Family law

RESEARCH PAPER:

Live in relationships-

Recognition in Hindu personal laws


Ankit Tiwari
130958011
BBA LLB 2
nd
year
Acknowledgement

The author is highly obliged to Sharda University for providing him, an opportunity to
research on a topic of such a contemporary relevance. This opportunity in the form of a
component of internal assessment has been extremely enriching and given him the
requisite impetus to improve his understanding and other nuances in the field of Family
Law.
The author is highly indebted to Mrs. Namita Singh Malik who has been a guiding light
in preparation of this paper and shared her views and for guiding me during many
interactions.










ABSTRACT

A country like India is slowly becoming inclined towards western culture and idea, one of which is the
idea of live in relationship which is of relevance to this paper. Live-in relationships in India are often
seen as a taboo and a sin. This trend is increasing especially in the metropolitan cities and urban areas.
According to Manu, premarital relationships existed in ancient times but were a rare occurrence. This
concept of live-in relationship is not new in India; it was earlier known as maitri-karar in which a
written agreement was made between the two opposite sex that they would live together as friends and
look after each other.
Such relations was criticized as destroying the sacred institution of marriage. Due to modernization and
liberal thinking there has been a transformation towards a new concept namely live in relationship. Law
plays an indispensible role for social change and the Indian judiciary has shown a right path for the
progress of the society relating to the concept of live in relationship. Live in relationship basically is
when two consenting adults of opposite sex (married or unmarried) live together without tying the knot
of marriage for a long period of time.
The main issue dealt with in this paper is whether such relationships are recognized under Hindu
personal laws, the legitimacy, guardianship and inheritance rights of children born out of such relations,
protection of woman in such relationship relating to maintenance and domestic violence and compare
the status of live in relationship with that of marriage. Furthermore, this paper also discusses the judicial
attitude towards such relations and whether there is a need to legalize it. In addition, some suggestions
have been made to improve the womans position in such relations. In conclusion it highlights the fact
that it is difficult if not impossible to fit the concept of live in relationships within personal laws
governing the institution of marriage and its related aspects.



Introduction

Aim and objectives The relevant objective of this paper is to understand the extent of
recognition of live in relationship in the Hindu personal laws. It aims to explain with clarity the judicial
attitude towards live in relationship in the Indian scenario. It helps in knowing the problems arising from
such relations and touches upon the societal attitude towards live in relationship.
The purpose and objective of this paper is to enumerate how the live in relationship has become a
reincarnation of marriage in the modern era. Basically the aim and objective of this paper is not to
criticize or support live in relationship but is only a critical examination of the contemporary issue
dealing with the concept of live in relationship. The quality of content in this paper is useful in better
understanding of the above mentioned objectives.

Scope- This paper has been developed taking into account the recent trends in the modern scenario.
This topic is of indispensible importance because the extent of its recognition should not harm the
institution of marriage. The scope of this paper is limited to the Indian perspective alone. The rights of
women, rights of children born out of such relationships and the impact of status of live in relationship
with status of married couples is also included in the scope of this paper. Also, the discussion dealt with
in this paper is only with respect to the Hindu personal laws.





Research questions-


1) Should live in relationship be legalized? If so, what are the consequences of legalization of such
relationship on married partners? Should a new law be made in India to regulate such kind of
relationship?

2) What is the status of children in the eyes of law(legitimate or illegitimate) with respect to right to
maintenance, guardianship and custody and inheritance rights of children born out of live in
relationship? What is the status of live in relationship with that of married couples in the above aspects?

3) What is the status of women in live in relationship with respect to maintainence, marriage and
divorce?

4) Whether the Indian society is prepared to accept such new kind of relationship


1) Whether the Indian society is prepared to accept such new kind of relationship?
Some of the traditional people of the society are of the view that it encourages extra-marital relationship
and casual sexual relationship, out of wedlock, which will dilute the concept of holy marriage or scared
union thereby causing damage to the age old-family values practiced by Hindus since time immemorial.
They are of view that losing virginity is sin as per customary law, in Mythology Kunti abounded Karna
,because he was born out of wedlock. The Rama is ideal husband and Sita is ideal wife. Many are of
view that if live-in relationship is encouraged, it will increase teenage and child pregnancy, HIV,
children born out of wedlock may be not properly brought up, which will lead to juvenile delinquency. It
will have adverse impact on the society. They feel that all this has destroyed the institution of marriage.
But the fact is that Hindu Marriage laws are no more religious law or customary law, it has assumed
secular character after codification in 1956.
Some liberal thinking people of the society who have an open mind set accepted the concept of dating
,which is prevailing in cities and towns and the reality that most young dating couples are entering into
live-in relationship to test their compatibility to each other ,the cohabitation (and other conjugal aspects)
will allow them to understand each other well ,which will help them to take decision for permanent
commitment through legal marriage and legalize relationship by entering into legally valid marriage. It
is better to opt for live-in relationship than going for divorce; this is basic logic of live-in relationship.
This purely western concept of relationship based individualism; primary motive is more freedom,
monetary independence, non-interference of their personal affairs and career.
1

Hence, society has people who accept the concept of live in relationship and some who are against it
saying detrimental to the sacrament of marriage.

2) Should live in relationship be legalized? If so, what are the consequences of
legalization of such relationship on married partners? Should a new law be made in
India to regulate such kind of relationship?
There is no special law in India to deal with the concept of live in relationships. The Courts in India,
through their decisions in different cases, have laid down the law in respect of such relationships. It is
argued that it is better if live in relationship is not legalized because
In the debate in the Lok Sabha on 15th December, 2008 in the question hour, Mr.H.R.Bhardwaj ,
Honble Union Law Minister while answering to the question related to live-in-relationships said that if
live-in- relationships are acceptable by society, then the government can make laws. Laws are made
keeping in view societal trends. It is hypothetical to ask a question whether we are contemplating a law
to govern live-in relationships. Less than one percent of the people are in such relationships. If a law is
enacted, it will only be misused.
2

In this regard we should not blindly follow what is happening in other countries because the societal
structure of our country is different from them. At the same time we should not ignore to consider the
real pulse of our society in the light of progress of the society. Therefore it is not useful to see the legal
trend in India as imitating the western model.

3) What is the status of children in the eyes of law(legitimate or illegitimate) with
respect to right to maintenance , guardianship and custody and inheritance rights of

1
http://legalgensis.blogspot.in/2011/09/live-in-relationship-legality.html
2
http://www.Indialawjournal.com/volume2/issue_2/article_by_saakshi.html
children born out of live in relationship? What is the status of live in relationship
with that of married couples in the above aspects?
Section 112 of the Indian Evidence Act, 1872
3
provides that legitimacy of a child is proved only if he
or she was born during the continuance of a valid marriage between his mother and father but the
Supreme Court in Tulsa v. Durghatiya
4
held that children born out of such a relationship will no more be
considered illegitimate.
5
Again in Vidhyadhari v. Sukhrana Bai,
6
the Supreme Court held that even if a
person had contracted into second marriage during the subsistence of his first marriage, children from
the second marriage would still be legitimate though the second marriage would be void.
Since there is no specific law that recognizes the status of the couples in live in relationship, hence the
law as to the status of children born to couples in live in relationship is also not very clear.

The Hindu marriage Act, 1955 gives grants the status of legitimacy to every child irrespective of his
birth out of a void, voidable or a legal marriage. But there is no specific law that raises any presumption
of legitimacy in favour of children of live in partners. The future of children of live in partners becomes
very insecure in case the partners step out of their relationship. There comes the requirement of a strong
provision to safeguard the rights of such children. The must be provision to secure the future of the child
and also entitling the children to a share in the property of both the parents.

Again in the absence of a specific legislation, the Supreme Court of India took the initiative to safeguard
the interest of children of live in couples. In the case of Bharata Matha & Ors. vs. R. Vijaya
Renganathan & Ors., the Supreme Court of India has held that child born out of a live-in relationship
may be allowed to succeed inheritance in the property of the parents, if any, but doesn't have any claim
as against Hindu ancestral coparcenary property.
At present there is no specific legislation that deals with concept of live in relationship and the rights of
the parties and the children of the live in partners. Through its various decisions the judiciary has tried to
accord legality to the concept and protect the rights of the parties and the children of live in couples. But
at present there is a need to formulate a law that would clarify the concept. There should be clear
provisions with regard to the time span required to give status to the relationship, registration and rights
of parties and children born out of it. The utmost need of the hour is to secure the future of the children

3
Birth during marriage, conclusive proof of legitimacy.- The fact that any person was born during the continuance of a valid marriage
between his mother and any man, or within two hundred and eighty days after its dissolution, the mother remaining unmarried, shall be
conclusive proof that he is the legitimate son of that man, unless it can be shown that the parties to the marriage had no access to each
other at any time when he could have been begotten.
4
(2008) 4 SCC 520
5
Mohd. Bauker v.Shurfoon Nissa Begum, (1859-61) 8 MIA 136
6
(2008) 2 SCC 238 : (2008) 1 SCC (L&S) 451
born to live in couples. The steps taken by the judiciary are indeed welcoming and pragmatic in
approach. Though the live in relations provide the individuals individual freedom but due to the
insecurity it carries it with, there needs to be a law to curtail its disadvantages.
A legitimate son, son of predeceased son or the son of predeceased son of predeceased son, so long as he
is minor, and a legitimate unmarried daughter or unmarried daughter of the predeceased son or the
unmarried daughter of a predeceased son of predeceased son, so long as she remains unmarried, shall be
maintained as dependants by his or her father or the estate of his or her deceased father.
7
But children
from live-in relationships do not enjoy this right under the Hindu Adoptions and Maintenance Act 1956,
whereas Section 125 of the Code of Criminal Procedure provides maintenance to children whether
legitimate or illegitimate while they are minors and after they attain majority where such child is unable
to maintain himself. However, the right to maintenance of children born from a live-in relationship was
upheld in 2007, in Dimple Gupta v. Rajiv Gupta.
8

In Hindu law, after the marriage of a man to a girl who is a legal minor, the husband is the legal
guardian of his wife as a minor and is entitled to her custody. The mere fact that she is a minor will not
disentitle her from claiming such custody to the exclusion of her parents.
9
Where the father and the
mother are not married to each other and a child is born to such parents, the mother and not the father
has the parental responsibility for the child.
10
Section 6(a) of the Hindu Minority and Guardianship Act
1956 provides the father as the natural guardian of his minor legitimate children and the mother becomes
the natural guardian in his absence i.e. where he is incapable of acting as the guardian.
11
Section 6(b)
of the Hindu Minority and Guardianship Act 1956 provides the mother as the natural guardian over any
illegitimate children she has.
While deciding a matter on custody, the court takes into account the welfare, age, sex and the wishes of
the child as well as the wishes of his parents; the welfare of the child shall be the paramount
consideration.
12
This applies even in custody cases involving children from live-in relationships.
Inheritance rights of children
Under Hindu law, an illegitimate child inherits the property of his mother only and not putative father.
If children from a live-in relationship were to still be considered illegitimate,86 inheritance from the
father's estate would be barred. In fact, where the live-in relationship has not subsisted for a reasonable
period of time, the courts would not consider a child from such relationship to be legitimate, thereby
barring his inheritance. However, where the live-in satisfies this condition, a child being legitimate

7
Section 21, The Hindu Adoptions and Maintenance Act, 1956
8
(2007) 10 SCC 30: (2008) 1 SCC (Cri) 567
9
Prof. Vijender Kumar, Live-In Relationship : Impact on Marriage and Family Institutions, (2012) 4 SCC
J-19 at p. J-19
10
Natural guardians of a Hindu minor, Section 6, The Hindu Minority and Guardianship Act, 1956
11
Githa Hariharan v. RBI, (1999) 2 SCC 228
12
Section 13, The Hindu Minority and Guardianship Act, 1956
can inherit from both the parents. In Revanasiddappav. Mallikarjun,87 the Supreme Court granted the
inheritance to the four children born from the woman with whom the man shared a live-in relationship,
calling them his legal heirs. The Court has thus ensured that no child born from a live-in relationship
of a reasonable period may be denied their inheritance.88
13

4) What is the status of women in live in relationship with respect to maintenance,
marriage and divorce?
Status of women with respect to marriage:
The Supreme Court in Lata Singh v. State of U.P
14
held that the live-in relationship is permissible only
in unmarried persons of heterosexual sex of the age of majority. The brothers of Lata Singh had alleged
that she was mentally unfit when they had protested her marriage. However this was held to be untrue
when she was examined by doctors. The live-in relationship if continued for such a long time, cannot be
termed as a walk in and walk out relationship; there has to be a presumption of marriage between
them.
15
In Gokal Chand v.Parvin Kumari
16
the court cautioned that the couple would not get legitimacy,
if the evidence of them living together was rebuttable. These decisions only served to recognize
marriages which were doubted, on the basis that a long-term live-in relationship existed. However the
courts did not recognize live-in relationships as independent of the institution of marriage, that is the
presumption of marriage was a key element.
In S.P.S. Balasubramanyam v. Suruttayan
17
the Supreme Court held that if a man and woman are living
under the same roof and cohabiting for a number of years, there will be a presumption under Section
114
18
of the Indian Evidence Act that they live as husband and wife and the children born to them will
not be illegitimate.
19
This decision suggested that the law treats long live-in relationships as good as
marriages. The courts could subsequently interpret live-in relations to mean living together as husband
and wife
20
to exclude those who enter into a live-in relationship by choice without intending to be
married, as that is still a matter of doubt and debate.
21

Maintenance:

13
http://www.westminsterlawreview.org/wlr19.php
14
(2006) 5 SCC 475 : (2006) 2 SCC (Cri) 478
15
Madan Mohan Singh v. Rajni Kant, (2010) 9 SCC 209:(2010) 3 SCC (Civ) 655; A. Dinohamyv. W.L.
Balahamy, AIR 1927 PC 185 : (1928) 1 MLJ 388
16
AIR 1952 SC 231
17
1992 Supp (2) SCC 304
18


Court may presume existence of certain facts, Indian Evidence Act, 1872
19
Tulsa v. Durghatiya, [(2008) 4 SCC 520
20
S Khushboo v. Kanniammal & Anr, AIR 2010 SC 3196
21
Prof. Vijender Kumar, Live-In Relationship : Impact on Marriage and Family Institutions, (2012) 4 SCC
J-19 at p. J-19
The Supreme Court in Yamunabai Anantrao Adhav v. Anantrao Shivram Adhav
22
held that where a man
having a living lawfully wedded wife marries another woman, his second wife had no claim to
maintenance under Section 125 of the Code of Criminal Procedure, 1973
23
, even though she might be
unaware of his earlier marriage. The Court refused to give any recognition to the fact that they had lived
together even if their marriage was void. The man was allowed to take advantage of this, although he
had failed to disclose his earlier marriage. The Supreme Court held that it would not grant any rights to
the woman in such a live-in relationship of circumstance.
24
In Malti v. State of U.P
25
, the Allahabad
High Court held that a woman living with a man could not be equated as his wife. In this case, the
woman was a cook in the man's house and she stayed with him and shared an intimate relationship. The
Court however refused to extend the meaning of the word wife as denoted in Section 125 of the Code
of Criminal Procedure
26
to include such a live-in partner's maintenance claims.
In Savitaben Somabhai Bhatiya v. State of Gujarat,
27
the Supreme Court went further to the extent of
observing that the fact that the respondent was treating the appellant as his wife is really
inconsequential because it is the intention of the legislature which is relevant and not the attitude of the
party. Even the plea that the appellant was not informed about the respondent's earlier marriage, when
she married him, is of no avail, because the principle of estoppels cannot be pressed into service to
defeat the provisions of Section 125 of the Code of Criminal Procedure.44 Thus, as per the present
provisions of Section 12545 , there is no escape from the conclusion that the expression wife refers
only to the legally wedded wife. Hence, the Court granted maintenance to the child and not to the
second wife. Under the law a second wife whose marriage is void on account of the survival of the first
marriage is not a legally wedded wife, and is, therefore, not entitled to maintenance under this
provision.46
In Narinder Pal Kaur Chawla v. Manjeet Singh Chawla,47 the Court took a liberal view and stated that
the second wife has a right to claim maintenance under the Hindu Adoptions and Maintenance Act,
1956.48 In this case the husband had not disclosed the facts of his first marriage and married the
appellant and maintained a relationship with her for 14 years as husband and wife. The Court also took
support from the provisions of the Protection of Women from Domestic Violence Act, 2005,49 and held
that if we do not give maintenance to the second wife it would amount to giving premium to the
respondent for defrauding the appellant.50
The Supreme Court in Rameshchandra Rampratapji Daga v. Rameshwari Rameshchandra Daga51 tried
to distinguish between the legality and morality of relationships. Where the Supreme Court

22
(1988) 1 SCC 530 : 1988 SCC (Cri) 182
23
Order for maintenance of wives, children and parents, Code of Criminal Procedure, 1973
24
Prof. Vijender Kumar, Live-In Relationship : Impact on Marriage and Family Institutions, (2012) 4 SCC
J-19 at p. J-19
25
2000 Cri LJ 4170 (All)
26
Order for maintenance of wives, children and parents, Code of Criminal Procedure, 1973
27
[(2005) 3 SCC 636; 2005 SCC (Cri) 787
observed that keeping into consideration the present state of statutory law, a bigamous marriage52 may
be declared illegal because it contravenes the provisions of the Hindu Marriage Act, 1955 but it cannot
be said to be immoral so as to deny even the right of alimony or maintenance to spouse.53
The increasing incidents of live-in relationships, especially those which occur by circumstance,
however ensured that the need for reforms was recognized. In 2003, the Malimath Committee Report on
Reforms in the Criminal Justice System suggested an amendment of the word wife in Section 125 of
the Code of Criminal Procedure to include a woman who is living in with a man for a reasonable
period.54 Ironically, back in 1985, the Supreme Court in Sumitra Devi v. Bhikan Choudhary55 had
held that where a man and woman were cohabiting for a long time and were treated by society as
husband and wife, marriage is to be presumed for awarding maintenance. However, the courts have not
extended this principle to include purported live-in partners. Significantly, the Protection of Women
from Domestic Violence Act 2005 became the first statute to give live-in partners the same recognition
as married couples. The protection under this Act does not qualify live-in partners to get the same
benefit under personal law.56
In M. Palani v. Meenakshi57 the respondent had filed a claim for maintenance of Rs 10,000 for food,
clothes, shelter and other basic necessities from the plaintiff, who had been in a live-in relationship with
her. The said application was filed under Section 2058 read with Section 26.59 The petitioner contended
that the respondent was not entitled to any maintenance since they had not lived together at any point of
time. They had only indulged in consensual sexual intercourse sometimes as friends, without any
thought of marriage. He hence contended that mere proximity at some time for the sake of mutual
pleasure (as in their case) could not be called a domestic relationship60 to invite the application of the
Protection of Women from Domestic Violence Act, 2005.
The Madras High Court looked into the definition of domestic relationship as given in Section 2(f) of
the Protection of Women from Domestic Violence Act, 200561 which did not specify that the couple
should have lived together for a particular period for the relationship to be a domestic relationship. The
Court held that at least at the time of having sex by them, they shared household and lived together. 62
The Court further held that the provisions of the Act would apply even in such a case; hence, a
maintenance claim under the Act was upheld. Thus the provisions of the Act would apply even in those
cases where man and woman share a frequent sexual relationship, even if there is no express intention to
a long-term commitment from either party. While some may see this as a weapon which may be used by
a woman to seek vengeance on a man, if he walks out of a soured live-in relationship, a larger issue of
protecting the rights and vulnerability of the other woman has been partially addressed by allowing
such claims.63
Partners in a live-in relationship do not enjoy an automatic right of inheritance to the property of their
partner. The Hindu Succession Act 1956 does not specify succession rights to even a mistress living
with a male Hindu. However, the Supreme Court in Vidhyadhari v. Sukhrana Bai64 created a hope for
persons living together as husband and wife by providing that those who have been in a live-in
relationship for a reasonably long period of time can receive property in inheritance from a live-in
partner. In this case property of a Hindu male, upon his death (intestate), was given to a woman with
whom he enjoyed a live-in relationship, even though he had a legally wedded wife alive.65
Divorce:
Women in live-in relationships are not recognized by their husband's surname, for any legal or financial
matters including opening a bank account, submission of income tax return, applying for loans, etc.66
They retain their identity as an individual and are not recognized as a wife67 or a domestic
partner.68Consequently live-in couples can separate informally without any formal divorce69 or the
intervention of a court.70 In case of live-in relationship, it is not possible to have a formal divorce in law
among partners. The careful scrutiny of the existing matrimonial laws indicates that unless this kind of
relationship is not recognized in law the partners cannot be allowed to separate formally. It looks like it
is easy to get into live-in relationship whether by choice or by circumstance but difficult to get out
of this relationship formally. Whereas the consequences of this relationship are left unanswered in law,
for example, there is no law in place which deals with the division and protection of their separate or
joint property on separation.
28

CONCLUSION
With the emergence of increase in trends of live in relationship there has been many debates whether to
amend the existing laws or not. There requirement of legalizing live in relationship has faced many
criticisms and any laws to protect women and children from such live in relationship must carefully
expressed by the courts. Personal laws differ for various communities on different matters and to fit in
live-ins into each of these aspects would be a difficult and complex exercise.
As seen from the analysis above through research it is clear that live in relationship are not equivalent to
marriage. Live-ins may thus entirely fit into personal laws only if they were given an equivalent status as
married spouses. The trend of Indian judiciary is not consistent with regard to recognition of such
relationships. But in so far as the protection of the claims of women in such relations is concerned, the
Indian judiciary is firm in its stand to render justice to the vulnerable section of the society.
On understanding the judgment given by different courts it is clear that Indian judiciary is neither
expressly encouraging nor prohibiting such kind of live-in-relationships in India. The judiciary is only
rendering justice in accordance with law in a particular case. The main concern of the judiciary is to
prevent the miscarriage of justice.
It has long been understood that law has to change with the times and reflect the dynamism of social
realities for it to be workable and fair. Legislation and legal principles have to be objective while
protecting the fundamental rights of a person as envisaged under the Constitution of India. Lastly, as

28
http://www.westminsterlawreview.org/wlr19.php
Flavia Agnes, a feminist activist stated, in light of the rights granted to same-sex couples
29
and
recognition of property rights of illegitimate children, there hardly seems to be any rationale behind
subjecting women in live-in relationships to unnecessary hardships. Whatever the stance on the moral
debate may be, it cannot outweigh basic human rights and the fundamental rights of women.
30

While women in a matrimonial relationship have legal recourse available to them, women in live-in
relationships do not have many options. It is not difficult to see that the rights of the woman in a
matrimonial relationship have come from the approval society has granted to marriage as an institution.
On the other hand, the rights of women in live-in relationships are still considered revolutionary in the
Indian society.

Suggestion
Live-in relationship is neither a crime nor a sin though socially unacceptable in this country. Long-
standing relationship as a concubine, though not a relationship in the nature of a marriage may deserves
protection because that woman might not be financially independent, but we are afraid that DV Act does
not take care of such relationships which may perhaps call for an amendment of the definition of Section
2(f) of the DV Act, which is restrictive and Exhaustive.
The Supreme Court in a number of cases has stated that where there is cohabitation for a reasonable
period of time, the couple shall be presumed to be leading a married life and shall enjoy such rights.
However, the Court has not defined how much time should be considered to confer the marital status on
such relationships. It needs the immediate attention of the lawmakers to make it clear through suitable
legislation otherwise different couples may be subjected to different yardsticks when they seek their
rights.
An amendment to Section 125 of the Code of Criminal Procedure could be one such example that would
bring a uniform law, which would outline the rights, duties and responsibilities of such couples. Such a
law could define those couples that to whom it applied (in terms of length of cohabitation), recognize the
two kinds of live-in relationships and provide remedies accordingly, in the same manner as the
Protection of Women from Domestic Violence Act, 2005.
31
Merely spending weekends together or
one-night stand would not make it a domestic relationship, because parliament has used the expression

29
Naz Foundation v. Delhi, WP(C) No.7455/2001
30
2 Warwick Student L. Rev. 54 2012
31
Deepak Lal, India: Population Change and Its Consequences, Population and Development Review,
The Political Economy of GlobalPopulation Change, Vol. 32, 1950-2050 (2006) at p.173
relationship in the nature of marriage it is necessary to understand society with its changing colours
and provide laws which are practicable and enforceable to tackle these complex issues.
32

Live-in-Relation would give rise to child pregnancy and has far reaching ramifications, adding despite
its aim to restrict multiple partners. It would have an adverse impact on the youths and result in the
spread of HIV/Aids. Therefore, awareness amongst youth is most important.



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