Metamorphosis Of Relationships - Legal Perspectives On Live-In Dynamics In Mumbai, India

Author: LawSphereX

Category: Family & Personal Law

Published: 2026-08-23T20:36:56.018472+00:00

Updated: 2026-08-26T17:10:27.74+00:00

METAMORPHOSIS OF RELATIONSHIPS: LEGAL

PERSPECTIVES ON LIVE-IN DYNAMICS IN MUMBAI,

INDIA

Reuel Philip, LL.B., Thakur Ramnarayan College of Law, Mumbai University, Maharashtra Sujata Singh Shekhawat, LL.B., Thakur Ramnarayan College of Law, Mumbai University, Maharashtra Rishu Mishra, LL.B., Thakur Ramnarayan College of Law, Mumbai University, Maharashtra “Cultural norms should evolve to reflect the diversity of relationships and lifestyles in a rapidly changing world.” - Vrinda Karat

ABSTRACT

Exploring the legal intricacies of Live- in relationship in India, this study analyses the evolving landscape shaped by societal, governmental, and cultural dynamics. Delving into the rights and responsibilities within live-in unions, with a specific focus on LGBTQ+ couples, it dissects marriage-like statuses, property distribution intricacies, and broader legal rights associated with cohabitation. Examining the influence of cultural norms, religious perspectives, and governmental policies on the acceptance of live-in relationships, the research critically evaluates changing attitudes in Indian society towards cohabitation. Addressing positive aspects and challenges, it explores domestic violence, consent-related issues, and societal stigma.

The research expands its scope to cover inheritance rights, the legal status of children born within live-in relationships, and broader societal implications, with special to the Indian Constitution. This study decodes the legal complexities surrounding live-in relationships in Mumbai, offering insights into diverse relational configurations in the contemporary societal landscape, empowering citizens to navigate and understand these relationships. Keywords: Live-In Relationships, Indian Laws, LGBTQ+, Legal Rights, Societal Attitudes.

INTRODUCTION

"Live-in relationships require legal recognition to protect the rights of individuals who choose this form of companionship. " - Indira Jaising The law is ubiquitous. Yet, most of us go about our daily lives not realizing the full import of the law. From the contracts we enter into when we purchase groceries, to the traffic rules we obey when we drive to work, every aspect of our lives is touched by the law. Given the important role that, law plays in our lives, we are curiously oblivious to its functioning. It is something as real as breathing and yet equally far from our conscious minds. This study examines the relationship between people who live together through the laws, namely the Constitution, individual rights, and the Supreme Court's enforcement of those rights.

The Indian Constitution's rights and values must be carefully balanced between societal customs and individual liberties, as can be seen by looking closely at the document. 1 The SC has decisively ruled in Favor of live-in relationships, raising issues between the rights of cohabiting couples and the needs of traditional conceptions of society2. It is a matter of some debate whether these judgements have had the desired impact on the systemic inequalities faced in the society. There is also the vexed question of the Legality of the Court in making these decisions, which some believe should be in the domain of Parliament. These aspects will be examined in this research, as well as in other essays in this anthology.

However, given t he current moral authority enjoyed by the Court, there is no doubt that the judgements handed down by it shape public discourse and play an important role in transforming society.

THE LAW AND SOCIAL CHANGE

The one of the most fundamental ways in which the law shapes us is in how we identify ourselves. Wife, mother, lover...each of these roles is not merely a societal construct but a societal construct backed by a complex set of legal rules. A whole ecosystem of laws and regulations governs the interactions we have in such positions, with each other and, inevitably, with ourselves. Our very sense of identity is shaped by the law. Before 2018, open marriage relationship between a marital couple was considered as Adultery3, which was criminalized in

1 The Philosophy of the Constitution. https://ncert.nic.in/textbook/pdf/keps210.pdf

2 Acharya, Kalika, and Udgata, Sankalp, Live-In-Relationships in India and Their Impact - A Sociological Study (Sept.,10, 2019). 3 India Penal Code, 1860, Section 497 “Joseph Shine vs Union of India” (SCC Online 1676). 2018 (India).

IPC. Post the changes in the Indian laws, this relationship was removed from its criminalized. status, but it remains a ground for divorce. In a live-in relationship, a woman's rights to assets and inheritance are severely limited; she is essentially treated as chattel. These laws not only determined the legal position of a woman but inevitably devalued her self-worth. When people all around you tell you that you are less than equal, coupled with the sanction of the law, it is certain that a large number of women will start internalizing and believing that. To change the position of women in cohabitation as well as partners of same sex relationship, it is necessary to change these laws. The law, of course, is not static. Usually, the law reflects and encapsulates the social and moral values of a society.

The law is a very significant tool for social transformation, precisely because of this. Law and society are mutually beneficial. The law is shaped by society and in turn shapes it4. When a society is hidebound by tradition and social stasis, any reform has to come through the agency of the law. The representatives of the people in Parliament are unlikely to think beyond that which is desired by the vocal majority (or sometimes even a socially powerful vocal minority). How will the law then, as an engine for social change, deliver? In the Indian ambience, at least in the recent past, the answer has almost always been the Supreme Court. This research will examine that the SC of India has entered the field in a multitude of areas relating to sex, gender and sexuality in regard to live in relationship.

The fundamental rights, that are undoubtedly the essence of the Constitution, support all of these interventions. The basic rights of citizen of India, are outlined in the third part of the Constitution. These rights are the legal armoury deployed by the courts in the judgements delivered by them. In our system of law, as in most systems governed by a written constitution, there is a chapter that contains the fundamental rights possessed by a citizen. But it is necessary to remember that this need not necessarily be the case. Britain, the country from which our Constitution derived the greatest inspiration, does not have such a set of rights. The chapter on Fundamental Rights in the Constitution was shaped by the experiences of the freedom struggle5. All the members of the Assembly as well as the Drafting Committee had been connected in some way to the freedom struggle.

They had lived life under a set of rules where no right was guaranteed, and every person was at the mercy of the British. 4 Funk, Derek Robert, "The Role of Law: How Law Shapes and Alters the Foundations of Societies" (2011). Undergraduate Honors Capstone Projects. 75. 5 “working of our Constitution”. Rationalised 2023-2024, https://ncert. nic. in/textbook/pdf/keps201. pdf.

A live-in relationship entails the cohabitation of an unmarried couple in a long-term

arrangement akin to marriage, without the formalities of matrimony6. This dynamic relationship challenges traditional societal norms, and as society evolves, so must its legal frameworks to accommodate these changes. The Indian legal landscape, however, lacks specific legislation dedicated to live-in relationships, necessitating an exploration of existing statutes, particularly the Protection of Women from Domestic Violence Act (PWDV). Various High Courts and the SC of India have grappled with understanding and explaining the nuances of live-in relationships, a concept perceived as alien in a society where marriage traditionally holds sanctity. The Indian judicial has proven instrumental in shaping the nation's laws pertaining to living together. Courts have ruled that individuals have the rights to choose to live together, irrespective of societal norms and moral judgments7.

The judiciary has affirmed that the law cannot criminalize such relationships merely on the grounds of societal disapproval. Despite the absence of specific legal framework, live-in relationships continue to gain acceptance and recognition in India. While they offer freedom and flexibility to couples, they also present unique legal challenges, especially concerning property, financial obligations, and inheritance. In the case of Mohabbat Ali Khan v. Muhammad Ibrahim Khan (1929)8, the court asserted that when a man and woman establish themselves as a cohabiting couple, the law presumes a valid marriage unless proven otherwise. This early legal perspective set the stage for recognizing the legitimacy of relationships involving shared living arrangements.

The Potential of a Live-In Relationship Even though Adam and Eve were arguably the first unmarried couple in history, the concept of "live-in relationship" has ancient roots that have been tracked back to the daylight of humanity. This is especially true in post-modern India. Their bond in the middle of nature flourished on mutual dependency and the evolutionary struggle for survival in spite of relationship as an institution, forcing the two to living together without any type of relationship customs or symbolic tokens.

6 Volume 3, Issue 1., “Live-In Relationships in India—Legal and Psychological Implications”,

https://doi.org/10.1177/2631831820974585.

7 Pardeep Singh and Another Vs State of Haryana and Others (May., 18, 2021).

8 Mohabbat Ali Khan v. Muhammad Ibrahim Khan, (1929) 31 BOMLR 846 (India).

The symbolic act of biting the apple of desire marked a transformative moment, giving rise to the selfish need for security and stability in relationships, ultimately leading to the establishment of the institution of marriage9. Across different cultures and regions, various theories and expressions of union formations emerged, each with its own set of wedding rituals and ceremonies. As we explore the variation of relationships formations globally, the concept of non-marital relationships or live-in relationships becomes a focal point. The increasing prevalence of relationships that are not conjugal in both developed and developing nations requires a historical analysis to understand the factors and circumstances that gave rise to this changing type of relationship. Doctrine of Common Law Marriage10 One historical avenue of non-marital relationships is the Doctrine of common law.

This doctrine presumes marital status without formal solemnization or registration, recognizing couples who agree to live together as spouses and present themselves as such to the community. In the lack of a legal marriage, it gave women in committed relationships the protection and privileges of a spouse or widow11. The development of common law of marriage in the United States(US), especially in New York following Chancellor Kent's 1809 ruling in Fenton v. Reed, is an example of how informal relationships that looked like marriage were accepted. The requirements for common law of marriage varied among states, but the core principle was the recognition of a marital contract through present consent12. In 1877, the case of Meister v. Moore13 solidified the approval of common law doctrine in the highest court, reflecting a growing consensus among courts and legal scholars on the doctrine.

9 Bendale, Dr. Ujwala and Dubey, Rashmi and Girme, Anuradha, Live-In-Relationship vis-à-vis Sanctity of Marriage (Jan. ,5, 2022).

10 Göran Lind “Common Law Marriage and Cohabitation Law” (Sept.,2008).

11 Hindu Succession Act, 1956 Section 8 ‘allows a widow to claim her share in the property of her deceased husband’.

12 PROBERT, R. Common Misunderstandings “Review of Common Law Marriage: A Legal Institution for

Cohabitation, by G. Lind”, Family Law Quarterly, 43(3), 587–597. (2009).

13 Meister v. Moore, 96 U.S. 76 (1877).

Social Background to Common Law Matrimony Common-law marriage cases from the nineteenth century provide insight into the historical frequency of heterosexual couples entering into relationships outside the bounds of marriage law14. These cases reveal the diverse nature of relationships within social norms, showcasing extra-legal unions that did not conform to either legal or social standards. The common law marriage cases’ social context demonstrates that courts were attuned to the societal realities presented before them. Judges recognized the diversity of relationships and unions, acknowledging that legal practice did not always align with social practices. In the Indian, where social stigma often surrounds non-marital relationships15, historical exploration becomes imperative to understand the roots of societal perceptions.

Addressing this issue requires a nuanced approach, considering legalities, societal norms, and the evolving dynamics of relationships in contemporary India. The rich history of non-marital relationships worldwide provides valuable insights for shaping legal frameworks and challenging societal biases. Statement of Research Problem In the Indian socio-legal landscape, live-in relationships have historically been regarded as taboo, a sentiment ingrained since the British colonial era. While metropolitan areas like Bangalore, Mumbai, and Delhi exhibit a shift in societal attitudes, the rural regions remain entrenched in traditional beliefs, viewing live-in relationships as a deviation from the sanctity of marriage—a concept deeply rooted in religious sacrament and procreation.

The resistance from parents and societal norms stems from a perception that live-in relationships prioritize pleasure over procreation, challenging traditional views conditioned over generations. The prevailing mind set portrays live-in arrangements as a shirking of responsibilities, often labelled as Western-influenced and detrimental to cultural and social

14 Lind, Göran, 'The Common Law Marriage Contract', Common Law Marriage: A Legal Institution for

Cohabitation (New York, 2008; online edn, Oxford Academic, (jan.,01,2009). 15 Doyle, D. M., & Molix, L. (2014). Love on the Margins: The Effects of Social Stigma and Relationship Length on Romantic Relationship Quality. Social Psychological and Personality Science, 5(1), 102-110.

values. The clash between generational perspectives highlights the evolving dynamics within Indian society. Amidst globalization and the infiltration of Western culture, the younger generation in India is gradually adopting a more open-minded stance, rationalizing their choices. While traditional views hold marriage as a sacred commitment based on understanding and tolerance, the contemporary reality reflects a transformation in the understanding of commitment within relationships. Live-in relationships, though opposed by some, find legitimacy in the fundamental right of individuals to choose their partners. Despite the alignment with fundamental rights, the legal landscape in India does not always mirror the sociological reality.

The prevalence of unstable forms of marriage, such as live-in relationships, carries significant social and cultural implications, challenging established norms. However, in a democratic society that upholds the principles of free speech and individual liberty, countering misconceptions necessitates a foundation in accurate data. The need to address this socio-legal issue in India is crucial. The conflict between established ethical standards and changing social mores emphasizes how critical it is to create legal structures that recognize the legitimacy of being together. Educating people about their rights and stressing their freedom to select a partner without fear of moral or ethical backlash is the difficult part. Research Methodology Goals of the Research The following goals are the focus of this study:

1. To understand if living collectively is legal in India.

2. To comprehend the effects of live-in partnerships on society and culture.

3. To discern whether there is a legitimate need and viability of such relationships in India.

4. To establish new laws to address such relationships in the society.

5. To weigh the benefits and drawbacks of this kind of relationship using sociological

theories as a guide. Population/Research Study Universe People from different parts of the city of Mumbai will be included in the population or research study universe for the reason of this study because of their varied perspectives and important contributions on this pressing issue. Methodology for Gathering Data The data used in this study came from secondary sources rather than primary ones. Data includes research papers by scholars and advocates, newspaper reports, reports from professors and other legal luminaries. Marriage Status and Live-In Relationship Status in India. Marriage in India In India, in accordance with Hindu customs, marriage is considered a divine union celebrated on Earth, signifying both religious and societal obligations, thus representing the highest form of social relationship.

Marriage rituals and customs vary among different religions, such as Hinduism, Islam, Sikhism, Buddhism, and Christianity. Nevertheless, it universally signifies a sacred lifelong connection between two individuals. In Hindu marriages, 16four primary rites are pivotal: sacred fire offerings (Homa), bride's handholding (Panigrahana), 7 steps around the fire by both bride and groom (Saptapadi), and the tying of the Mangalsutra (Mangalaya Dharna). In Muslim marriages in India, referred to as Nikaah, it's recognized as a social contract in which the husband's family provides a dower, called Meher, to the bride and her family. Legality around marriage in Mumbai Marriages in India embody intricate layers and a rich tapestry of colours, owing to the country diverse religious and cultural landscape.

A "legal marriage" in India is one that carries the endorsement of the law, and these laws are typically rooted in the religious customs, beliefs, 16“Hinduism and marriage” Indian Journal - https://www. ncbi. nlm. nih. gov/pmc/articles/PMC3705690/.

and traditions of the population. The Solemnization of Marriage and the Significance of Ceremonies in Establishing a Legally Recognized Marriage. The Hindu Marriage laws, does not prescribe any obligatory ceremonies for the validation of a lawful marriage. A marriage may be formally consummated in line with the traditions, rituals, and rituals of the

partners, according to the Section 7 from the Act17. Hence, there are no strict regulations governing the rituals or ceremonies required to legitimize a marriage; any ceremony or ceremonies agreed upon by the bride, groom, or both parties are sufficient to establish the legitimacy of the marriage. Muslim Marriages In contrast to Hindu marriages in India, Muslim marriages are not subject to a codified marriage law. The specifics of Muslim marriages, including their conditions, requirements, ceremonies, and overall nature, are dictated by Sharia law. This legal framework, rooted in Islamic texts like the Quran, Hadith, and Fatwas (Islamic scholars' rulings), governs the principles and practices of Muslim unions.

Valid Permanent Marriage While current laws provide provisions for dissolving marriages through divorce, a permanent marital life is one where two individuals join in matrimony with no intention of dissolution. In 18Islamic jurisprudence, this form of marriage is referred as "Sahih," and it is the prevalent type of union among Muslims. The prerequisites for this type of marriage are stipulated in a marriage contract, known as Nikah-Nama, which is executed by the parties involved. Legal status of Live-In Relationship Within Indian law, cohabitation arrangements are not officially recognised, with the exception of the section found in the Domestic Violence laws, which classifies a woman living in a 17 Hindu Marriage Act, on section 7 “as per Hindu customs and traditions, Saptapadi: A significant Hindu wedding ritual involving seven steps.

Upon the completion of this ritual, the marriage is considered legally binding” (India). 18Justice (R) Dr. Munir Ahmad Mughal, Islamic jurisprudence.

relationship that is similar to marriage as a party aggrieved. Prior to this, the legal quandary revolved around the question of whether an extended cohabitation between an unmarried man and woman, irrespective of the absence of legally valid matrimonial union as per personal laws, conferred upon her the right to seek legal remedies against her male partner. Legal Recognition of Live- In Relationship Although there is currently no explicit statutory protection for Cohabitation in India, many Indian laws have impliedly protected the parties' rights to live-in relationships. Live-in relationships have received legal recognition solely through the Indian judiciary19. These laws are covered in the sections that follow: Indian Evidence Act, 1872 According to Section 114 of the Act, the court may infer specific facts based on the circumstances.

When this section is applied, a court can easily argue that there is a "presumption of marriage" when two people have lived together as husband and wife for a long time. As soon as that is established, a live-in partnership will become legally recognized, as well as the female partner is going to be granted the status of wife. Domestic violence legislation Section 2(f) of DV Laws provides a definition of 'domestic relationship' that encompasses 'relationship in marriage. ' The term 'relationship in the nature of marriage' within this section is broad enough to include 'live-in relationships. ' According to Section 2(f), the Act not only applies to married couples but also to relationships similar to marriage.

Section 2(a) of the act defines an 'aggrieved person' as 'any woman who claims to be a victim of domestic abuse by the respondent and who is or was in an intimate relationship with the respondent. If a woman in an intimate relationship experiences verbal, physical, psychological, or financial abuse, she may be eligible for legal remedies. This Act grants various rights and protections to abused women. If the court finds evidence of domestic violence, it can issue 19IJLJ - Vol. 11 No. 1(Part-II). “Legal Recognition of Live-In Relationship: An Emerging Trend of Social Transformation in India” Dr. Sangeeta Chatterjee.

orders prohibiting the accused from engaging in activities that harm the victim. As a result, this Act is the sole legal provision that explicitly protects female partners in live-in relationships. Dowry Prohibition Act, 1961 This Act does not explicitly apply to live-in relationships. The court has ruled that dowry pertains to financial demands in the context of marriage, and since live-in relationships are not formal or ceremonial marriages, the concept of dowry does not apply. Maintenance under Hindu Marriage laws, 1955 In the D. Velusamy20 case, four essential criteria must be met for a female partner in a live-in21 relationship to gain legal recognition as a wife and be eligible for maintenance. Therefore, if these prerequisites are met, a female partner in a live-in relationship can receive maintenance under this Act.

Maintenance under Section 125 of the Code of Criminal Procedure, 197322 Section 125 of the Cr. P. C. addresses maintenance for a 'wife' and defines 'wife' as a woman who has not remarried after divorce, either by her husband or through another divorce attorney. Consequently, this section does not specifically cover a female as a wife. Malimath Committee on Reforms of the Criminal Justice System In 2003, the Malimath Committee recommended amending Section 125 of the Criminal Procedure Code, 1973, to include 'a woman living with a man for a reasonable period. ' Additionally, in June 2008, the National Commission for Women recommended to the Ministry of Women and Child Development that live-in female partners should have the right to maintenance under this section. Chanmuniya vs.

Virendra Kumar Singh Kushwaha23 Chanmuniya, the appellant who sought to assert her marital rights, the Supreme Court

20 D. Velusamy V. D. Patchaiammal, (2010)10 SCC 469 (India).

21 D. Velusamy vs. D. Patchaiammal, (2010), 10 SCC 469 (India).

22 Dr. Justice V.S. Malimath Report. Committee on Reforms of Criminal Justice System. Government of India, Ministry of Home Affairs. Report Vol I; Mar.,2003.

23 Chanmuniya v. Virendra Kumar Singh Kushwaha (1881) 6 AC 364 (India).

interpreted this section in light of the mentioned recommendations and granted maintenance to the female partner in the live-in relationship. However, concrete amendments have not been made to date on this matter. A landmark case 24Indra Sarma vs VKV Sarma,

The Supreme Court's standpoint was that not all cohabiting unions can be equated to marriages. In this specific case, it was established that the petitioner could not be deemed to have engaged in a live-in relationship in the conventional sense, as it lacked the essential and intrinsic characteristics of a marital bond. Instead, it constituted a distinct form of relationship from what one would expect in a marriage, despite the petitioner's full knowledge of the respondent's marital status. Within this legal decision, the Court also issued the following remarks: • Such relationships may give rise to a pattern of reliance and vulnerability, potentially enduring for extended periods. Consequently, there arises a pressing need for appropriate and effective safeguards in these kinds of unions, particularly for women and any offspring involved.

• The legislature cannot encourage premarital sex, but since these relationships can occasionally be quite intimate, citizens are free to voice their opinions both in favor and against them. The Hon’ble Supreme Court laid down the guidelines are as follows: • Resource pooling and financial arrangements – In order to maintain a long-term relationship, they need to assist each other financially. • Domestic Arrangements- putting the burden of running the household on the woman. • Sexual Relationship – Sexual interactions that are not simply for fun but also for emotional support and childbearing. • Children – This is a significant sign of a committed partnership, such as a marriage.

24 Indra Sarma vs V.K.V. Sarma, AIR.2014 SC 309 (India).

Rights of Children Born Out of Live-In Relationship25 The status of children born within live-in relationships is a topic open to debate. According to Section 16 of the Hindu Marriage Act, 1955, all children born from annulled Hindu marriages are considered legitimate. Similarly, Section 24 of the Special Marriage Act, 1954 extends legitimacy to children born from annulled inter-religious marriages, and Section 21 of the Divorce Act, 1869 does the same for children born from annulled Christian marriages. Therefore, if a live-in couple's relationship does not meet the criteria for marriage and ends, their children would also be considered legitimate and entitled to inherit their parents' possessions. However, they would not be eligible to inherit property.

If the relationship qualifies as a valid marriage, the children, in their innocence, would have the same property and succession rights as the children of a legally recognized marriage. Live-In Dynamics in Mumbai -Data Analysis & Discussion Findings from Kandivali, Borivali and Mira Road – Mumbai, India The Google form aimed at gathering data for a legal research paper on live-in relationships in India, focusing on insights from three distinct areas in Mumbai City: Kandivali, Borivali, and Mira Road. This geographical diversity adds a valuable layer to the research, considering potential regional variations in attitudes, cultural norms, and legal awareness. The inclusion of diverse age groups in the survey enhances the depth of the study. Varied perspectives from different generations can illuminate evolving societal views on live-in relationships.

Younger participants might provide insights into modern attitudes, while older respondents could offer perspectives rooted in tradition, creating a comprehensive snapshot of societal attitudes toward this evolving concept. Kandivali, Borivali, and Mira Road, being part of Mumbai, contribute urban perspectives to the research. Mumbai, as a cosmopolitan city, is often a microcosm of broader social changes in India. Exploring how individuals in these specific areas perceive live-in relationships can unveil nuanced perspectives influenced by local dynamics and city life. 25 Kattukandi Edathil Krishnan vs Kattukandi Edathil Valsan, (Jun. ,13, 2022) 2022 SCC Online SC. 738 (India).

Fig 1: Total number of Population Participated in the Survey. 26 Around 55. 5% of females and 43. 5% of males participated in this survey. The survey results provide a compelling snapshot of the awareness levels surrounding live-in relationships among participants in Kandivali, Borivali, and Mira Road. Notably, a significant 48. 4% of respondents indicated a high level of familiarity with the concept. This suggests a considerable awareness and acknowledgment of live-in relationships within these urban pockets of Mumbai. On the flip side, 12. 9% expressed being not familiar at all, while 38. 7% indicated a moderate level of unfamiliarity. These figures underline the existence of a segment of the population that lacks awareness or understanding of the intricacies associated with live-in relationships.

It prompts an exploration into the factors contributing to this lack of familiarity—whether it's rooted in cultural beliefs, insufficient information dissemination, or a combination of societal factors. What is the primary reason for choosing a live-in relationship over marriage or remaining single?

26 Google form link data collected (2023) (Mumbai, India).

https://docs.google.com/forms/d/1ULBbCo21N14gQ7DH7i6DM7YxZ2ifXqr_d9Kih9SgmDI/edit#response=A CYDBNgQLUlPPavPfi3WN0aPRxwuOZ8itXBbLr9taAWdF8igtLCX_rA-TRhm5hpVKzli4bw

Fig 2 Reasons for live-in relationship responses by survey participants.27 The survey's exploration into the primary reasons for choosing a live-in relationship over marriage or remaining single unveils a rich tapestry of motivations within the surveyed populace. The dominant response, with 55.6%, reflects a prevalent desire for testing compatibility. This underscores a contemporary societal shift towards pragmatic approaches to relationships. Individuals increasingly view live-in arrangements as a means to assess longterm compatibility before committing to marriage, signalling a nuanced evolution in relationship dynamics. A notable 19.4% of respondents identified greater personal freedom as their motivation for

opting for a live-in relationship. This suggests a desire for autonomy and independence, showcasing a departure from more traditional, structured institutions like marriage. The acknowledgment of personal freedom as a key factor aligns with broader cultural shifts emphasizing individual choice and self-determination in matters of relationships. The inclusion of responses citing financial reasons and incapacity to get married reveals the socio-economic dimensions influencing relationship choices. Economic considerations, such as the cost of a wedding or financial stability, emerge as practical factors steering individuals towards live-in relationships as a viable alternative. Additionally, responses like "testing compatibility before marriage" indicate a nuanced perspective on the temporal aspects of commitment.

Some individuals might perceive live-in relationships as a transitional phase before embracing the institution of marriage, reflecting a blend of traditional and contemporary values. The response "I don't know, I'm a student" brings attention to the demographic context. Students, being in a phase of transition and exploration, might approach relationships with a more fluid mindset, driven by evolving personal and academic considerations. Do you believe that societal perceptions of live-in relationships have changed in recent years?

27 ibid.

Fig. 3 Societal perceptions responses in the survey by the participants28. A significant 41.7% of participants affirming a positive shift suggests a prevailing belief that

societal attitudes have indeed changed in recent years. This mirrors broader trends seen globally, where traditional norms around relationships undergo reinterpretation in the face of evolving societal values. The 18. 3% who outright deny a change in societal perceptions reflect a degree of resistance or scepticism towards acknowledging shifts in collective attitudes. This subgroup might be anchored in more traditional perspectives or experiences that do not align with perceived societal changes. The 40% responding with "maybe" introduces an intriguing element of uncertainty or ambivalence. This segment could be reflecting a nuanced understanding of the complexity surrounding societal perceptions, recognizing that shifts may be occurring but with varying degrees or unevenly across different demographics or regions.

Exploring the factors contributing to perceived changes or lack thereof would be insightful. Cultural influences, generational gaps, and media representation could play pivotal roles in shaping how individuals perceive the evolution of societal attitudes towards live-in relationships.

28 Ibid.

In your opinion, should live-in relationships be legally recognized, similar to marriage? Fig. 4 Opinion on cohabitation legally recognition by participants. 29 The responses to the question regarding legal recognition of live-in relationships showcase a nuanced and diverse array of perspectives. The 21. 7% supporting legal recognition express a desire for acknowledging the legitimacy and rights of individuals in live-in relationships, aligning with evolving societal norms. Conversely, the 26. 7% opposing legal recognition may stem from traditional beliefs, asserting that legal frameworks should be exclusive to marriage. Their perspective underscores the ongoing societal debate about the role of legal institutions in regulating different forms of relationships. The substantial 48.

3% responding with "it depends" introduces a pragmatic consideration, recognizing the need for context-specific approaches. This group likely believes that legal recognition should be contingent on factors like duration and commitment within the live-in arrangement. The response advocating for "some rights, not all" suggests a middle ground, emphasizing the need for legal protection without necessarily mirroring the comprehensive framework of marriage. These diverse viewpoints underscore the complexity of incorporating legal dimensions into the evolving landscape of modern relationships.

29 Ibid.

What are some advantages of live-in relationships, in your view? Fig 5 Advantages of live-in relationship participants view30. Inheritance rights signify that individuals in live-in relationships may have the opportunity to inherit from their partners in the event of one partner's demise. This can provide a sense of financial security and ensure that assets are passed on to the surviving partner. Property rights highlight the ability for couples in live-in relationships to share and co-own property, which can lead to economic stability and shared responsibilities. This aspect can be particularly advantageous when it comes to the division of assets, making it more equitable and legally recognized. Custody and visitation rights pertain to couples who have children together while living in a domestic partnership.

These rights help ensure that both partners have legal rights to access and care for their children, contributing to the emotional well-being and upbringing of their offspring. The pie chart visually represents the distribution of these advantages, offering a quick and informative way to understand the significance of each response in the context of live-in relationships. It serves as a helpful tool for policymakers, sociologists, and individuals considering cohabitation to appreciate the legal and emotional benefits of such partnerships.

30 Ibid.

Do you think live-in relationships are common among certain age groups? Fig 6 Responses of participants on prevalence of Live-in relationship.31 The pie chart represents responses to a question about the prevalence of live-in relationships and the demographics of those who engage in them. When asked whether live-in relationships are very common, the data revealed that 41.7% of respondents believed that these relationships are more common among younger adults, suggesting a perception that this arrangement is increasingly popular among the youth. Furthermore, 23.3% of respondents indicated that live-in relationships are more prevalent among middle-aged adults, indicating that a significant portion of the population associates this living arrangement with individuals in their middle years. A notable 16.75% of respondents expressed uncertainty regarding the commonality of live-in

relationships, reflecting a lack of consensus or knowledge on the subject. Additionally, a segment of respondents, accounting for 18.25%, believed that live-in relationships are equally common across age groups. This pie chart provides a clear snapshot of public perceptions about the prevalence of live-in relationships, showing that there is no unanimous viewpoint, with varying opinions about the age groups in which such arrangements are most common. 31Ibid.

How do live-in relationships impact the institution of marriage? Fig. 7 Participants opinion regarding the impact of live-in relationship32. The above pie chart illustrates public opinion regarding the impact of live-in relationships on marriages. According to the data, 23. 3% of respondents believe that live-in relationships can strengthen marriages by promoting compatibility and understanding before tying the knot. On the contrary, 30% of respondents think that live-in arrangements may weaken the institution of marriage, possibly due to concerns about commitment or traditional values. A significant portion, 40%, expressed uncertainty about the effect, indicating a lack of consensus or a need for further research to understand the implications of live-in relationships on the institution of marriage.

This pie chart provides a concise overview of the diverse perspectives on this complex issue, reflecting the ongoing debate surrounding the role of live-in relationships in the context of marriage.

32 Ibid.

What kind of legal rights and responsibilities should be associated with live-in relationships, if any? Fig. 8 Participants opinion on legal rights and responsibilities associated with cohabitation. 33 Analyzing the collected data could reveal patterns or differences in attitudes and legal awareness among the surveyed locations and age groups. It may also unveil correlations between cultural factors and perceptions of live-in relationships. Ultimately, the research has the potential to not only contribute to the understanding of live-in relationships in the Indian context but also shed light on the dynamic interplay between societal norms, geography, and generational shifts in a diverse and vibrant city like Mumbai, India. Lesbian couple Relationship "Indian laws must evolve to keep pace with the changing dynamics of relationships and personal choices.

" - Menaka Guruswamy A same-sex couple living together was given police protection by the Punjab and Haryana High

Court, which noted that Article 21 of the Indian Constitution continues to apply in such cases. This order was made by Justice Anoop Chitkara's bench in response to a protection request

33 Ibid.

made by a prominent lesbian couple that have been living together for the past four years34. "Love, attraction, and fondness have no boundaries, and not even the boundary of gender. However, some segments of societies cannot keep pace with the boldness of expression, courage not to be subservient, and the rapidly changing ethos and lifestyles that Gen-Z and millennials might like to embrace or follow, including openly proclaiming their attraction towards persons of similar gender," The Court noted, emphasizing that same-sex live-in couples are similarly covered by Article 21. According to Article 21 of the Indian Constitution, every person residing on Indian territory has an inherent and unalienable fundamental right to life.

The State is obligated to protect life, and the Court ordered the relevant Superintendent of the Police, SHO, or any other officer to provide the petitioners with the necessary protection. Same Sex Relationship A five-person Constitution Bench judges, including on the topic of same-sex

marriage/marriage equality, CJ of India – DY Chandrachud and Justice. Sanjay Kishan, S. Ravindra Bhat, PS Narasinha and Hima Kholi released four distinct decisions. On certain areas, they agreed, but on others, they didn't. In an exhausting35 366-page decision filled with a lot of legalese, the justices unanimously decided that the couple did not have a fundamental right of entering into a marriage contract. Moreover, the Supreme Court clearly said that it was not competent to participate in judicial legislation by interpreting the Special Marriage Act's provisions in a way that made it a law free from gender-based limitations. The Court entrusted the responsibility of effecting any such legislative amendments to the legislative branch, i. e. , the Parliament.

Nevertheless, there were divergent opinions on specific issues, with Justices Bhat, Kohli, and Narasimha forming the majority perspective, while Chief Justice Chandrachud and Justice Kaul voiced their dissenting viewpoint.

34 X v. State of Punjab & Ors. (2023) 10 RAJ CK 0075, Sept.,13,2022 (India).

35 Supriyo vs. Union of India (Oct.,17, 2023), 2023 INSC 920 (India).

“Whereas the comprehensive judgment addressed multiple facts pertaining to the rights of the LGBTQIA+ community”. All five judges have ruled in unanimity that there isn't an innate, fundamental right to marriage. The elucidations provided in their respective judgments are as follows: India's Chief Justice (CJI) Chandrachud, who exhaustively deliberated upon this matter within his extensive 247page verdict, articulated, "The Constitution does not expressly enshrine a fundamental right to marriage. A legal enactment alone cannot elevate an institution to the category of a basic right. However,

a number of aspects of marriage align with constitutional principles, such as the freedom of life and liberty for oneself as well as the rights to human dignity. " Justice Bhat, who delivered the decision on both Justice Kohli's and his own behalf, agreed with this viewpoint, stating that, contrary to what the petitioner had claimed, there is no automatic assumption that a person has the intrinsic right to marry based solely on the terms of Part III. He pointed out, "It is not tenable to assert unequivocally that an unqualified right to marry exists, meriting classification as a fundamental freedom. " Justice Kaul and Justice Narasimha, each offering separate opinions, likewise concurred entirely with this viewpoint.

The petitioners requested two options for gender-neutral interpretation of the special marriage law (SMA) in the event that a provision was determined to be in violation of the third part of the Constitution. Rule it null and invalid. To prevent it from being deemed void, modify it by either deleting or adding/substituting phrases. CJI Chandrachud stated in her opinion that "it would take India backward to the before independence era where two persons of distinct faiths and class were incapable to commemorate their love in the manner of marriage. " If the statute is declared invalid for prohibiting same-sex couples, Chandrachud added.

Such a ruling would not only force the country to return to a time of disparities in society and religious intolerance, but it would also force the courts to decide whether to uphold Article 13 in the Constitution and eliminate one kind of bias and prejudice at the expense of allowing another. This Court would effectively be entering the legislative domain if it adopted the second

strategy and added language to the Special Marriage Act's and other related statutes' provisions, such as the ISA36 and HSA37. Justice Bhat concurred, stating that it cannot be argued that the 1954 SMA's excluded of nonheterosexual couples rendered it without justification and turned it into a prejudiced organization. "Gender unbiased comprehension, similar to a lot allegedly forward-thinking ambitions, might not be entirely properly at times and may result in women being subjected to unintentional fragility, particularly if actual efforts are made to achieve an equilibrium in a system of society that for centuries tends in Favor of cis-heterosexual men," he said in reference to the gender-neutral interpretation of the Special Marriage Laws in India.

Personal rules governing marital grant individuals who define as male or female and who identify as intersex or transgender and are engaged in hetero-sexual relationship the Legal right to marry, under the direction of the Union Cabinet Secretary, a committee created to define the range of rights available to same-sex couples in civil unions—as hinted at during legal proceedings by Mr. Tushar Mehta, the Solicitor General, representing the Union Government—will be assembled with the express intent of clarifying and defining the extent of benefits available to same-sex couples in the context of their unions. The Court has instructed the Committee to start this initiative only after carefully considering the views of relevant parties and representatives from each State and Union Territory, acknowledging this guarantee.

Furthermore, it is said that the Committee, which is led by the Cabinet Secretary, shall administer its report to the various governments of the states and territories as well as the Union Government. Contrary to the Majority View, the minority perspective recognized the right or liberty to enter into a contract for marriage, even if it maintained that there was no clear basic claim to matrimony. In accordance with the Majority View, it was observed that while the minority perspective posited the absence of an explicit fundamental entitlement to matrimony, it acknowledged a right or liberty to contract a union. argued that there is, in fact, a right—referred to as a "right to a relationship38"—that is protected by Article 21 of the Constitution. Judge Bhat's ruling, which applied to both Judge Kohli and himself, stated that the only way to legally recognize a

36 Indian Succession Act, 1954 (India).

37 Hindu Succession Act, 1956 (India).

38 INDIA CONST. art. 21.

right to a union—which is similar to marriage or a civil partnership—is to pass legislation that grants the parties to the relationship legal status. Consequently, it follows that the court is powerless to order or prescribe the creation of a regulatory structure that would grant legal standing. Judge Narasimha, in his judgment, emphasized the classification made by Chief Justice Chandrachud regarding the status of two individuals in a relationship: a) relationships' devoid of legal consequences, and b) The legal implications of marriages and "unions. " However, he contended that the judicial system would violate the principle of The division of The authorities if it gave the State explicit instructions to recognize or give legal status to "unions" that would result in benefits. In this context, Judge Bhat observed that the State may select from a range of policy outcomes.

These options include making all laws pertaining to marriage and family gender-neutral, creating a statute akin to the Special Marriage Act with gender-neutral language to provide the LGBTQ+ community a legal avenue for matrimony, enacting legislation to establish civil unions or domestic partnership, among other possibilities39. Contrary to the Majority View, Chief Justice Chandrachud and Judge Kaul held that the term "sex" in Article 15 of the Constitution encompasses other identity markers linked to the sex and 40gender, such as "sexual orientation. " Therefore, prohibiting individuals from entering into a union based on their sexual orientation would be in violation of Article 15.

Furthermore, they dismissed the idea that allowing non-heterosexual unions would set a precedent for endorsing incestuous, polyandrous, and polygamous unions across all communities, in line with the personal laws of certain religious and tribal communities that presently permit polygamy or polyandry. Such a restriction based on sexual orientation would encroach upon the principles outlined in Article 15 of the Constitution.

39 Supreme Court of India.

40 INDIA CONST. art. 15, “forbids discrimination on grounds only of religion, race, caste, gender, or place of birth”.

When Judge Kaul discussed the issue of non-heterosexual couples getting married, he said it would be incorrect to say that these kinds of relationships are only a part of the contemporary social environment. Even in heterosexual relationships, he pointed out, socially prescribed gender roles may be challenged by the legal recognition of not heterosexual unions. In these kinds of unions, neither partner is constrained by traditional gender roles when forming their partnership, including how much work gets done by whom. Additionally, social acceptance would increase with legal recognition, which would increase the LGBTQ+ community's participation in public spaces. Judge Kaul said, paraphrasing Bon Jovi's song lyrics, "nonheterosexual couples have just as much right to be recognized for their affection, dedication, and responsibility as heterosexual couples do.

As long as this autonomy doesn't violate anyone else's rights, let's safeguard it. It is, after all, "my life. " Legal Status of Live-In Relationships in Various Jurisdictions The United States The United States the American judiciary cleared the path for the declaration of anticohabitation laws unconstitutional in order to uphold the right to privacy. The US Supreme Court ruled in Lawrence v. Texas41 that the US Constitution does not apply to laws that forbid sexual contact between consenting adults, sodomy, or private homosexual activity. The right to confidentiality, freedom of sexual orientation, and consenting to carnal behaviour were all upheld in this case. Although the legal approach to unmarried couples varies by state, the recognition of the ability to make private decisions regarding sexuality braced the just to cohabitation. In Martin v.

Ziherl42, the Virginia Supreme Court ruled that the state's antifornication laws are unconstitutional under the US Constitution's Fourteenth Amendment. Florida eliminated the criminal laws that classified cohabitation as a misdemeanour in 2016. Michigan and Mississippi forbid cohabitation between couples of different sexes. Despite California's ban on common law marriage, "domestic partners" are recognized, and a Domestic Partners Register has been set up. The state of California Family Code states that: (1) The parties are over the age of eighteen; (2) The domestic partnership may be endorsed by both parties; and (3) It is prohibited for partners who have no relatives by blood to get married.

41 Lawrence v. Texas,539 U.S. 558 (2003).

42 Martin v. Ziherl, 607 S.E.2d 367 (Va. 2005).

The individual in question is not an element of another home connection or has any obligations with another person as if they were married. However, maintaining stability in these relationships at home in the USA remained challenging and frequently resulted in civil litigation. The British Empire During the Victorian era, cohabitation was frowned upon due to stringent morality. It's fascinating to note that single moms give birth to over half of all infants born in the UK nowadays. The United Kingdom A growing number of unmarried births have led to political pressure to alter the current legal

framework. The primary question that needs to be answered right now is if the State should provide incentives to encourage marriage or if it ought to put the status of the parents over the status of a spouse. Scotland passed cohabitation laws at a faster pace than Wales and England. A spouse may file a lawsuit for financial support in 43Section 28 of this legislation. Scotland

provided legal status to live-in partnerships in 2006, considering the duration of cohabitation, the kind of relationship, and the finances arrangements. An unattached father in the nation is considered to have a parental duty if his name is on the birth certificate. Suggestion Recognizing the pressing need to formalize live-in relationships through legislation, it is imperative to empower all involved parties with rights and establish clear obligations, thereby defining the parameters of such relationships. In light of this, several recommendations emerge as essential considerations. Firstly, any legislation on live-in relationships is crafted with due consideration for the foundational structure of traditional values prevalent in Indian society. Family law experts advocate for the adoption of written cohabitation agreements, akin to pre-marital agreements or legally binding contracts.

These agreements comprehensively address various aspects, including the division of expenses, property ownership, the management of separate or joint 43 Barbara Stark, Domestic Partnerships and Same-Sex Marriage Family Law in the World Community, 2d ed. 211-246 (2009).

bank accounts, and explicit provisions for the distribution of assets in the event of separation or the demise of one partner. Property acquired during cohabitation, such as a house, furnishings, or movable valuables, may become contentious if the couple decides to part ways or if one partner passes away. To mitigate legal complications, the cohabitation agreement must distinctly stipulate each party's entitlements. In cases involving cohabiting parents, legal intricacies may arise concerning children born within such relationships. It is imperative for unmarried couples to establish paternity or maternity through legally recognized documents, legitimating their parental relationship. Active involvement in raising the child is crucial for claiming custody or visitation rights.

Legitimation also holds significance for inheritance purposes, and the establishment of a written will is deemed the most effective means to ensure the rightful distribution of assets to children. Furthermore, proposing legal recognition for live-in relationships after a specific duration has transpired emerges as a key recommendation. This would afford the couple and any children born within the relationship legal rights equivalent to those of a married couple and their legitimate children. This includes entitlements to maintenance, custody, inheritance, and succession. Importantly, such legal status must also safeguard the rights of all parties in the event of the relationship dissolving due to a breakup or the death of a partner.

In addressing the contemporary challenges posed by live-in relationships, there is a call for the enactment of new legislation specifically tailored to investigate and navigate the unique issues these relationships present. This legislation should grant explicit rights and obligations to the involved parties, thereby curbing the misuse of existing laws and mitigating instances of violence, particularly faced by female partners in such relationships. While advocating for legal status for live-in relationships, it is imperative to strike a balance. Not all the benefits accorded to marriage necessarily are extended. Reasonable restrictions should be integrated into the legislation to safeguard the rights of all affected parties, preventing situations where a married individual claims a live-in relationship without legal ramifications.

Striking this balance ensures that the legal framework aligns with the evolving dynamics of relationships while upholding the principles of justice and fairness.

Conclusion In the realm of legal exploration into live-in relationships, our research underscores the delicate equilibrium between the inherent benefits of such unions—providing couples the opportunity to intimately acquaint themselves with one another and the autonomy to disengage—and the array of societal and legal challenges that disproportionately impact women within these arrangements. The evolving landscape of social values and norms necessitates a nuanced understanding, punctuated by the issuance of guidelines by the Supreme Court aimed at both regulating these relationships and safeguarding the rights of women and children ensconced within their folds. Our legal investigation highlights the enduring significance of the concept of marriage as a foundation for upholding social order, even as it acknowledges the tides of changing societal acceptance.

Beyond the mere recognition or regulation of live-in relationships, the focus must extend to fostering positive, affectionate, and meaningful connections. As a legal scholar, I posit that directing attention towards cultivating relationships that promote well-being holds paramount importance, eclipsing the potential drawbacks of remaining in isolation or enduring partnerships characterized by discontent, negativity, and turmoil. Drawing inspiration from Friedrich Nietzsche's timeless aphorism, the conclusion is aptly framed: within the confines of legal discourse on live-in relationships, there exists a symbiotic relationship between reason and passion. This delicate interplay encapsulates the multifaceted nature of love and its intersection with the pursuit of societal harmony.

In essence, the legal landscape must not only grapple with the intricacies of regulation but also strive towards an understanding that embraces the complexities of human relationships, ensuring that the legal framework contributes to the cultivation of positive and meaningful connections in the everevolving tapestry of societal dynamics. This has been possible largely because the Supreme Court enjoys a unique prestige and legitimacy in India. There are few other institutions that are respected as much as it is, even if one disagrees with its decisions. It has therefore been able to expand the fundamental rights by relying on the moral authority it has. The Court regularly intervenes in matters of public interest through its judgements and orders. In fact, these days, even casual observations of judges on the Bench make front-page news.

However, the actual judgements of the Supreme Court and their impact on society are not fully understood or appreciated by the general public. Information about the Court’s judgements are heavily edited by newspapers and electronic media, or in some cases completely misinterpreted on social media. In the process of dissemination of information to the public, there is almost a game of Chinese whispers. The powers of the Court and what it actually decides gets transformed into something quite different from what the Court actually held. It is hoped that this book will help the general public better appreciate the issues at stake and how the Court shapes the discussion around them.

References • Acharya, Kalika and Udgata, Sankalp, Live-In-Relationships in India and Their Impact - A Sociological Study (September 10, 2019). Available at SSRN: https://ssrn. com/abstract=3451288 • Margaret Mahoney, Forces Shaping the Law of Cohabitation of Opposite Sex Couples, 7 Journal of Law & Family Studies 135 (2005). Available at: https://scholarship. law. pitt. edu/fac_articles/268 • Shinde, Dhananjay and Shinde, Saniya, A Comparative Study of The Law of Cohabitation In Scotland and India (July 7, 2022). Available at SSRN: http://dx. doi. org/10. 2139/ssrn. 4156031 • https://ncert. nic. in/textbook/pdf/keps210. pdf • https://journals. sagepub. com/doi/10. 1177/2631831820974585 • https://doi. org/10. 1177/2631831820974585 • https://ijcrt. org/papers/IJCRT2108495. pdf • Funk, Derek Robert, "The Role of Law: How Law Shapes and Alters the Foundations of Societies" (2011).

https://digitalcommons. usu. edu/honors/75 • https://hcommons. org/deposits/view/hc:45416/CONTENT/a-research-study-onlive-in-relationships-in-india-cslr. pdf/ • https://dejurenexus. com/wp-content/uploads/2021/05/Rights-of-a-Child-Born- Out-of-a-Live-In-Relationship-By-Devina-Row. pdf • https://ncert. nic. in/textbook/pdf/keps201. pdf • Pardeep Singh And Another vs State of Haryana And Others https://indiankanoon. org/doc/185916918/#:~:text=Learned%20State%20counsel% 20submits%20that,treated%20as%20a%20basic%20feature.

https://doi.org/10.1093/acprof:oso/9780195366815.003.0012 • Bendale, Dr. Ujwala and Dubey, Rashmi and Girme, Anuradha, Live-In- Relationship vis-à-vis Sanctity of Marriage (January 5, 2022). Available at SSRN: http://dx.doi.org/10.2139/ssrn.4001839 • Meister v. Moore https://supreme.justia.com/cases/federal/us/96/76/ • Lind, Göran, 'The Common Law Marriage Contract', Common Law Marriage: A Legal Institution for Cohabitation (New York, 2008; online edn, Oxford Academic,1Jan.2009), https://doi.org/10.1093/acprof:oso/9780195366815.003.0006 • Doyle, D. M., & Molix, L. (2014). Love on the Margins: The Effects of Social Stigma and Relationship Length on Romantic Relationship Quality. Social Psychological and Personality Science, 5(1), 102-110. https://doi.org/10.1177/1948550613486677 •

D.

Velusamy vs. D.

Patchaiammal (10

SCC

469). 2010. https://indiankanoon.org/doc/1521881/ Accessed 23 October 2023. • Dr. Justice V.S. Malimath Report. Committee on Reforms of Criminal Justice System. Government of India, Ministry of Home Affairs. Report Vol I; March 2003. https://www.mha.gov.in/sites/default/files/criminal_justice_system.pdf. Accessed 23 October 2023. • PROBERT, R. (2009). Common Misunderstandings [Review of Common Law Marriage: A Legal Institution for Cohabitation, by G. Lind]. Family Law Quarterly, 43(3), 587–597. http://www.jstor.org/stable/25740716 • Barbara Stark, Domestic Partnerships and Same-Sex Marriage Family Law in the World Community, 2d ed. 211-246 (2009) Available at: https://scholarlycommons.law.hofstra.edu/faculty_scholarship/421 • Supreme Court of India. https://main.sci.gov.in/supremecourt/2022/36593/36593_2022_1_1501_47792_J

udgement_17-Oct-2023.pdf • https://main.sci.gov.in/supremecourt/2022/36593/36593_2022_1_1501_47792_J udgement_17-Oct-2023.pdf