The Punjab and Haryana High Court's refusal to protect a live-in couple raises troubling questions about liberty, honour and whether constitutional courts are beginning to echo the moral vocabulary of extra-constitutional bodies they once condemned.
By Ramphal Kataria
Abstract
The Punjab and Haryana High Court's June 2026 order refusing protection to a live-in couple has generated concern far beyond the fate of two individuals. By invoking parental dignity, family honour and the sanctity of marriage while declining protection, the Court entered a constitutional terrain that the Supreme Court has repeatedly sought to leave behind. For nearly two decades, constitutional jurisprudence has steadily expanded the sphere of personal autonomy by recognizing the right of adults to choose their partners, irrespective of social disapproval. The latest order appears to reverse that trajectory by elevating social morality over constitutional morality. This essay situates the controversy within the broader history of marriage, caste, patriarchy and honour in Indian society. Drawing upon the writings of B.R. Ambedkar, Louis Dumont, Friedrich Engels, Anthony Giddens, Simone de Beauvoir and several constitutional judgments, it argues that the right to choose a partner is not merely a private preference but a fundamental constitutional guarantee. The essay further examines the continuing influence of Khap Panchayats, honour killings, caste endogamy and patriarchal control over female sexuality, demonstrating how restrictions on choice preserve old hierarchies and obstruct the slow democratization of Indian society.
"Honour belongs to individuals, not to families."
The order of the Punjab and Haryana High Court refusing police protection to a live-in couple may eventually be tested before a higher forum. Judicial orders are neither immutable nor beyond criticism. Yet some judgments carry consequences beyond the litigants before the Court. They reveal deeper anxieties about society and expose the competing visions of liberty and morality that animate constitutional democracies.
This appears to be one such case.
While declining protection to an adult couple, the Court observed that by running away from home, the petitioners had brought disrepute upon their families and affected the dignity and honour of their parents. It further remarked that extending protection in such circumstances might amount to granting judicial approval to an illicit relationship.
The language was remarkable.
Not because Indian society lacks conservatism. Conservatism has always existed. But because constitutional courts have historically functioned as counter-majoritarian institutions. Their purpose is not to reflect prevailing prejudices but to protect individual rights against those prejudices.
The issue before the Court was not whether marriage is socially desirable. Marriage undoubtedly remains one of humanity's oldest and most cherished institutions. Nor was the question whether live-in relationships are morally superior to marriage. Reasonable people may hold differing views on morality.
The issue was far narrower and far more fundamental.
Should adults facing threats be denied protection because their choices offend social sensibilities?
The Supreme Court's answer over the last twenty years has consistently been in the negative.
Yet the present order appears to suggest otherwise.
When Courts Begin Speaking the Language of Honour
There is something deeply unsettling when constitutional discourse starts borrowing vocabulary historically employed by caste councils and patriarchal communities.
Honour.
Family prestige.
Social reputation.
Illicit relationships.
Bad name.
These are not unfamiliar expressions in north India. They constitute the language through which countless young men and women have been disciplined, ostracised and, in extreme cases, murdered.
For generations, Khap Panchayats across Haryana and western Uttar Pradesh have justified interference in matrimonial choices through precisely such arguments. Family dignity and community honour have often been invoked to subordinate individual desires.
The Supreme Court, however, has repeatedly condemned such attitudes.
In Shakti Vahini v Union of India (2018), the Court described honour killings as barbaric and held that no individual or collective body could interfere with the choice of consenting adults.
Similarly, in Lata Singh v State of Uttar Pradesh (2006), the Supreme Court categorically declared that a major woman was free to marry or live with anyone she wished.
The constitutional position appeared settled.
Or so it seemed.
Protection Is Not Approval
One of the most problematic assumptions underlying such reasoning is the conflation of protection with endorsement.
Courts protect undertrials without endorsing crimes.
They protect unpopular speech without approving the opinions expressed.
They protect religious minorities without validating theological doctrines.
Likewise, protecting adults from violence does not imply approval of their relationships.
Protection is not certification.
A constitutional court's obligation is to secure life and liberty, not to determine the moral worth of personal relationships.
Once protection becomes contingent upon social acceptability, fundamental rights cease to be rights and become privileges bestowed upon those who conform.
The Constitution Protects Liberty, Not Reputation of Communities
Article 21 guarantees life and personal liberty.
Article 19 protects association and expression.
Article 14 ensures equality before law.
These rights belong to individuals.
The Constitution recognizes citizens, not clans.
It protects persons, not castes.
It safeguards dignity, not collective vanity.
There is no fundamental right vested in parents to veto adult choices.
Nor does the Constitution confer upon communities the authority to supervise intimacy.
Yet historically, Indian society has attempted precisely that.
To understand why, one must travel far beyond courtrooms.
One must travel into the history of marriage itself.
Because marriage was never merely about love.
It was about property.
About inheritance.
About lineage.
About caste.
And above all, about control.
Marriage: Humanity's Most Ancient Social Contract
Long before states emerged, long before codified laws and organised religions, human communities developed systems regulating sexual relationships and reproduction.
Anthropologists such as Lewis Henry Morgan argued that primitive societies organized themselves through kinship rather than territorial states. Marriage evolved gradually from loose communal arrangements into increasingly structured unions.
Friedrich Engels, drawing upon Morgan's work in The Origin of the Family, Private Property and the State (1884), argued that the emergence of private property transformed family relations. Monogamy, according to Engels, arose not from romance but from inheritance and the desire to ensure legitimate heirs.
"The monogamous family," Engels wrote, "was founded on the supremacy of the male."
Marriage thus became an institution deeply intertwined with patriarchy.
Women increasingly came to be treated as custodians of lineage and property.
Their sexuality required regulation.
Their autonomy became subordinate to family interests.
Love occupied a secondary place.
The preservation of bloodlines occupied the primary one.
The centuries that followed merely refined these mechanisms.
Religion sanctified them.
Society normalized them.
Law codified them.
And honour became their moral vocabulary.
The Indian Story Was Never Entirely Uniform
Ironically, the claim that modern relationships are alien to Indian civilization rests upon a selective reading of history.
Ancient Hindu texts recognized eight forms of marriage.
Among them, Gandharva marriage represented voluntary union based on mutual attraction and consent.
Kautilya's Arthashastra recognized the legitimacy of consent.
Even the Mahabharata contains narratives where women exercised agency.
Indian civilization has never been monolithic.
It has accommodated contradictions and diversity.
Yet over centuries, caste hierarchy and patriarchy narrowed the space available for female choice.
Marriage became less about individuals and more about communities.
Women became carriers of family honour.
Control over sexuality became essential to preserving caste purity.
And love increasingly became a threat.
That threat remains alive even today.
For in India, marriage has rarely been a private matter.
It has always been a public institution.
And nowhere is this more evident than in the persistence of caste.
Endogamy, Patriarchy and the Fear of Choice:
Why Love Has Always Threatened Hierarchy
"The real explanation of caste is endogamy."
— B.R. Ambedkar
The Indian obsession with regulating marriage did not emerge accidentally.
Nor is it merely an expression of parental affection, concern or cultural continuity.
Behind the anxieties surrounding love marriages, inter-caste unions and live-in relationships lies something much deeper and much older—a social order that has survived for centuries by controlling who marries whom.
Dr. B.R. Ambedkar understood this better than anyone else.
Long before sociologists and anthropologists systematically examined caste and kinship, Ambedkar, in his seminal paper Castes in India: Their Mechanism, Genesis and Development (1916), identified the central mechanism through which caste reproduced itself.
Not occupation.
Not religion.
Not ritual.
But endogamy.
"The real explanation of caste," Ambedkar wrote, "is endogamy."
This single observation demolished centuries of conventional explanations.
According to Ambedkar, caste survives because groups insist upon marrying within themselves. Once endogamy becomes sacrosanct, every social institution—from family to religion—begins to serve one overriding purpose: the preservation of caste purity.
Marriage thus ceases to be a union between individuals.
It becomes an instrument of social reproduction.
Love, therefore, becomes dangerous.
Because love is unpredictable.
And caste systems cannot survive unpredictability.
The Anxiety Behind Arranged Marriages
Marriage in India has rarely been left to individuals.
Parents negotiate.
Families approve.
Communities certify.
Priests sanctify.
Caste councils monitor.
Relatives gossip.
Neighbours scrutinize.
The individual merely participates.
What appears outwardly as concern for compatibility often masks a deeper concern: the preservation of caste boundaries.
The vocabulary may vary.
Good family.
Respectable background.
Similar culture.
Same traditions.
Compatible values.
Behind these seemingly benign expressions lies a coded language that often translates into caste, class and community.
Marriage becomes less about companionship and more about social reproduction.
Pierre Bourdieu called this phenomenon the reproduction of social capital.
Families use marriage to preserve not only wealth but also status and symbolic power.
Upper castes preserve caste.
Business families preserve wealth.
Landowning communities preserve property.
Political families preserve influence.
Love threatens each of these calculations.
Louis Dumont and the Hierarchical Imagination
French sociologist Louis Dumont, in his monumental work Homo Hierarchicus (1966), argued that hierarchy constitutes the central organizing principle of Indian society.
Unlike modern societies that prioritize equality and individualism, traditional Indian society is based upon graded inequalities.
Individuals derive meaning not from autonomy but from their place within the collective order.
Family.
Caste.
Community.
Hierarchy.
Duty.
These values often supersede individual preferences.
Marriage therefore becomes a social transaction rather than a personal decision.
The individual is expected to subordinate desire to social expectations.
Love becomes suspect because it introduces equality into a system built upon hierarchy.
Choice becomes disruptive because hierarchy thrives on obedience.
The persistence of honour-based violence demonstrates that Dumont's insights remain disturbingly relevant.
Women and the Burden of Honour
If caste survives through endogamy, endogamy survives through the control of women.
This uncomfortable truth runs through the history of every patriarchal society.
Simone de Beauvoir observed in The Second Sex:
"Humanity is male, and man defines woman not in herself but as relative to him."
Women have historically been transformed into symbols rather than individuals.
Symbols of purity.
Symbols of tradition.
Symbols of honour.
Symbols of family prestige.
Their bodies become territories over which communities exercise control.
Their choices become collective concerns.
Their desires become negotiable.
Marriage becomes less about companionship and more about safeguarding community boundaries.
A son marrying outside caste may invite criticism.
A daughter doing the same often invites outrage.
The asymmetry reveals the patriarchal foundations of honour.
Because what society ultimately seeks to regulate is female sexuality.
Uma Chakravarti and Brahmanical Patriarchy
Historian Uma Chakravarti's concept of "Brahmanical patriarchy" provides a powerful framework to understand this phenomenon.
According to Chakravarti, caste and patriarchy are inseparable.
Women's sexuality becomes the site through which caste purity is maintained.
Strict control over marriage.
Restrictions on mobility.
Surveillance over relationships.
The glorification of chastity.
All become mechanisms for preserving hierarchy.
Honour, therefore, is not merely cultural.
It is political.
And often violent.
The obsession with controlling daughters is not about protection.
It is about lineage.
Because daughters possess the ability to disrupt caste continuity.
Love, therefore, becomes rebellion.
Why Society Forgives Men More Easily
Indian society has always applied different moral standards to men and women.
A man's transgressions are often viewed as youthful indiscretions.
A woman's choices are treated as collective humiliation.
Male sexuality enjoys greater social tolerance.
Female sexuality invites greater scrutiny.
This double standard explains why honour killings disproportionately target women.
The issue is rarely morality.
It is ownership.
Patriarchy assumes that daughters belong to families before marriage and to husbands after marriage.
Autonomy disrupts this arrangement.
Hence the anxiety.
Hence the violence.
Hence the insistence upon obedience.
Marriage as Property and Lineage
Friedrich Engels argued that monogamous marriage emerged alongside private property.
Its principal function was inheritance.
The certainty of paternity became crucial.
Women's sexuality therefore required regulation.
Centuries later, modern societies continue to carry remnants of these structures.
Marriage remains intertwined with property, inheritance and status.
Large landholding communities across northern India continue to treat marriage as an instrument of preserving family assets.
The concern is seldom abstract morality.
The concern is continuity.
Who inherits?
Who belongs?
Who carries the lineage?
These questions often hide beneath the language of tradition.
Why Inter-Caste Marriages Terrify Society
Nothing threatens caste more than inter-caste marriages.
Ambedkar understood this.
In Annihilation of Caste, he declared:
"Fusion of blood alone can create the feeling of being kith and kin."
Inter-caste marriage was not merely desirable.
It was revolutionary.
Because caste survives by controlling intimacy.
Break endogamy and caste begins to weaken.
Which explains why communities react with such hostility.
Love across caste boundaries is perceived not merely as disobedience but as social treason.
The consequences can be devastating.
Expulsion.
Boycott.
Violence.
Murder.
The phenomenon known as honour killing emerges from this anxiety.
Ironically, the victims are often punished not for immorality but for exercising constitutional freedoms.
Why Love Marriages Continue to Be Viewed with Suspicion
India's arranged marriage system remains one of the strongest in the world.
Studies consistently show that a majority of marriages still occur within caste boundaries.
Inter-caste marriages remain relatively rare.
Even among educated families, matrimonial advertisements continue to prioritize caste compatibility.
The language may appear modern.
The preferences remain ancient.
Parents seek doctors.
Engineers.
Government officers.
Fair complexion.
Good family.
Same religion.
Same caste.
The marketplace has changed.
The logic has not.
Economic liberalization modernized consumption.
It did not fully democratize intimacy.
India embraced smartphones faster than it embraced social equality.
The contradiction remains visible everywhere.
Young people study together.
Work together.
Travel together.
Fall in love.
Yet marriage often returns them to the boundaries their grandparents inherited.
Choice exists.
But only within limits.
Freedom is celebrated.
Until it challenges hierarchy.
The Strange Double Standards of Affluent India
The affluent classes frequently preach modernity while practicing selective conservatism.
Their children may study abroad.
Date freely.
Live independently.
Even marry foreigners.
Economic capital cushions social rebellion.
But lower and middle classes often encounter harsher sanctions.
There, caste remains rigid.
Community surveillance remains intense.
Khap authority remains influential.
Honour remains collective.
The same society that celebrates celebrity romances becomes intolerant when ordinary citizens exercise similar choices.
The moral outrage, therefore, is often selective.
Modernity for the privileged.
Tradition for everyone else.
And nowhere does this contradiction become more visible than in the politics of Khap Panchayats.
For in large parts of Haryana and western Uttar Pradesh, the authority of constitutional institutions has long coexisted uneasily with older structures of social power.
Sometimes the conflict remains invisible.
Sometimes it becomes fatal.
And sometimes, tragically, the language of those extra-constitutional structures begins to find echoes in institutions meant to restrain them.
That story is impossible to understand without understanding the rise of the Khaps themselves.
Honour, Khaps and the Violence Against Choice:
Why Love Continues to Terrify North India
"Honour killings guillotine individual liberty."
— Supreme Court in Shakti Vahini v. Union of India (2018)
The vocabulary of honour is as old as patriarchy itself.
Across civilizations, men have fought wars for honour, communities have defended honour and families have invoked honour to justify acts that would otherwise appear indefensible.
But perhaps nowhere is honour invested with such collective anxiety as in matters of marriage and sexuality.
For centuries, societies have placed upon women the impossible burden of carrying the prestige of entire families, communities and castes.
When a daughter chooses for herself, it is rarely seen as an individual act.
It becomes a collective humiliation.
And nowhere has this phenomenon manifested itself more visibly than in the Khap-dominated regions of Haryana and western Uttar Pradesh.
The Khaps: From Clan Assemblies to Moral Regulators
Khap Panchayats did not originate as instruments of oppression.
Historically, they emerged as clan-based institutions among Jat communities and other agrarian groups across present-day Haryana, western Uttar Pradesh and Rajasthan.
Before modern states and bureaucracies became entrenched, these councils functioned as mechanisms for dispute resolution and collective administration.
They coordinated irrigation.
Resolved land disputes.
Maintained social order.
Provided community solidarity.
Their authority rested not upon legislation but upon custom.
In pre-modern societies, such institutions were perhaps inevitable.
The problem arose when these traditional councils assumed powers they were never constitutionally entitled to possess.
Gradually, their jurisdiction expanded.
From property disputes to social regulation.
From mediation to moral policing.
From community welfare to control over marriage.
And eventually, from persuasion to coercion.
They became self-appointed custodians of honour.
The Politics of Gotra and Community Purity
Among many Khaps, marriage within the same gotra or neighbouring villages is prohibited on the assumption that such unions resemble incestuous relations.
These customs, however, often go far beyond biological concerns.
Their underlying objective is social control.
Young men and women are expected to submit to collective authority.
Individual choice becomes secondary.
Personal liberty becomes subordinate to community consensus.
Marriage ceases to belong to the couple.
It belongs to the caste.
The village.
The elders.
The community.
The very idea that two adults may independently decide whom to marry strikes at the foundations of this social arrangement.
Choice becomes rebellion.
Love becomes disobedience.
Autonomy becomes dishonour.
Honour Is a Collective Fiction
The concept of honour itself is deeply paradoxical.
Individual dignity is meaningful because it belongs to persons.
But collective honour often functions differently.
It is an abstraction.
A fiction maintained through conformity.
And because it is abstract, it constantly requires policing.
Women's clothing.
Women's mobility.
Women's friendships.
Women's sexuality.
Women's marriages.
Everything becomes subject to surveillance.
In such societies, daughters are not merely daughters.
They become repositories of family prestige.
Their choices are no longer personal.
They become public questions.
This explains why violence committed in the name of honour is rarely spontaneous.
It is ideological.
It emerges from the belief that preserving social order is more important than preserving human life.
Manoj and Babli: Love Versus Tradition
Perhaps no case better illustrates the cruelty of honour than the story of Manoj and Babli.
In 2007, Manoj and Babli, both belonging to the Jat community in Haryana, married against the wishes of their families.
The couple sought police protection.
But protection came too little and too late.
They were abducted and brutally murdered.
The Khap Panchayat had declared their marriage unacceptable because they belonged to the same gotra.
Their crime was not violence.
Their crime was love.
The Karnal Sessions Court's conviction of several accused marked a historic moment.
But the tragedy exposed a disturbing reality.
The threat to individual liberty often does not come from strangers.
It comes from families.
Communities.
Traditions.
And collective notions of honour.
Honour Killings Are Murders, Not Cultural Practices
The Supreme Court has repeatedly refused to romanticize these crimes.
In Shakti Vahini v. Union of India (2018), Chief Justice Dipak Misra wrote:
"Honour killing guillotines individual liberty, freedom of choice and one's own perception of choice."
The Court observed that no individual, group or collective body has the authority to interfere with the marriage of consenting adults.
The judgment was unequivocal.
Khap Panchayats possess no legal authority.
Social approval cannot become a prerequisite for constitutional rights.
No community sentiment can override individual liberty.
The Constitution, the Court reminded, recognizes citizens—not clans.
Yet social realities remain stubborn.
Why Honour Killings Continue
Honour killings are not crimes of passion.
They are crimes of order.
They occur because existing hierarchies perceive themselves to be under threat.
Inter-caste marriages threaten caste.
Interfaith marriages threaten religious boundaries.
Love marriages threaten parental authority.
Live-in relationships threaten patriarchal notions of legitimacy.
The violence seeks to restore control.
The objective is deterrence.
Punish one couple.
Warn hundreds.
The message becomes clear:
Freedom has limits.
Those limits are defined by society.
Not by the Constitution.
Politics and the Patronage of Khaps
The influence of Khaps extends beyond villages.
Political parties, irrespective of ideology, have often courted their support.
Electoral arithmetic encourages accommodation.
Public criticism remains cautious.
Many leaders invoke tradition while avoiding direct confrontation.
The consequence is troubling.
Institutions that lack constitutional legitimacy acquire political respectability.
Their resolutions begin to shape public discourse.
Their moral vocabulary enters mainstream politics.
And occasionally, their assumptions find echoes elsewhere.
This is what makes certain judicial observations deeply disquieting.
Because when constitutional institutions begin employing the language of honour and social approval, they inadvertently strengthen the worldview of those who have historically opposed individual freedom.
Women Bear the Highest Cost
The victims of honour crimes are overwhelmingly women.
Because patriarchal societies do not merely regulate marriage.
They regulate female agency.
A son who marries outside caste may invite criticism.
A daughter who does the same may invite violence.
The difference is revealing.
Honour resides disproportionately in women's bodies.
Not because women seek such burdens.
But because societies place them there.
Simone de Beauvoir's insight remains profoundly relevant:
"One is not born, but rather becomes, a woman."
Women become symbols.
Bearers of purity.
Guardians of lineage.
Custodians of culture.
And symbols, unlike individuals, are denied autonomy.
The Silence of Society
Perhaps the greatest tragedy lies not in violence itself but in the silence surrounding it.
Villages know.
Neighbours know.
Relatives know.
Communities know.
Yet few speak.
Collective silence transforms prejudice into legitimacy.
The extraordinary becomes ordinary.
The barbaric becomes customary.
And murder becomes morality.
This normalization is what constitutional courts were meant to challenge.
For constitutions are not merely legal documents.
They are moral revolutions.
They seek to replace inherited hierarchies with equal citizenship.
But constitutional morality and social morality often collide.
Nowhere is this conflict sharper than in matters of intimacy.
Love and Fear in Contemporary India
Young Indians inhabit two worlds simultaneously.
They study together.
Work together.
Travel together.
Fall in love.
And yet they remain imprisoned within structures inherited from centuries past.
Modern aspirations coexist with ancient anxieties.
WhatsApp and caste panchayats.
Instagram and endogamy.
Corporate offices and honour killings.
Dating applications and arranged marriages.
Constitutional rights and social sanctions.
India's transformation remains incomplete.
Economic modernization has progressed rapidly.
Social democratization has moved painfully slowly.
The result is a society caught between two ages.
One speaks the language of rights.
The other speaks the language of honour.
One celebrates autonomy.
The other demands obedience.
And nowhere is this conflict more visible than in the courtroom itself.
For over the last two decades, the Supreme Court has consistently attempted to move Indian society towards constitutional morality.
It expanded the meaning of liberty.
It enlarged the sphere of personal autonomy.
It repeatedly declared that adults possess an inalienable right to choose their partners.
Those judgments represented one of the most remarkable transformations in Indian constitutional history.
But the journey towards liberty was neither accidental nor easy.
It was built case by case.
Word by word.
And judgment by judgment.
Understanding why the recent Punjab and Haryana High Court order has disturbed so many requires understanding that constitutional journey itself.
The Constitution Against Society:
How the Supreme Court Made Choice a Fundamental Right
"The Constitution protects the liberty of every individual, not the expectations of society."
For much of Indian history, individual choice in matters of marriage and intimacy was subordinate to family, caste and community. The Constitution changed the grammar of citizenship. It introduced a radically different idea—that individuals, and not communities, are the primary bearers of rights.
Yet the triumph of constitutional morality was neither automatic nor inevitable.
It emerged slowly.
Case by case.
Principle by principle.
And often against the weight of prevailing social morality.
From Subjects to Citizens
The framers of the Constitution understood that Indian society was deeply hierarchical.
Dr B.R. Ambedkar repeatedly warned that India was entering a life of contradictions.
Political equality, he observed, had arrived through universal franchise, but social and economic inequalities remained intact.
The Constitution therefore sought to create not merely a legal order but a social revolution.
Granville Austin described it as a "social document."
Its purpose was not merely to establish institutions.
Its purpose was to transform society.
And nowhere is this transformative ambition more evident than in the expanding meaning of Article 21.
Initially interpreted narrowly, Article 21 gradually evolved into a reservoir of substantive freedoms encompassing dignity, privacy, autonomy and personal choice.
The Supreme Court became one of the principal architects of this transformation.
Lata Singh v State of Uttar Pradesh (2006):
The Right to Marry Whom One Chooses
Few judgments were as direct and unambiguous as Lata Singh v State of Uttar Pradesh (2006).
Lata Singh, an adult woman, had married outside her caste. Her brothers reacted violently and initiated criminal proceedings against her husband and relatives.
The Supreme Court condemned such actions in unequivocal language.
Justice Markandey Katju observed:
"This is a free and democratic country, and once a person becomes a major, he or she can marry whosoever he or she likes."
The Court further directed police authorities across the country to protect couples facing threats.
It described honour crimes as barbaric remnants of feudalism.
The significance of Lata Singh lay not merely in its outcome but in its philosophy.
Parental approval was not elevated into a constitutional requirement.
Family honour was not recognized as a competing right.
Individual autonomy prevailed.
S. Khushboo v Kanniammal (2010):
Morality Cannot Criminalize Adults
The actress Khushboo faced numerous criminal complaints after expressing views supportive of premarital relationships.
The controversy reflected a familiar anxiety.
Can society dictate morality through criminal law?
The Supreme Court answered in the negative.
Justice Markandey Katju and Justice A.K. Ganguly held:
"Living together is a right to life."
The Court observed that morality and criminality are distinct concepts.
A view may offend social sensibilities.
That does not make it unlawful.
The judgment recognized a fundamental truth:
Constitutional rights exist precisely to protect unpopular choices.
If rights depended upon majority approval, they would cease to be rights altogether.
D. Velusamy v D. Patchaiammal (2010):
Recognizing Relationships Beyond Marriage
In D. Velusamy, the Supreme Court examined whether women in relationships resembling marriage could seek protection under the Protection of Women from Domestic Violence Act, 2005.
The Court evolved the concept of a "relationship in the nature of marriage."
Though it imposed certain conditions, the judgment acknowledged a changing social reality.
Relationships outside formal marriage existed.
The law could not pretend otherwise.
The decision reflected judicial pragmatism rather than moral disapproval.
Indra Sarma v V.K.V. Sarma (2013):
Society May Disapprove, But Law Cannot Ignore
Justice K.S. Radhakrishnan recognized that live-in relationships had become a social reality.
The Court acknowledged that such relationships might not enjoy universal social acceptance.
Yet it emphasized the need for legal protection, particularly for women and children.
Importantly, the Court observed:
"Live-in relationships are neither crimes nor sins."
The judgment urged the legislature to consider a comprehensive legal framework.
Society's discomfort, the Court implied, cannot justify legal invisibility.
Justice K.S. Puttaswamy v Union of India (2017):
Privacy Is the Right To Be Left Alone
The privacy judgment transformed Indian constitutional jurisprudence.
A nine-judge Bench declared privacy a fundamental right.
But privacy, the Court clarified, was much more than secrecy.
It encompassed autonomy.
Dignity.
Identity.
Choice.
Justice D.Y. Chandrachud wrote:
"Privacy recognizes the autonomy of the individual and the right to make essential choices."
The judgment specifically included decisions concerning family, marriage and intimate relations.
For perhaps the first time, the Court articulated a constitutional philosophy where intimacy itself became a protected domain.
Shafin Jahan v Asokan K.M. (2018):
The Hadiya Case and Freedom to Choose
The Hadiya case arose from an interfaith marriage opposed by the woman's parents.
The Kerala High Court had annulled her marriage, effectively placing parental authority above adult autonomy.
The Supreme Court reversed the decision.
Chief Justice Dipak Misra held:
"The right to marry a person of one's choice is integral to Article 21."
Justice Chandrachud's concurring opinion went even further:
"The Constitution protects the ability of each individual to pursue a way of life or faith to which she or he seeks to adhere."
This was perhaps one of the strongest reaffirmations of personal liberty.
Parents may disagree.
Society may disapprove.
But adults remain free.
Shakti Vahini v Union of India (2018):
A Constitutional Assault on Honour Killings
The Supreme Court's judgment in Shakti Vahini represented a direct challenge to Khap Panchayats.
The Court held:
"Any attempt by Khap Panchayats or any assembly to scuttle the marriage between two consenting adults is absolutely illegal."
Chief Justice Dipak Misra observed:
"Honour killing guillotines individual liberty."
The judgment recognized honour crimes not merely as murders but as assaults on constitutional values.
It directed States to establish preventive, remedial and punitive measures.
The message was clear.
Communities possess no authority over adult relationships.
Navtej Singh Johar v Union of India (2018):
Constitutional Morality Over Social Morality
If one judgment captures the spirit of modern constitutionalism, it is Navtej Singh Johar.
While striking down Section 377, the Supreme Court articulated a broader philosophy of freedom.
Justice Chandrachud wrote:
"Constitutional morality cannot be martyred at the altar of social morality."
Justice Indu Malhotra observed:
"History owes an apology."
The judgment affirmed that rights do not depend upon majoritarian approval.
The Constitution protects minorities, dissenters and unconventional choices precisely because society often fails to do so.
This principle extends far beyond sexuality.
It applies equally to marriage and intimate relationships.
Joseph Shine v Union of India (2018):
The State Cannot Police Intimacy
While striking down adultery laws, the Court rejected the notion that women are the property of men.
Marriage, it held, does not extinguish individuality.
Justice Chandrachud observed:
"Society has no role to play in determining our choice of partners."
The State's role is not to enforce morality.
Its role is to preserve liberty.
The Emergence of Constitutional Morality
The phrase "constitutional morality" traces its intellectual roots to Dr B.R. Ambedkar.
Ambedkar warned that constitutional morality is not a natural sentiment.
It must be cultivated.
It requires respect for institutions, liberty and individual rights.
Justice Chandrachud expanded the concept in contemporary jurisprudence.
Constitutional morality demands that the State protect citizens even when society disapproves.
Social morality changes with time.
Constitutional morality protects principles.
One reflects prejudice.
The other safeguards freedom.
Why Protection Does Not Mean Approval
Perhaps the most dangerous misconception surrounding cases involving live-in relationships is the assumption that providing protection amounts to endorsing a particular lifestyle.
This logic is constitutionally unsustainable.
Courts protect unpopular speech without approving its content.
They protect prisoners without approving crimes.
They protect religious minorities without endorsing theology.
Similarly, protecting adults facing violence does not imply approval of their relationships.
Protection concerns life.
Approval concerns morality.
The Constitution speaks the language of rights.
Not the language of virtue.
The Troubling Implications of Recent Reasoning
Against this backdrop, any judicial reasoning that elevates family honour and parental dignity above adult autonomy naturally invites concern.
The issue is not whether marriage is sacred.
Marriage has immense social significance.
Nor is the issue whether live-in relationships are ideal.
Reasonable people may disagree.
The issue is whether social disapproval can dilute constitutional protections.
Can honour become a constitutional value superior to liberty?
Can parental expectations override adult choices?
Can police protection be withheld because a relationship is considered morally undesirable?
For two decades, the Supreme Court's answer has consistently been no.
That is why certain contemporary observations appear less as extensions of constitutional jurisprudence and more as departures from it.
And the implications of such departures extend beyond live-in relationships.
Because beneath the controversy lies a deeper conflict.
The conflict between two moral universes.
One rooted in hierarchy.
The other rooted in liberty.
One inherited from tradition.
The other born of constitutional democracy.
The struggle between these two visions is far from over.
Indeed, it is only now entering its most complex phase.
For Indian society itself is changing.
And nowhere are those changes more visible than in the emergence of new forms of intimacy, changing aspirations, women's education, urbanization and the slow but irreversible democratization of love itself.
Love in the Age of Modernity:
Live-In Relationships, New Intimacies and the Slow Democratization of Love
"What appears immoral to one generation often becomes ordinary to the next."
If the conflict between constitutional morality and social morality forms the legal heart of contemporary debates, the transformation of intimacy forms their sociological soul.
For the truth is simple.
Societies change.
And with changing societies, human relationships change too.
Marriage itself has never been static.
Love itself has never been immutable.
What appears eternal often turns out to be historical.
And what appears unnatural often turns out to be merely unfamiliar.
The anxiety surrounding live-in relationships in India emerges partly from the assumption that marriage has always been the only legitimate site of companionship and intimacy.
History suggests otherwise.
Human relationships have continuously evolved.
The institution of marriage has changed.
Gender roles have changed.
Family structures have changed.
And with them, the meaning of love itself has undergone transformation.
Marriage Was Never Frozen in Time
The traditional Indian imagination often treats marriage as an eternal and sacred institution whose essential character has remained unchanged since antiquity.
History tells a different story.
Marriage has constantly reinvented itself.
Polygamy once existed.
Child marriage once enjoyed social legitimacy.
Widow remarriage was condemned.
Inter-caste marriages were taboo.
Divorce was stigmatized.
Women's consent was often irrelevant.
Yet each of these assumptions has gradually changed.
Social practices that once appeared natural came to be regarded as unjust.
The sacredness of marriage itself survived.
Its form evolved.
What changed was not the value of companionship.
What changed was the meaning of equality within companionship.
From Duty to Companionship
For centuries, marriage functioned less as an emotional relationship and more as an economic and social institution.
Its primary purposes included:
Reproduction.
Property transmission.
Lineage preservation.
Social alliances.
Community stability.
Love was desirable but not indispensable.
Compatibility meant social compatibility.
Not emotional compatibility.
Modernity altered these priorities.
Economic independence weakened traditional dependencies.
Education expanded aspirations.
Women entered the workforce.
Urbanization reduced community surveillance.
Individuals began seeking companionship rather than merely stability.
Love gradually moved from the margins to the centre of marriage.
And once love became central, choice inevitably became important.
Anthony Giddens and the Transformation of Intimacy
British sociologist Anthony Giddens, in his influential work The Transformation of Intimacy (1992), argued that modern relationships increasingly resemble what he termed "pure relationships."
Such relationships survive not because tradition demands them but because individuals voluntarily find emotional fulfillment within them.
They are based upon:
Equality.
Communication.
Mutual respect.
Emotional satisfaction.
Unlike traditional marriages sustained by external pressures, pure relationships depend upon internal commitment.
People remain together because they wish to.
Not because society compels them to.
This transformation has profound implications.
Love becomes democratic.
Authority declines.
Individual agency expands.
And relationships become matters of negotiation rather than obedience.
Ulrich Beck and the Individualization of Society
German sociologist Ulrich Beck described modernity as an age of individualization.
Traditional institutions lose their monopoly.
Individuals increasingly construct their own biographies.
Marriage becomes a choice rather than destiny.
Careers replace inherited occupations.
Cities replace villages.
Personal aspirations replace collective prescriptions.
Love itself becomes individualized.
According to Beck and Elisabeth Beck-Gernsheim in The Normal Chaos of Love (1995), modern intimacy is characterized by uncertainty.
Relationships become fragile.
Divorce becomes possible.
Live-in relationships emerge.
Yet these developments are not signs of social collapse.
They are consequences of freedom.
Freedom creates possibilities.
Possibilities create anxieties.
Anxieties create nostalgia.
And nostalgia often disguises itself as morality.
Simone de Beauvoir and Women's Liberation
Perhaps no transformation has influenced modern relationships more profoundly than women's emancipation.
Simone de Beauvoir famously observed:
"One is not born, but rather becomes, a woman."
Her argument was revolutionary.
Women's roles are socially constructed.
And what society constructs, society can reconstruct.
Economic independence fundamentally altered gender relations.
Women no longer remained economically dependent upon marriage.
Education expanded opportunities.
Careers created alternatives.
Marriage ceased to be a necessity.
It became a choice.
And once marriage becomes a choice, companionship becomes as important as duty.
This shift has unsettled patriarchal structures worldwide.
Not because marriage has weakened.
But because authority within marriage has changed.
Equality replaced obedience.
Partnership replaced subordination.
Choice replaced compulsion.
Live-In Relationships: A Global Phenomenon
Live-in relationships did not emerge because societies abandoned morality.
They emerged because societies changed.
Several factors contributed:
Urbanization
Cities weaken traditional surveillance.
Individuals acquire anonymity.
Community pressure declines.
Delayed Marriages
Education and careers postpone marriage.
Young adults seek companionship before formal commitment.
Women's Economic Independence
Financial autonomy enables choices.
Compatibility Concerns
Couples increasingly prioritize emotional compatibility.
Fear of Divorce
Many prefer understanding each other before marriage.
Individual Aspirations
Personal happiness acquires greater importance.
Live-in relationships thus represent neither moral decline nor civilizational collapse.
They represent one among several evolving forms of companionship.
India's Slow Transition
India is experiencing these changes unevenly.
Metropolitan India and rural India often inhabit different centuries.
Urban professionals increasingly postpone marriage.
Women pursue careers.
Young adults migrate for education.
Interactions between genders become common.
Friendships evolve into relationships.
Yet marriage remains deeply influenced by caste, religion and family expectations.
The result is a peculiar contradiction.
People date modernly.
Marry traditionally.
Love individually.
Marry collectively.
Freedom exists.
But within boundaries.
The Elite and the Ordinary: Two Moral Universes
The Indian elite frequently inhabits a different moral world.
Celebrities openly discuss relationships.
Business families send children abroad.
Global lifestyles are celebrated.
Intercontinental marriages attract admiration.
But the same freedoms are not equally available to ordinary citizens.
Middle-class and lower-income communities continue to experience stronger social regulation.
Caste.
Religion.
Region.
Community honour.
These pressures remain intense.
Thus morality itself becomes class-specific.
What is considered fashionable among elites becomes immoral among the poor.
The hypocrisy is striking.
Modernity for the privileged.
Tradition for the rest.
Does Live-In Relationship Threaten Marriage?
Perhaps the most common fear is that live-in relationships will destroy marriage.
Evidence from around the world suggests otherwise.
Marriage has survived industrialization.
World wars.
Women's emancipation.
Divorce laws.
Contraception.
Globalization.
And digital revolutions.
Institutions adapt.
They do not disappear.
Indeed, marriage continues to remain desirable because human beings seek companionship, affection and emotional security.
Live-in relationships do not abolish marriage.
They merely expand choices.
The existence of one form of intimacy does not invalidate another.
Freedom is not a zero-sum game.
Marriage need not fear alternatives.
Only authoritarian structures fear alternatives.
Why Moral Panic Accompanies Social Change
Every major social transformation produces anxiety.
Inter-caste marriages once appeared scandalous.
Widow remarriage was condemned.
Women's education was opposed.
Divorce was stigmatized.
Love marriages invited suspicion.
Today these practices are widely accepted.
Tomorrow's normality often begins as today's controversy.
Social morality moves slowly.
Constitutional morality anticipates the future.
This is why constitutions protect unpopular choices.
Because social acceptance usually arrives decades later.
Indian Society Is Changing—Whether It Likes It or Not
India's demographic profile itself is transforming.
Young people migrate.
Women pursue higher education.
Marriage ages rise.
Family structures shrink.
Nuclear families expand.
Digital platforms facilitate interaction.
Geographical boundaries weaken.
Traditional institutions adapt slowly.
But they cannot prevent change indefinitely.
The process is uneven.
Contradictory.
Messy.
Yet irreversible.
The anxiety surrounding live-in relationships must therefore be viewed not as a battle between morality and immorality.
It is a conflict between two visions of society.
One rooted in authority.
The other rooted in autonomy.
One sees relationships as social obligations.
The other views them as personal choices.
Neither side possesses a monopoly over virtue.
But in a constitutional democracy, the State cannot impose one vision upon everyone.
Its duty is not to decide how citizens should live.
Its duty is to ensure that citizens are free to decide for themselves.
And this is where the law acquires particular significance.
Because while society may disapprove, constitutional democracies must protect.
That protection derives not from changing fashions but from enduring principles embodied in the Constitution itself.
For rights do not exist only for the conventional.
They exist even more urgently for those who choose differently.
And nowhere is this principle more important than in matters concerning love, intimacy and companionship.
For the ultimate question before constitutional democracies is not whether relationships conform to tradition.
It is whether adults possess the freedom to define their own happiness.
That question lies at the heart of liberty itself.
And it is there that the debate over live-in relationships ultimately belongs.
Courts Must Speak the Language of the Constitution, Not the Language of Honour
The Constitution, Statutes and the Future of Freedom
"Constitutional morality is not a natural sentiment. It has to be cultivated."
— B.R. Ambedkar
For nearly two centuries, Indian society has been engaged in a slow and often painful negotiation between tradition and freedom.
The abolition of sati was once condemned as an assault on religion.
Widow remarriage was denounced as immoral.
Women's education was resisted.
Inter-caste marriages invited social ostracism.
Love marriages provoked outrage.
Divorce was stigmatized.
And today, live-in relationships continue to provoke anxiety.
History, however, reveals a remarkable pattern.
What one generation condemns, another generation normalizes.
Social morality changes.
Constitutional morality endures.
And it is precisely because societies change unevenly that constitutions exist.
They are not instruments for preserving inherited prejudices.
They are instruments for protecting liberty against inherited prejudices.
The Constitution Recognizes Citizens, Not Communities
The Indian Constitution does not speak the language of clan, caste or community.
It speaks the language of citizenship.
Article 14 guarantees equality before law.
Article 15 prohibits discrimination.
Article 19 protects freedom of expression and association.
Article 21 guarantees life and personal liberty.
These rights belong to individuals.
Not families.
Not communities.
Not caste councils.
The Constitution recognizes persons, not lineages.
It protects dignity, not collective vanity.
There exists no constitutional right enabling parents to veto adult choices.
Nor does any provision confer upon communities the authority to supervise intimacy.
The rights belong to citizens.
And citizens attain majority not merely in age but in law.
To deny this autonomy is to deny adulthood itself.
Ambedkar's Idea of Constitutional Morality
Few concepts have shaped contemporary jurisprudence more profoundly than constitutional morality.
The expression owes its intellectual origins to Dr. B.R. Ambedkar.
Ambedkar understood that Indian society was deeply hierarchical.
He knew that liberty would often conflict with tradition.
Democracy, he warned, could not survive merely through electoral institutions.
It required constitutional morality.
Respect for individual rights.
Tolerance of differences.
Acceptance of dissent.
Protection of unpopular minorities.
Constitutional morality, therefore, does not demand that society abandon tradition.
It merely insists that tradition cannot override liberty.
This distinction is fundamental.
Individuals may voluntarily choose traditional lives.
But the State cannot impose tradition upon everyone.
Nor can courts transform social approval into a condition precedent for constitutional protection.
The Statutory Position: The Law Has Already Recognized Social Change
Despite the absence of a separate legislation governing live-in relationships, Indian law has gradually accommodated changing realities.
The Protection of Women from Domestic Violence Act, 2005 recognizes relationships "in the nature of marriage."
Section 2(f) extends protection beyond formally solemnized marriages.
Judicial interpretations have further expanded these protections.
Women in qualifying relationships may seek:
Protection from violence.
Residence orders.
Maintenance.
Compensation.
Children born out of such relationships are not illegitimate.
In Tulsa v Durghatiya (2008), the Supreme Court recognized their legitimacy.
In Revanasiddappa v Mallikarjun (2011), the Court emphasized inheritance rights flowing from constitutional principles of equality and dignity.
Thus, Indian law has not treated such relationships as criminal aberrations.
It has sought to protect vulnerable individuals within them.
The philosophy is simple.
The law protects people.
Not moral categories.
Protection Is Not Approval
Perhaps the greatest conceptual error surrounding these debates lies in confusing protection with endorsement.
The Constitution protects unpopular speech.
That does not imply agreement.
It protects accused persons.
That does not imply approval.
It protects religious minorities.
That does not imply theological endorsement.
Similarly, protecting adults facing violence does not amount to validating their lifestyle.
Police protection concerns life.
Not morality.
The State's obligation arises from danger.
Not from approval.
Otherwise, constitutional rights become conditional upon social conformity.
And rights conditional upon approval cease to be rights.
Why Certain Judicial Observations Raise Concern
The issue before constitutional courts is never whether judges personally approve of a relationship.
Judges, like citizens, may hold private moral convictions.
But constitutional adjudication requires a different vocabulary.
When courts invoke:
Family honour;
Social reputation;
Bad name;
Illicit relationships;
they risk entering a terrain traditionally occupied by extra-constitutional institutions.
The concern is not that marriage has been described as sacred.
Marriage possesses immense social significance.
The concern lies elsewhere.
Can parental honour become a constitutional limitation upon liberty?
Can social morality outweigh Article 21?
Can protection from violence depend upon the perceived morality of the victim?
For decades, the Supreme Court's answer has been unequivocal.
No.
And it is precisely because of that jurisprudential history that certain contemporary formulations appear troubling.
Not because they defend marriage.
But because they appear to subordinate liberty.
Khaps and Constitutional Democracy Cannot Occupy the Same Moral Space
Khap Panchayats are social realities.
Their existence cannot be denied.
Their historical role cannot be erased.
But neither history nor popularity confers constitutional legitimacy.
In Shakti Vahini, the Supreme Court categorically held that no collective body possesses authority over adult relationships.
Honour killings were described as barbaric.
Community assemblies cannot decide whom citizens should marry.
Constitutional democracies recognize individuals.
Not clans.
The danger arises when the language of constitutional institutions begins to resemble the language historically employed by those extra-constitutional bodies.
Because legitimacy often travels through language.
Words matter.
Judicial vocabulary matters.
Constitutional discourse matters.
Courts are expected to restrain social prejudices.
Not echo them.
Breaking Endogamy Is Essential to Social Democracy
Dr. Ambedkar understood something many reformers failed to appreciate.
Political equality without social equality remains incomplete.
And social equality cannot emerge without challenging endogamy.
Inter-caste marriages do more than unite individuals.
They weaken hierarchy.
They democratize kinship.
They undermine inherited privilege.
Ambedkar therefore regarded inter-caste marriages as indispensable to the annihilation of caste.
Choice itself becomes revolutionary.
Not because love is inherently radical.
But because hierarchy fears unpredictability.
Caste survives through controlled marriages.
Patriarchy survives through controlled sexuality.
Honour survives through controlled women.
Liberty threatens all three.
Which explains why opposition to choice remains so intense.
Young India and the Future
India is the world's youngest major democracy.
Its aspirations are changing.
Women are entering universities.
Young men and women work together.
Migration is dissolving old boundaries.
Digital technologies are reshaping intimacy.
Traditional authority structures are weakening.
The transition is uneven.
Contradictory.
Sometimes painful.
But irreversible.
Marriage will survive.
Families will survive.
Communities will survive.
But they will survive by adapting.
Not by coercing.
The future belongs not to imposed conformity but to negotiated coexistence.
Tradition and liberty need not be enemies.
What they require is mutual restraint.
Tradition cannot extinguish freedom.
Freedom need not abolish tradition.
Constitutional democracy provides the framework within which both may coexist.
The Real Question Is Not About Live-In Relationships
Ultimately, the debate transcends live-in relationships.
It concerns a larger question.
Who owns adulthood?
The individual?
Or the family?
Who decides companionship?
The citizen?
Or the community?
Who determines dignity?
The Constitution?
Or social reputation?
These questions lie at the heart of democracy itself.
For democracies do not merely distribute political power.
They distribute moral authority.
They transfer sovereignty from collective identities to individual citizens.
That transfer remains incomplete in India.
And every conflict over marriage, love and intimacy reflects that unfinished journey.
Conclusion
Courts Must Speak the Language of the Constitution, Not the Language of Honour
Marriage is one of humanity's oldest institutions.
Its social significance cannot be denied.
Nor can the concerns surrounding new forms of intimacy be dismissed.
Live-in relationships may present numerous social and legal complexities.
Marriage remains cherished by millions.
Tradition deserves respect.
But respect cannot become compulsion.
For the Constitution did not promise Indians the freedom to make only approved choices.
It promised them the freedom to make choices.
That promise acquires meaning precisely when society disapproves.
The history of India has been a history of expanding freedoms.
From sati to widow remarriage.
From untouchability to equality.
From arranged conformity to companionate marriage.
From silence to choice.
The journey remains unfinished.
Honour killings still occur.
Khap Panchayats still exert influence.
Inter-caste marriages remain rare.
Women continue to bear disproportionate burdens.
And social morality continues to resist change.
Against these forces, constitutional courts have historically stood as guardians of liberty.
Their role is not to validate social anxieties.
Their role is to protect citizens from them.
For if constitutional courts begin speaking the language of honour rather than rights, of reputation rather than liberty, and of social approval rather than constitutional morality, they risk transforming themselves from guardians of freedom into custodians of conformity.
History suggests that societies progress not because institutions preserve old fears, but because they learn to accommodate new freedoms.
And the Constitution of India, at its noblest, has always belonged to that future.
References
1. Ambedkar, B.R. Castes in India: Their Mechanism, Genesis and Development (1916).
2. Ambedkar, B.R. Annihilation of Caste (1936).
3. Engels, Friedrich. The Origin of the Family, Private Property and the State (1884).
4. Simone de Beauvoir. The Second Sex (1949).
5. Louis Dumont. Homo Hierarchicus (1966).
6. Anthony Giddens. The Transformation of Intimacy (1992).
7. Ulrich Beck and Elisabeth Beck-Gernsheim. The Normal Chaos of Love (1995).
8. Patricia Uberoi. Family, Kinship and Marriage in India (1993).
9. Uma Chakravarti. Gendering Caste (2003).
10. M.N. Srinivas. Social Change in Modern India (1966).
11. André Béteille. Society and Politics in India (1991).
12. Granville Austin. The Indian Constitution: Cornerstone of a Nation (1966).
13. Claude Lévi-Strauss. The Elementary Structures of Kinship (1949).
14. Jack Goody. The Development of the Family and Marriage in Europe (1983).
15. Pierre Bourdieu. Distinction (1979).
16. Lata Singh v State of Uttar Pradesh (2006) 5 SCC 475.
17. S. Khushboo v Kanniammal (2010) 5 SCC 600.
18. D. Velusamy v D. Patchaiammal (2010) 10 SCC 469.
19. Indra Sarma v V.K.V. Sarma (2013) 15 SCC 755.
20. Tulsa v Durghatiya (2008) 4 SCC 520.
21. Revanasiddappa v Mallikarjun (2011) 11 SCC 1.
22. Justice K.S. Puttaswamy v Union of India (2017) 10 SCC 1.
23. Shafin Jahan v Asokan K.M. (2018) 16 SCC 368.
24. Shakti Vahini v Union of India (2018) 7 SCC 192.
25. Navtej Singh Johar v Union of India (2018) 10 SCC 1.
26. Joseph Shine v Union of India (2019) 3 SCC 39.
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