The Right to Marry: Insights from Shafin Jahan v. Asokan K.M
Kavita Krishnan, Women's Right Activist has rightly quoted, "It is not just her
freedom to choose, but her physical freedom has also been curtailed. She is
effectively a prisoner at her father's house right now".
The case of Shafin Jahan v Asokan K.M popularly known has (Hadiya's Case) which had a direct bearing upon the two most important component one is religion and another is marriage. The case concerns with the issue of inter- religious marriages and women liberty to marry. The case also emphasised upon the cherished value of liberty of individual which has been titled by the media as "Love Jihad". The court in this case came across the question of right of an adult woman to get married.
Respondent of this case has filed a writ of habeas corpus before the Honourable High Court claiming that his daughter was likely to be transported outside the country, where the High Court has allowed the petition and declared the marriage as null and void. Aggrieved by the decision appeal was preferred to the Honourable Supreme Court of India. Honourable Supreme Court held that father cannot be allowed to curtail the fundament right guaranteed under Article 21 of the Constitution of India, of his daughter who out her violation married the appellant. Supreme Court further observed that the exercise of the jurisdiction by the High Court to declare the marriage as null and void while adjudication the writ petition of habeas corpus was plainly in the excess of judicial power which has lead to the transgression of constitution and fundamental rights of the appellant.
Case Name: Shafin Jahan V. Asokan K.M & Ors.
Court: Supreme Court Of India
Judges: Chief Justice Deepak Mishra, Justice A.M Khanwilkar & Justice D.Y Chandrachud
Case Citation: Air 2018 Sc 357
Appellant: Shafin Jahan
Respondent: Asokan K.M & Ors.
Background Of The Case:
Ms. Akhila Asokan was a Hindu by birth and during her college education she was converted to Islam and started residing at her friend's home. Her father unaware of everything filed the writ of habeas corpus before the Honourable High Court of Kerala. When the girl appeared before the court, her father came to know about her conversion and further her father made the allegation that she has been forcefully converted.
But Akhila on the other hand made the statement before the court that she had been married to Shafin Jahan, a Muslim and thereafter produced the marriage certificate, on which her name was mentioned as Hadiya. The court was of the opinion that such conversion was a move of suspicion and investigation was carried out which showed Shafin Jahan accused of criminal offence and other radical tendencies. The Honourable High Court of Kerala in its final order has considered the marriage as null and void and granted the custody of Akhila to her father. Aggrieved from the decision Shafin Jahan filed an appeal before the Honourable Supreme Court of India, The Supreme Court on further investigation restored their marriage.
The Judgement
The Supreme Court of India has set aside the judgement delivered by the High Court of Kerala which has passed the order of annulment of marriage and hand over the custody of Akhila to her father. The Supreme Court further ordered that the investigation by National Investigation Agency shall continue without any interference in the marriage. The Three Judge Bench consisting of the Chief Justice Deepak Mishra, Justice A.M Khanwilkar and Justice D.Y Chandrachud removed Hadiya from the custody of her father and on her wish to continue studies she is sent back to her college again.
Case Analysis
"Rainbow is described by some as the autograph of the Almighty and lightning, albeit metaphorically, to be the expression of cruelty of otherwise equanimous "Nature". Chief Justice Dipak Mishra
Elaborating the reality essence, it can be said that when the liberty of person is illegally smothered and strangulated and his/her choice is throttled by the state or private person the signature of life melts and living becomes a bare subsistence. Such an act is an expression of acrimony which gives indecent burial to the individuality of a person and refuses to recognise the other's identity.
The facts of this case depict a different story which has given the colour of different narrative. Since the state is expected to facilitate as well as to protect the rights and liberties of every citizen but the state in this present case can be seen as supporting the cause of father who has endeavoured not allowed his daughter to make her own choice with regard to faith and the liberty to live with the man with whom she has entered into wedlock.
Thus, in the case of Lata Singh V State of UP[1] bench of two judges was of the opinion that, "India is a free and democratic country and once the person becomes major, he or she can marry whosoever he/she likes. If the parents of boy and girl do not approve such inter- religious marriage or inter caste marriage the maximum, they can do is that they can cut off social relation with the son and daughter. But they cannot give threatening warning to commit suicide, or instigate the act of violence to harass the person who has undergone inter- religious marriage or inter caste marriage."
Thus the court in this case further ordered the police authorities and other administration throughout the country to see that if a boy or a girl who is a major undergoes inter-religious or inter caste marriages with a woman or man of a major age, the couple is not subjected to be harassed, threat or any act of violence and anyone who gave such kind of threat, harassment or any act of violence a stern action by initiating criminal proceeding shall be taken against that person.
Thus, it needs no special emphasis to the state that after attaining the age of majority every individual has choice of freedom to take decision of life which has its significance. The court cannot no longer remain to assume the role of parents patriae. The daughter in the present case is entitled to enjoy her freedom of choice as the law permit and court should not assume the role of guardian or any kind of sentiment or egotism of father.
A marriage can be dissolved on the request of parties by a competent court of law. Deprivation of marital status is a matter of serious concern and annulling marriage under the bark of Article 226 of the Indian Constitution is totally against constitutional and fundamental freedom. The Constitution of India being the social document recognises the liberty and autonomy which is provided to each and every individual without any consideration. The Constitutional and fundamental freedom includes the ability to take decision on aspects which defines one personhood and identity.
The right to marry a partner within or outside the religion lies in the exclusive domain of each and every individual. Thus, marriage lies within the corner zone of privacy which is inviolable. The constitutional regime under its Preamble and under Part III from Article 25-28 of the Constitution of India provides individual with the right to profess, propagate and practice religion. Choice of marriage, faith, religion lies in the capacity of individual autonomy which is supreme by virtue of the Indian Constitution.
Article 16 of the Universal Declaration of Human Rights provides with the concept of fundamental importance of marriage as a part of human liberty.
Article 16 states:
The Constitution of India being the supreme protects the ability of each individual to live and pursue the life in a way the individual wants to be but subject to reasonable restrictions provided therein. Matter of marriage, faith, religion, love, partnership, food and dress are the central aspect one's fundamental freedom and liberty. Thus, society in no way has to play any role in order to determine the choice of partner.
In the landmark case of Justice K.S. Puttaswamy v. Union of India [2] the nine judge bench held that the ability to make decision on matters of one's life is inviolable aspect of human personality and liberty. The court further observed that:
"The autonomy of the individual is the ability to make decision on vital matters of concern of life. The intersection between one's mental integrity and privacy entitles the individual to freedom of thought, the freedom to believe in what is right and the freedom of self determination. The family, marriage, procreation and sexual orientation are all integral to the dignity of the individual."
The apex court in the another case, Common Cause (A Regd. Society) v. Union of India[3] held that "our autonomy as persons is founded on the ability to decide on what to wear, how to dress, what to eat, what to share, when to speak and what about to speak, right to believe or not to believe, whom to love or whom to choose as a partner are innumerable matters which deals with the concept of individual liberty and fundamental freedom."
In another important case the apex court in the case of Soni Gerry v Douglas[4], the court dealt with the case pertaining where the daughter of appellant who is major expressed her desire to reside in Kuwait where she was pursuing her education, the court observed that, "She has without any hesitation clearly stated that she intends to go back to Kuwait to pursue her career.
In such a situation we are of the considered opinion that as a major she is entitled to express and exercise her choice of freedom and the court cannot get into the aspect whether she has been forced by her father or not. There may be ample reason on her behalf to go back to her father in Kuwait but we are not concerned with her reason. What she has stated before the court that alone matters in this case and that is the heart of the reasoning of the court which keeps all controversies at bay."
Doctrine Of Parens Patriae
Black's Law Dictionary define "Parens Patriae"
"Parens Patriae jurisdiction is the right of the sovereign and imposes a duty on sovereign, in public interest to protect persons under disability who have no rightful protector. The connotation of the term parens patriae differ from country to country, for instance in England it is the king, in the America it is the people." Thus the government is within the duty to protect and control persons under disability.
Conceptually the theory of parens patriae is the obligation of the state to protect and takes into the custody the rights and the privileges of its citizens for discharging its obligations. Our constitution makes it imperative for the state to secure to all its citizens the rights guaranteed by the Constitution and where the citizen are not in the position to assert and secure their rights the state must come into picture and protect and fight for the rights of citizen.
Marriage-Basic Tenet Of The Society
Family and marriage has been considered as the grundnorm and basic tenet for the existence of a particular society. They both have been defined to play a very important and vital role for the foundation of a civilised society. It is the only relationship of marriage that binds the parties together in obligations towards each other. As a basic unit of a civilised society, family and marriage has been considered as sanctified this has the duty to protect the martial home.
The Honourable Supreme Court of India in the case of Chetan Dass v. Kamla Devi[6] and Sarla Mudgal v. Union of India [7] held that "Marriage is the very foundation of civilised society. The relation once formed the law steps in and binds the parties to various obligations and liabilities there under. Marriage is an institution in the maintenance of which the public at large is deeply interested. It is the foundation of the family and in turn of the society without which no civilisation can exist. Marriage is an institution the continuance of which imbibes the perpetuation of society.
The institution of marriage revolves around certain important fundamental decisions concerning as whom to marry, when to marry. Once the marriage bond is formed certain fundamental choices and decisions to be made out which involves the personal liberty of the individual." The apex court in the recent case has reiterated the fundamental right to choose his or her life partner as fundamental constituent of Article 21 in the case of Shakti Vahini v. Union of India.[8] The word liberty included under Article 21 of the Indian Constitution is not limited to only one quantifiable right.
The rights covered under the garb of Article 21is visible in the entire gamut of legal systems. The import of the enumeration of privacy as a fundamental right embraces in itself the freedom of conscience, freedom of belief, faith and worship, freedom of sexual orientation, freedom and right to choose partner for marriage.
Judiciary: Protector And Harbinger Of Freedom Of Choice And Religion
"At the heart of any system based on the rule of law, there is a strong judicial system, independent and equipped with powers, financial resources, material and skills that are necessary to protect human rights within the framework of administering justice".
The Honourable High Court in this particular case has treaded upon that area which is outside the purview of the constitutional limits of the court. The judgement delivered by the High Court has encroached upon the private space reserved to the couple in which neither law nor the judges can intrude. The High court was of the opinion that twenty four old girl Hadiya is weak and vulnerable and capable of being exploited in many ways.
Thus the approach of the High Court seems to have lost the sight of the fact that girl in this particular case is a major and is capable of taking her own decisions and is entitled to the rights guaranteed under the Constitution of India. The concern of the Supreme Court in intervening in this matter is much about the miscarriage of justice which flawed from the decision of the High Court which has underlined the approach of paternalism as reflected in this case.
The strength of the Constitutionalism shall lie in diversity and pluralism not on the personal domain of the individual. It is obligatory upon the state that expression of choice and freedom is the acceptance of the individual identity. It is important to have realization of rights than the conferment of right. Non acceptance of his/her choice simply means in creating discomfort to the constitutional right of the individual. The duty of every court is to act as protector and guardian of fundamental rights.
Conclusion
Conversion to another religion and marrying to person according to one's choice is an integral part of individualism and important aspect of his/her freedom. Thus, the court cannot probe the validity of marriage if two adults have married according to the personal law. The political debate over "Love Jihad" has been attracted the attention of some political groups which has ulterior motives.
In a country like India where there is diversity in religion, culture and tradition the Constitution under Article 25 provides each and every individual with the right to profess, practice and propagate religion and right to choose and follow religion of their own choice. Curtailment of the expression and freedom of choice emanating from individual will destroy the individualistic identity of the person.
The social norms and value are always above the constitutionally guaranteed freedom. The freedom to choose partner and to follow any religion of choice is matter of constitutional and human right. Choosing a particular faith, religion, or partner for life is substratum of the individuality and sans it; the freedom of choice becomes a shadow.
The Supreme Court making reference to the Article 21 of the Indian Constitution stated that:
"Right to privacy is an inalienable right which is closely associated with the innate dignity of the individual and right to autonomy and self determination to take decision.
"Constitution is ever growing and it is perpetually continuous as it embodies the spirit of nation. It is enriched at the present by the past experiences and influences and makes the future richer than the present".
End Notes:
Also Read:
The case of Shafin Jahan v Asokan K.M popularly known has (Hadiya's Case) which had a direct bearing upon the two most important component one is religion and another is marriage. The case concerns with the issue of inter- religious marriages and women liberty to marry. The case also emphasised upon the cherished value of liberty of individual which has been titled by the media as "Love Jihad". The court in this case came across the question of right of an adult woman to get married.
Respondent of this case has filed a writ of habeas corpus before the Honourable High Court claiming that his daughter was likely to be transported outside the country, where the High Court has allowed the petition and declared the marriage as null and void. Aggrieved by the decision appeal was preferred to the Honourable Supreme Court of India. Honourable Supreme Court held that father cannot be allowed to curtail the fundament right guaranteed under Article 21 of the Constitution of India, of his daughter who out her violation married the appellant. Supreme Court further observed that the exercise of the jurisdiction by the High Court to declare the marriage as null and void while adjudication the writ petition of habeas corpus was plainly in the excess of judicial power which has lead to the transgression of constitution and fundamental rights of the appellant.
Case Name: Shafin Jahan V. Asokan K.M & Ors.
Court: Supreme Court Of India
Judges: Chief Justice Deepak Mishra, Justice A.M Khanwilkar & Justice D.Y Chandrachud
Case Citation: Air 2018 Sc 357
Appellant: Shafin Jahan
Respondent: Asokan K.M & Ors.
Background Of The Case:
Ms. Akhila Asokan was a Hindu by birth and during her college education she was converted to Islam and started residing at her friend's home. Her father unaware of everything filed the writ of habeas corpus before the Honourable High Court of Kerala. When the girl appeared before the court, her father came to know about her conversion and further her father made the allegation that she has been forcefully converted.
But Akhila on the other hand made the statement before the court that she had been married to Shafin Jahan, a Muslim and thereafter produced the marriage certificate, on which her name was mentioned as Hadiya. The court was of the opinion that such conversion was a move of suspicion and investigation was carried out which showed Shafin Jahan accused of criminal offence and other radical tendencies. The Honourable High Court of Kerala in its final order has considered the marriage as null and void and granted the custody of Akhila to her father. Aggrieved from the decision Shafin Jahan filed an appeal before the Honourable Supreme Court of India, The Supreme Court on further investigation restored their marriage.
The Judgement
The Supreme Court of India has set aside the judgement delivered by the High Court of Kerala which has passed the order of annulment of marriage and hand over the custody of Akhila to her father. The Supreme Court further ordered that the investigation by National Investigation Agency shall continue without any interference in the marriage. The Three Judge Bench consisting of the Chief Justice Deepak Mishra, Justice A.M Khanwilkar and Justice D.Y Chandrachud removed Hadiya from the custody of her father and on her wish to continue studies she is sent back to her college again.
Case Analysis
"Rainbow is described by some as the autograph of the Almighty and lightning, albeit metaphorically, to be the expression of cruelty of otherwise equanimous "Nature". Chief Justice Dipak Mishra
Elaborating the reality essence, it can be said that when the liberty of person is illegally smothered and strangulated and his/her choice is throttled by the state or private person the signature of life melts and living becomes a bare subsistence. Such an act is an expression of acrimony which gives indecent burial to the individuality of a person and refuses to recognise the other's identity.
The facts of this case depict a different story which has given the colour of different narrative. Since the state is expected to facilitate as well as to protect the rights and liberties of every citizen but the state in this present case can be seen as supporting the cause of father who has endeavoured not allowed his daughter to make her own choice with regard to faith and the liberty to live with the man with whom she has entered into wedlock.
Thus, in the case of Lata Singh V State of UP[1] bench of two judges was of the opinion that, "India is a free and democratic country and once the person becomes major, he or she can marry whosoever he/she likes. If the parents of boy and girl do not approve such inter- religious marriage or inter caste marriage the maximum, they can do is that they can cut off social relation with the son and daughter. But they cannot give threatening warning to commit suicide, or instigate the act of violence to harass the person who has undergone inter- religious marriage or inter caste marriage."
Thus the court in this case further ordered the police authorities and other administration throughout the country to see that if a boy or a girl who is a major undergoes inter-religious or inter caste marriages with a woman or man of a major age, the couple is not subjected to be harassed, threat or any act of violence and anyone who gave such kind of threat, harassment or any act of violence a stern action by initiating criminal proceeding shall be taken against that person.
Thus, it needs no special emphasis to the state that after attaining the age of majority every individual has choice of freedom to take decision of life which has its significance. The court cannot no longer remain to assume the role of parents patriae. The daughter in the present case is entitled to enjoy her freedom of choice as the law permit and court should not assume the role of guardian or any kind of sentiment or egotism of father.
A marriage can be dissolved on the request of parties by a competent court of law. Deprivation of marital status is a matter of serious concern and annulling marriage under the bark of Article 226 of the Indian Constitution is totally against constitutional and fundamental freedom. The Constitution of India being the social document recognises the liberty and autonomy which is provided to each and every individual without any consideration. The Constitutional and fundamental freedom includes the ability to take decision on aspects which defines one personhood and identity.
The right to marry a partner within or outside the religion lies in the exclusive domain of each and every individual. Thus, marriage lies within the corner zone of privacy which is inviolable. The constitutional regime under its Preamble and under Part III from Article 25-28 of the Constitution of India provides individual with the right to profess, propagate and practice religion. Choice of marriage, faith, religion lies in the capacity of individual autonomy which is supreme by virtue of the Indian Constitution.
Article 16 of the Universal Declaration of Human Rights provides with the concept of fundamental importance of marriage as a part of human liberty.
Article 16 states:
- Men and women of full age without any limitation due to race, nationality or religion have the right to marry and to found a family. They are entitled to equal rights as to marriage and its dissolution.
- Marriage shall be entered into only with the free and full consent of the intending spouse.
- The family is the natural and the fundamental group unit of society and is entitled to protection by the society and state.
The Constitution of India being the supreme protects the ability of each individual to live and pursue the life in a way the individual wants to be but subject to reasonable restrictions provided therein. Matter of marriage, faith, religion, love, partnership, food and dress are the central aspect one's fundamental freedom and liberty. Thus, society in no way has to play any role in order to determine the choice of partner.
In the landmark case of Justice K.S. Puttaswamy v. Union of India [2] the nine judge bench held that the ability to make decision on matters of one's life is inviolable aspect of human personality and liberty. The court further observed that:
"The autonomy of the individual is the ability to make decision on vital matters of concern of life. The intersection between one's mental integrity and privacy entitles the individual to freedom of thought, the freedom to believe in what is right and the freedom of self determination. The family, marriage, procreation and sexual orientation are all integral to the dignity of the individual."
The apex court in the another case, Common Cause (A Regd. Society) v. Union of India[3] held that "our autonomy as persons is founded on the ability to decide on what to wear, how to dress, what to eat, what to share, when to speak and what about to speak, right to believe or not to believe, whom to love or whom to choose as a partner are innumerable matters which deals with the concept of individual liberty and fundamental freedom."
In another important case the apex court in the case of Soni Gerry v Douglas[4], the court dealt with the case pertaining where the daughter of appellant who is major expressed her desire to reside in Kuwait where she was pursuing her education, the court observed that, "She has without any hesitation clearly stated that she intends to go back to Kuwait to pursue her career.
In such a situation we are of the considered opinion that as a major she is entitled to express and exercise her choice of freedom and the court cannot get into the aspect whether she has been forced by her father or not. There may be ample reason on her behalf to go back to her father in Kuwait but we are not concerned with her reason. What she has stated before the court that alone matters in this case and that is the heart of the reasoning of the court which keeps all controversies at bay."
Doctrine Of Parens Patriae
Black's Law Dictionary define "Parens Patriae"
- The State is regarded as a sovereign: the state in its capacity as provider of protection to those who are unable to care for themselves.
- A doctrine by which a government has standing to prosecute a lawsuit on behalf of citizen especially on behalf of someone who is under a legal disability to prosecute the suit. The state ordinarily has no standing to sue on behalf of its citizens, unless a separate sovereign interest will be served by the suit.
"Parens Patriae jurisdiction is the right of the sovereign and imposes a duty on sovereign, in public interest to protect persons under disability who have no rightful protector. The connotation of the term parens patriae differ from country to country, for instance in England it is the king, in the America it is the people." Thus the government is within the duty to protect and control persons under disability.
Conceptually the theory of parens patriae is the obligation of the state to protect and takes into the custody the rights and the privileges of its citizens for discharging its obligations. Our constitution makes it imperative for the state to secure to all its citizens the rights guaranteed by the Constitution and where the citizen are not in the position to assert and secure their rights the state must come into picture and protect and fight for the rights of citizen.
Marriage-Basic Tenet Of The Society
Family and marriage has been considered as the grundnorm and basic tenet for the existence of a particular society. They both have been defined to play a very important and vital role for the foundation of a civilised society. It is the only relationship of marriage that binds the parties together in obligations towards each other. As a basic unit of a civilised society, family and marriage has been considered as sanctified this has the duty to protect the martial home.
The Honourable Supreme Court of India in the case of Chetan Dass v. Kamla Devi[6] and Sarla Mudgal v. Union of India [7] held that "Marriage is the very foundation of civilised society. The relation once formed the law steps in and binds the parties to various obligations and liabilities there under. Marriage is an institution in the maintenance of which the public at large is deeply interested. It is the foundation of the family and in turn of the society without which no civilisation can exist. Marriage is an institution the continuance of which imbibes the perpetuation of society.
The institution of marriage revolves around certain important fundamental decisions concerning as whom to marry, when to marry. Once the marriage bond is formed certain fundamental choices and decisions to be made out which involves the personal liberty of the individual." The apex court in the recent case has reiterated the fundamental right to choose his or her life partner as fundamental constituent of Article 21 in the case of Shakti Vahini v. Union of India.[8] The word liberty included under Article 21 of the Indian Constitution is not limited to only one quantifiable right.
The rights covered under the garb of Article 21is visible in the entire gamut of legal systems. The import of the enumeration of privacy as a fundamental right embraces in itself the freedom of conscience, freedom of belief, faith and worship, freedom of sexual orientation, freedom and right to choose partner for marriage.
Judiciary: Protector And Harbinger Of Freedom Of Choice And Religion
"At the heart of any system based on the rule of law, there is a strong judicial system, independent and equipped with powers, financial resources, material and skills that are necessary to protect human rights within the framework of administering justice".
The Honourable High Court in this particular case has treaded upon that area which is outside the purview of the constitutional limits of the court. The judgement delivered by the High Court has encroached upon the private space reserved to the couple in which neither law nor the judges can intrude. The High court was of the opinion that twenty four old girl Hadiya is weak and vulnerable and capable of being exploited in many ways.
Thus the approach of the High Court seems to have lost the sight of the fact that girl in this particular case is a major and is capable of taking her own decisions and is entitled to the rights guaranteed under the Constitution of India. The concern of the Supreme Court in intervening in this matter is much about the miscarriage of justice which flawed from the decision of the High Court which has underlined the approach of paternalism as reflected in this case.
The strength of the Constitutionalism shall lie in diversity and pluralism not on the personal domain of the individual. It is obligatory upon the state that expression of choice and freedom is the acceptance of the individual identity. It is important to have realization of rights than the conferment of right. Non acceptance of his/her choice simply means in creating discomfort to the constitutional right of the individual. The duty of every court is to act as protector and guardian of fundamental rights.
Conclusion
Conversion to another religion and marrying to person according to one's choice is an integral part of individualism and important aspect of his/her freedom. Thus, the court cannot probe the validity of marriage if two adults have married according to the personal law. The political debate over "Love Jihad" has been attracted the attention of some political groups which has ulterior motives.
In a country like India where there is diversity in religion, culture and tradition the Constitution under Article 25 provides each and every individual with the right to profess, practice and propagate religion and right to choose and follow religion of their own choice. Curtailment of the expression and freedom of choice emanating from individual will destroy the individualistic identity of the person.
The social norms and value are always above the constitutionally guaranteed freedom. The freedom to choose partner and to follow any religion of choice is matter of constitutional and human right. Choosing a particular faith, religion, or partner for life is substratum of the individuality and sans it; the freedom of choice becomes a shadow.
The Supreme Court making reference to the Article 21 of the Indian Constitution stated that:
"Right to privacy is an inalienable right which is closely associated with the innate dignity of the individual and right to autonomy and self determination to take decision.
"Constitution is ever growing and it is perpetually continuous as it embodies the spirit of nation. It is enriched at the present by the past experiences and influences and makes the future richer than the present".
End Notes:
- Lata Singh v. State of UP (2006) 5 SCC 475
- Justice K.S. Puttaswamy v. Union of India 2017 (10) SCC 1
- Common Cause (A Regd. Society) v. Union of India (2018) 5 SCC 1
- Soni Gerry v. Douglas (2018) 2 SCC 197
- Charan Lal Sahu v. Union of India (1990) 1 SCC 613
- Chetan Dass v. Kamla Devi, (2001) 4 S.C.C. 250 (India)
- Sarla Mudgal v. Union of India, (1995) 3 S.C.C. 635 (India)
- Shakti Vahini v. Union of India 2018 (7) SCC 192
Also Read:
- Critical Analysis Of Social Tradition And Customs With Changes In Respect To Lgbtq+ Community With UCC Perceptive Of Same Sex Marriage
- Shafin Jahan v Ashokan K.M
- Analysis On Shafin Jahan V K.M Ashokan And Role Of Right To Privacy
- Shafin Jahan v/s K.M. Ashokan: To Uphold The Freedom Of Choice And Religion
Award Winning Article Is Written By: Mr.Sameer Miyan
Authentication No: OT467177886430-31-1024
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