to comprise women who had previously been in a live-in relationship.
Now, against her will, his accomplice has abandoned her in order to provide the position of wife to a woman
in a live-in relationship. And as soon as she is granted status, she is given the right of maintenance under
section 125 of the CrPC, 1973. However, there is a dispute that even if the wife's position is offered to
women in a live-in relationship, the partners cannot divorce since they are not legally married. Therefore,
how can women assert their right to be maintained under Section 125 of the CrPC, 1973.

6. DISCUSSION

When it comes to legal or financial issues, such as open an account in a bank, filing an income tax return, or
asking for loans, Women who are in a live-in relationship are not identified by their partner's surname. They
retain their own identities and are not considered "wives" or "domestic partners." As a result, live-in couples
may split amicably, deprived of the need for a formal divorce or the involvement of a court. 19

A formal divorce in law between partners is not conceivable in the event of a live-in relationship. A thorough
examination of current marital rules reveals that the partners cannot legally split until this type of relationship
is not recognized in law. While entering a live-in relationship seems to be easy, whether "by choice" or "by

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circumstance," exiting this formal relationship appears to be difficult. While the legal ramifications of this
relationship are unclear, there is currently no legislation addressing the split and security of their individual or
joint property after parting.

In Narinder Pal Kaur Chawla v. Manjeet Singh Chawla, 2021 the Supreme Court used a liberal standard,
concluding that the second wife was entitled to support under the 1956 Hindu Adoptions and Maintenance Act.
In this case, the husband concealed information about his former marriage when he married her after a 14-year
separation. Additionally, the Court cited the 2005 Protection of Women from Domestic Violence Act. It
concluded that contradictory support to the second wife would be tantamount to rewarding the respondent for
misleading the claimant.

In Rameshchandra Rampratapji Daga v. Rameshwari Rameshchandra Daga, 24 the Supreme Court attempted
to differentiate between partnerships' "legality" and "morality."
While the Supreme Court said that a bigamous marriage might be declared illegal under existing statute law
because it breaches the Hindu Marriage Act, 1955, it can't be deemed immoral enough to deprive the spouse or
in fact the right to alimony or maintenance.

However, the growing number of live-in relationships, particularly those that develop "out of need," confirmed
that the need for change was recognised. In 2003, the Malimath Committee Report on "Reforms in the Criminal
Justice System" recommended amending Section 125 of the Code of Criminal Procedure to consist of a female
who has been "living in" with a male for a "reasonable time."

In Sumitra Devi v. Bhikan Choudhary,22 the Supreme Court held in 1985 that when a male and a female cohabit
for an extended period and are recognized as husband and wife by the social order, marriage is presumed to
award support. Though, the courts have not prolonged this notion to ostensibly cohabiting couples. Notably, the
2005 Protection of Women from Domestic Violence Act was the first to recognize live-in partners equal to
married couples. This Act does not provide the same protection on live-in couples as personal law does.

In M. Palani vs. Meenakshi,23 the respondent sought Rs 10,000 in maintenance from the opponent, who was in
a live-in relationship with her. The request was made in line with the provisions of Sections 20 and 26 of the
Protection of Women from Domestic Violence Act, 2005. According to the petitioner, the respondent was not
allowed to support since they had never lived together. They had sometimes engaged in consensual sexual
encounters as friends, with no purpose of marrying. Consequently, he said that mere proximity for mutual
pleasure (as in their case) couldn't be deemed a "domestic relationship" under the Protection of Women from
Domestic Violence Act, 2005.

7. CONCLUSION

To summarize, there is a crucial need for legal provisions on live-in relationships that provide a clear image
while taking into account the contemporary Indian social environment, which is founded on the creation of
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culture and tradition. Live seeing someone should be legalized, but only after a long time of living together, to
protect the rights of partners and children born from these relationships. Living with each other and in
connection will typically be a human rights and unusual style. Regardless of its broad presence in the widely
held Western nations, India's social texture is very astonishing. This may be seen because marriage is still the
most preferred kind of relationship in India. In any event, this is not to say that mature unmarried partners who
want to live with each other in the same house should be shunned or despised. The legal executive's attempts to
safeguard the rights of people living under such defensive schemes are indisputably a welcome step forward for
the more significant benefit of the general public. The administrators' task now is to devise an arrangement that
gives legal sanctity to live-in relationships while also ensuring the enthusiasm for Indian traditional social ethics
and traditions so that our deeply rooted sanskar of marriage does not become obsolete in the eyes of future
generations.

8. SUGGESTIONS

We suggest the following in light of the study's findings:

• Parliament should enact legislation governing "live-in relationships" that addresses the following
issues about the people engaged in such a relationship:
 Rights of Maintenance of the Parties
 Definition & Characteristics of a live-in relationship
 Protection from dowry demand & against domestic violence
 Rights of custody of children
 Issues of Legitimacy as well as Inheritance by children

• Additionally, for such legislation to be effective, it should require mandatory registration of live-in
relationships so that the parties have actual evidence of the relationship and may seek redress under
the law.
• Additionally, as indicated by research participants, individuals should know their adverse
consequences/effects. They should be informed that, at the moment, no legislation protects their
rights in the event of a live-in relationship.
They may seek protection or redress only via legal precedents.

BIBLIOGRAPHY
Books
a. Prof. Vijender Kumar, Live-In Relationship : Impact on Marriage and Family Institutions, (2012).
Journal
b. Anuja Agrawal , "Law and 'Live-in' Relationships in India", xlvii Economic & Political Weekly, (2012).
c. Avantika Sarkar, "Law, Religion and Conjugal Ties: A Study of 'Live-inRelationships' in Contemporary
Indian Society",1 IJHRLR (2015).
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www.ijcrt.org © 2021 IJCRT | Volume 9, Issue 8 August 2021 | ISSN: 2320-2882
d. Mr. Yuvraj D. Patil, Socio-Legal Perspective of Live-in-Relationship in India (2011).
e. Surjit S. Gill, Sikhs in Sabah and Labuan: A Historical Perspective, Labuan Sikh Society, (2003)
Cases Laws
f. Lata Singh v. State of Uttar Pradesh, (2006) 5 SCC 475
g. Gokal Chand v. Parvin Kumari, AIR 1952 SC 231
h. SPS. Balasubramanyam v. Suruttaya, AIR 1992 SC 756
i. YamunabaiAnantraoAdhav v. AnantraoShivramAdhav, (1988) 1 SCC 530= AIR
1988 SC 644. 6(D)
j. Malti v. State of Uttar Pradesh, 2000 CriLJ 4170, I (2001) DMC 204
k. SavitabenSomabhaiBhatiya v. State of Gujarat, 2005 (2) SCR 638
l. Narinder Pal Kaur Chawla v. Manjeet Singh Chawla, A.I.R. 2008 Del. 7
m. RameshchandraRampratapjiDaga v. RameshwariRameshchandraDaga, 2005 2
SCC 33
n. Sumitra Devi v. BhikanChoudhary, (1978) 3 SCC 527
o. M. Palani v. Meenakshi, AIR 2008 Mad 162
Websites
p. http://www.legalservicesindia.com/article/211/Live-in-Relationships.html
q. http://projectcloud.info/laws/live-in-relationship-review-and-analysissrishtiaishwarya/
r. http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1926477

Endnotes
1
Mr. Yuvraj D. Patil, Socio-Legal Perspective of Live-in-Relationship in India (2011).available at
http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1926477 (last visited on August 26, 2021).
2
Live in Relationship- Review and Analysis by Srishti Aishwarya; available at:
http://projectcloud.info/laws/live-in-relationship-review-and-analysis-srishtiaishwarya/; (last visited on
August 26, 2021).
3
Live-in relationship-it's position in India and abroad-pros and cons-legitimacy of child-inheritance of property
by GopalSwathyavailable at: http://www.legalservicesindia.com/article/211/Live-inRelationships.html(last
visited on August 26, 2021).
4
SCC OnLine All 332.
5
(2010) 5 SCC 600
6
(2006) 8 SCC 726

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7
AIR 2011 SC 479.
8
Crl. App. No. 2009 of 2013; Decided on 26-11-2013 (SC): 2013 (14) SCALE 448 9 2001
SCC OnLine All 332.
9
Nandakumar vs The State Of Kerala on 20 April, 2018, CRIMINAL APPEAL NO. 597 OF 2018 (Arising out
of SLP (Crl.) No. 4488 of 2017)
10
(2010) 9 SCC 209 : AIR 2010 SC 2933
11
Anuja Agrawal , “Law and ‘Live-in’ Relationships in India”, xlvii Economic & Political Weekly, (2012).
12
Avantika Sarkar, “ Law, Religion and Conjugal Ties: A Study of ‘Live-in-Relationships’ in Contemporary
Indian Society”,1 IJHRLR (2015).
13
Ibid.
14
(2006) 5 SCC 475
15
AIR 1952 SC 231
16
AIR 1992 SC 756
17
(1988) 1 SCC 530= AIR 1988 SC 644. 6(D)
18
Prof. Vijender Kumar, Live-In Relationship : Impact on Marriage and Family Institutions, (2012).
19
Surjit S. Gill, Sikhs in Sabah and Labuan: A Historical Perspective, Labuan Sikh Society, (2003)
20
AIR 2008 Del. 7
21
SCC 33
22
(1978) 3 SCC 527
23
AIR 2008 Mad 162

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