Recently, the Supreme Court of India in Public Interest Foundation v. Union of India 2018, has issued certain directions to deal with criminalization in politics in India.

It has been long observed that persons with extensive criminal backgrounds have been contesting national or state elections in India and in few cases, have become legislators as well. As per the National Commission to Review the Working of the Constitution (NCRWC) India, some of the electoral candidates even had charges of serious criminal offences against them including murder, attempt to murder, rape, crimes against women, etc.

The Supreme Court herein held that in order to ensure that there is free and fair democracy, the electoral candidates should possess high integrity and morality. Further, that allowing electoral candidates with criminal antecedents to contest elections, would mean interference with the purity and integrity of the electoral process and violation of a voter’s freedom to choose freely a candidate, thereby adversely affecting the democracy of the country.

According to the Supreme Court, A political party which does not respect democratic principles in its internal working cannot be expected to respect principles in the governance of the country.

According to the Representation of People Act, 1951 as amended thereof, political members are disqualified only after conviction. But the time consuming trials often delay the convictions, if any and as a result of which, it becomes difficult to prevent the growing criminalization in politics.

Therefore, the Supreme Court herein, has issued the following directions in a bid to strengthen the democratic set-up in India:

Each contesting candidate shall fill up the form as provided by the Election Commission and the form must contain all the particulars as required therein.

It shall state, in bold letters, with regard to the criminal cases pending against the candidate.

If a candidate is contesting an election on the ticket of a particular party, he/she is required to inform the party about the criminal cases pending against him/her.

The concerned political party shall be obligated to put up on its website the aforesaid information pertaining to candidates having criminal antecedents.

The candidate as well as the concerned political party shall issue a declaration in the widely circulated newspapers in the locality about the antecedents of the candidate and also give wide publicity in the electronic media. When we say wide publicity, we mean that the same shall be done at least thrice after filing of the nomination papers.

The Supreme Court has, further, suggested that the Parliament of India should soon enact a legislation to ensure that persons facing serious criminal charges do not enter into the political stream.

Daliparthy Harini

Senior Legal Associate

The Indian Lawyer


Arifa Khan

PG College of Law, Osmania University

Intern at The Indian Lawyer

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Recently, there has been a huge uproar about sexual harassment of women at workplace including film and media industry, whereby a number of actors and journalists have raised their voice against the indecent or undesirable behavior or acts committed by other film actors and journalists against them.

This led to an announcement by the Minister for Women and Child Development in India, Mrs. Maneka Gandhi, to appoint committees that will look into the allegations of sexual harassment of women at workplace.

The committees may be constituted under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 as amended thereof (the Act). This Act is based on guidelines issued by the Supreme Court of India in Vishaka and others vs. State of Rajasthan and others 1997.

The Supreme Court in the said case of Vishaka and others vs. State of Rajasthan and others 1997, had laid down certain guidelines to be observed by all employers or other responsible persons at workplaces to ensure prevention of sexual harassment of women at workplaces and to preserve and enforce the right to gender equality of working women (Guidelines):

Duty of an employer to prevent or deter the commission of acts of sexual harassment and to also provide for procedures for resolution, settlement or prosecution of acts of sexual harassment.

Sexual harassment includes unwelcomed sexually determined behavior such as physical contact and advances, demand or request for sexual favors, making sexually colored remarks, showing pornography, any other unwelcome physical, verbal or non-verbal conduct of sexual nature (Sexual Harassment).

Immediate action to be taken by an employer against the offender and ensure that the victims or witnesses of Sexual Harassment incidents are not discriminated or mistreated and victimized.

Establishment of an appropriate complaint mechanism and complaints committee headed by a woman for redressal of complaints related to Sexual Harassment incidents at workplaces.

Such a complaint committee would have to prepare an annual report about the cases filed and disposed of pertaining to Sexual Harassment incidents at workplaces and submit the same to the concerned government department.

Awareness to be increased by employers regarding the rights of female employees and the Guidelines or law in that regard.

The Central/State Governments have to ensure that the Guidelines or law in that regard are followed by employers, etc.

The Act provides for protection against Sexual Harassment of women at workplace and for the prevention and redressal of complaints of Sexual Harassment, etc:

Workplace- Any Government establishment and/or private sector enterprise, non-governmental organisation, hospital, sports institute, any other place visited by employee during course of employment including transportation provided by employer, a house or dwelling place would come under the purview of a workplace (Workplace).

Prevention- Apart from prevention of Sexual Harassment, the Act also provides for prevention of acts of promise of preferential treatment, threat of detrimental treatment, creation of intimidating or hostile work environment, etc.

Committee- The Act provides for setting up of an internal complaints committee by an employer, local complaints committee by Government in every district, etc where an aggrieved woman can file her complaints of Sexual Harassment at Workplace within 3 months of the date of incident, which may be extended by the committee concerned if they are satisfied that circumstances were such which prevented the aggrieved woman from filing the complaint.

Settlement or inquiry- The committee concerned may settle the matter, failing which, it may conduct an inquiry into the matter and/or register a case with the police.

Daliparthy Harini

Senior Legal Associate

The Indian Lawyer


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Clearing the confusion that came with the insertion of the amended provisions, namely, Sections 34(5) and (6) of the Arbitration and Conciliation Act, 1996, inserted by Amending Act 3 of 2016, the Supreme Court dealt with the nature of these amended provisions in the case of ‘The State of Bihar & Ors. Vs. Bihar Rajya Bhumi Vikas Bank Samiti’ (Civil Appeal No. 7314 of 2018).

The question before the Court was whether Section34 (5) is mandatory in nature or whether it is directory, i.e. whether non-issue of notice to the other party can lead to dismissal of the suit on this very ground.

Section 34, sub-sections (5) and (6) of the Arbitration and Conciliation Act, 1996 read as follows:

“34. Application for setting aside arbitral award.—


(5)    An application under this section shall be filed by a party only after issuing a prior notice to the other party and such application shall be accompanied by an affidavit by the applicant endorsing compliance with the said requirement.

(6)    An application under this section shall be disposed of expeditiously, and in any event, within a period of one year from the date on which the notice referred to in sub-section (5) is served upon the other party.”

The Court said that Section 34(5) is a procedural provision whose object is to dispose of applications under Section 34 expeditiously within one year, and not to scuttle the same. All rules of procedure are the handmaids of justice and if, in advancing the cause of justice, it is made clear that such provision should be construed as directory, then so be it, irrespective of the fact that the language used therein is mandatory in nature.

The Court referred to an instructive passage in Maxwell on Interpretation of Statutes, 10th Edition, which says that considerations of convenience and justice are uppermost, and if general inconvenience or injustice results, without promoting the real aim and object of the enactment, the provision must be declared to be directory.

The Court drew analogy to Section 80 of the Civil Procedure Code, 1908,to say that,“Section 80, though a procedural provision, has been held to be mandatory as it is conceived in public interest, the public purpose underlying it being the advancement of justice by giving the Government the opportunity to scrutinize and take immediate action to settle a just claim without driving the person who has issued the notice having to institute a suit involving considerable expenditure and delay. This is to be contrasted with Section 34(5), also a procedural provision, the infraction of which leads to no consequence. To construe such a provision as being mandatory would defeat the advancement of justice as it would provide the consequence of dismissing an application filed without adhering to the requirements of Section 34(5), thereby scuttling the process of justice by burying the element of fairness.”

The Court thus, held that the amended provisions are directory in nature despite the mandatory language used therein, largely because no consequence has been provided for the breach of the time limit specified.

Surabhi Aggarwal

Senior Associate

The Indian Lawyer



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Amrapali Group of Companies (the Company) has been accused of delaying the construction of apartments and handing over their possession to home buyers in its projects in Noida and Greater Noida in Delhi national capital region. In August, 2018  the Supreme Court gave a warning that it would order the sale of “each and every property” of the Company to recover the cost of construction of pending real estate projects, The Company had earlier told the court in an affidavit that it was not in a position to complete the projects and give timely possession of flats to over 42,000 home buyers.

The Supreme Court on 12th September 2018 in the matter of Bikram Chatterji & Ors. Vs. Union of India, had ordered the Company to hand over all original account books of the Amrapali Group of Companies within 24 hours from the year 2008-2015 and 2015-2018 of the 46 Companies of the Amrapali Group.

The Company failed to comply with the Court’s Order and another Order was passed by the Court on 26th September 2018 directing the Company to hand over all the account books, original documents, the Court held that “all the account books, original documents etc. to be handed over to to the forensic auditors, not only by the Amrapali Group of Companies but also those which were in possession of the statutory auditors

Therefore, Shri Pawan Kumar Aggarwal and Shri Ravi Bhatia who were appointed as forensic auditors in this case said in the Court on Tuesday,  9th October 2018, that Amrapali Group of Companies did not comply with the last Order of this Court and further stated that “as per the emails, the documents have not been handed over and only skeletal documents of two companies have been handed over on 20.11.2018, namely of Amrapali Zodiac and Amrapali Princely Estates

The Bench comprising of Justice Arun Mishra and Justice U U Lalit held on 9th October 2018 directed that the Directors, Anil Kumar Sharma, Shiv Priya and Ajay Kumar, will remain in custody due to non-compliance of Orders passed by this Court on 12th and 26th September 2018.

The Bench further held that “We are constrained to observe that it is not only deliberate non-compliance of the order but effort is being made to fritter away the documents in utter violation of the order passed by this Court. No justification could be pointed out by the learned counsel appearing on behalf of the Amrapali Group of Companies for not complying with the orders passed by this Court……..considering the non-compliance evident on record, we find that there is no other way except to direct the Police to seize all the documents and to hand over the documents to the forensic auditors after seizing them from the possession of 46 Companies and their Director”.

In another matter pertaining to Unitech Ltd., Mr. Sanjay Chandra and Mr. Ajay Chandra Directors were also sent to jail in September 2017 in connection with a cheating case registered against them. With the Amprapali Directors also being sent to jail the Supreme Court has assured deceived home buyers that if they do not get the flat the said Companies will be liable to repay the sums invested.

Taruna Verma

Senior Associate

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Ms. Chanda Kochhar, the first woman to head Industrial Credit and Investment Corporation of India (ICICI) Bank (the Bank), has stepped down as its Chief Executive Officer (CEO) on 04-10-2018.

As per newspaper reports, the Bank had sanctioned a loan of Rs. 3,250 Crore (Loan) to Videocon Group in 2012. Further, there were allegations that Videocon Group advanced the Loan amount to NuPower Renewables, thereby, causing a quid pro quo arrangement between the Videocon Group and the Bank on the following grounds:

Venugopal Dhoot, the Chairman of Videocon Group, was earlier a stakeholder and co-owner of NuPower Renewables.

Deepak Kochhar, husband of Ms. Chanda Kochhar, co-owned NuPower Renewables along with his father and Ms. Chanda Kochhar’s brother’s wife.

As per the Reserve Bank of India (RBI) Master Circular- Loans and Advances – Statutory and Other Restrictions dated 01-07-2015, it had laid down certain regulatory restrictions which state that loans and advances should not be granted to relatives of a bank’s chairman/managing director or other directors, etc without the prior approval of the board of directors of the bank.

As per the Securities and Exchange Board of India (SEBI), all directors and key managerial personnels of listed companies should disclose any conflict of interest in any transactions executed by the company. But Ms. Chanda Kochhar failed to disclose the conflict of interest, if any, with regard to transactions between Videocon Group and NuPower Renewables.

The Bank had initiated an inquiry, headed by former Supreme Court Judge B N Srikrishna, to probe various allegations against Ms. Chanda Kochhar. Also, the Central Bureau of Investigation (CBI) has initiated an inquiry against officials of the Bank. The reports of the inquiries are awaited.

Harini Daliparthy

Senior Associate at The Indian Lawyer


Suchit Patel

Sultan Ul-Uloom College of Law, Hyderabad

Intern at The Indian Lawyer

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The Prime Minister of India, Mr. Narendra Modi and the President of the Russian Federation, Mr. Vladimir V. Putin met for the 19th edition of the Annual Bilateral Summit held on 04.10.2018 to 05.10.2018 in New Delhi.

In order to strengthen the partnership between India and Russia, there were discussions about cooperation between the two countries across various sectors including economy and infrastructure. Following are the highlights of the discussions in the Summit regarding economic and infrastructure aspects:

Appreciated the work done by Invest India, the national investment promotion and facilitation Agency, to facilitate Russian investors to make investments in India, and the planned launch of a Single Window Service by the Ministry of Economic Development of the Russian Federation to facilitate investments and operations of Indian companies in Russia.

Implementation of investment projects in sectors of mining, metallurgy, power, oil and gas, railways, pharmaceuticals, information technology, chemicals, infrastructure, automobile, aviation, space, etc.

Memorandum of Understanding executed between National Small Industries Corporation of India, set up by the Indian Government to promote the growth of micro, small and medium enterprises in India, and the Russian Small and Medium Business Corporation.

Indian Government invited Russian companies to participate in the development of industrial corridors and infrastructure in India including roadways and railways, smart cities, creation of a joint transportation logistics company, etc. Russia expressed interest in railway speed raising projects.

Proposal of trilateral meeting between India, Russia and Iran for development of transport corridors between India and Russia through Iran.

Facilitate interaction between importers and exporters from India and Russia during trade exhibitions and fairs, etc.

Simplification of customs operations during import and export of goods between India and Russia through proposed launch of Green Corridor Project.

Organize regional delegations in major events Saint Petersburg International Economic Forum, Eastern Economic Forum and Partnership/Investment Summits, India-Russia Interregional Forum, etc, in order to encourage direct cooperation between business, entrepreneurs and governmental bodies in India and Russia.

Joint projects for effective use of affordable environment friendly utilization of natural resources and renewable energy sources available in India and Russia to reduce the negative effects of climate change.

Eliminate trade barriers, cooperate for greater production and trade in agricultural products in India and Russia.

Joint collaboration in investments, production, etc of precious metals, minerals, natural resources and forest produce, etc.

Cooperation in the field of information technology, internet of things, electronics system design and manufacturing, software development, supercomputing, etc.

Both countries have welcomed this partnership for strengthening an open, transparent and non-discriminatory multilateral trade system between the two countries across a whole range of sectors.

Daliparthy Harini

Senior Legal Associate

The Indian Lawyer

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Extra-judicial confessions are those confessions that are made by an accused before any person other than a magistrate or in a court. It is a free and voluntary confession of guilt by a person accused of a crime in the course of conversation with persons other than a judge or a magistrate. Extra-judicial confession can be accepted and be the basis of a conviction if it passes the test of credibility.

Various courts in India have held that extra-judicial confessions must be received with great caution and can be relied upon only when it is clear, consistent and convincing. It is the court’s discretion to decide upon the credibility of the witness in front of whom such confession has been made, as there may be a risk of failure of the party expressing his/her understanding about the confession. In order to resolve these issues, various courts have required some material corroboration that connects the accused person with the crime in question.

The Supreme Court has laid down the following guidelines dealing with extra-judicial confessions in Sahadevan & Anr. vs. State of Tamil Nadu 2012 and reiterated in Vijay Shankar v. State of Haryana vide judgment dated 04-08-2015:

The extra-judicial confession is weak evidence by itself. It has to be examined by the court with greater care and caution.

It should be made voluntarily and should be truthful.

It should inspire confidence.

An extra-judicial confession attains greater credibility and evidentiary value if it is supported by a chain of cogent circumstances and is further corroborated by other prosecution evidence.

For an extra-judicial confession to be the basis of conviction, it should not suffer from any material discrepancies and inherent improbabilities.

Such statement essentially has to be proved like any other fact and in accordance with law.

Recently, the Supreme Court has in Ram Lal vs. State of Himachal Pradesh passed a Judgment dated 03-10-2018, where it held that extra-judicial confession of accused need not be corroborated in all cases. It further held that conviction can be made on the basis of voluntary confession which is corroborated by independent evidence. But in cases of extra judicial confession it is not necessary to corroborate each and every circumstance mentioned in the confession. The courts can exercise their discretion in convicting an accused based on his/her voluntary confession alone.

In the present case, the accused was convicted for falsifying the accounts of the United Commercial Bank, Shimla by the Trial Court and the High Court of Himachal Pradesh.

In the Appeal before the Supreme Court, it was averred that the extra judicial confession made by the accused may have been under a threat or inducement by higher officials of the said Bank. But the Apex Court held that such threat or inducement should create a reasonable belief in the mind of the accused that he would get an advantage by making such confession. Thus, the Supreme Court concluded that the conviction of the accused was correct as it was based on his voluntary extra judicial confession statement.

Harini Daliparthy

Senior Associate at The Indian Lawyer


Arifa Khan

P.G. College of Law, Osmania University, Hyderabad

Intern at The Indian Lawyer

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The Lucknow Bench of Allahabad High Court, in the case titled Fahad & Ors. v. State of UP, through The Principal Secretary, Home Department and Ors., decided on 25.09.2018, has fined the doctor for writing medico-legal reports shabbily and directed Principal Secretary Home, Principal Secretary Medical and Health, Director General of Medical and Health to ensure compliance of a 2012 circular directing doctors to write clear medico-legal reports.

The Circular was issued by the Director-General on November 8, 2012, in the case titled Chhabiraj vs. State of U.P. and others, when the Court was forced to summon Director General, Medical and Health, U.P. Lucknow, directing that:

Medico-legal report shall be written in clear writing which is legible;

Simple words shall be used as far as possible;

Short/Short form/Abbreviation words shall not be used in the Medico-Legal Report;

Signatures, Name and Designation of the doctor who prepared the report shall clearly be mentioned.

The Bench was pained to note how poor handwriting of doctors in medico-legal reports was obstructing the administration of justice and observed that, “The doctors have been scribing medico legal report, injury report, bed head tickets, prescriptions and post-mortem examination reports in such handwriting that it cannot be read by the prosecutor, the defence lawyer or the Court. We are faced with a situation in which when the medico-legal report was summoned, counsel for none of the parties or the Court could read the report on account of the way it was written”.

The Bench further stated that, “By depiction of such injuries, as has been done in this case, neither the prosecution would be enlightened nor the defence, or even the court. The very purpose of having a medico-legal examination report is defeated. Such misleading and confusing injury report would help the accused to take benefit of lacuna in the prosecution case.  This court is pained at recording in every case that the medical report is summoned for reference for effective adjudication, the handwriting of the doctor in the report is not readable.”

The court reiterated that the relevance of the medico-legal report in cases of hurt, homicide or suicide is enormous and made a significant point that, “In a case of incised wound, the injury depicted in the medico-legal report/post-mortem report can clarify whether the knife was sharp on one side or both sides; the size of the blade; the force with which the knife has been thrust in the body and the direction from which the knife has been thrust. Likewise, in blunt injuries, explanation of the injury in the medico-legal report speaks volumes about the manner in which the injury might have been caused. It assists the Court in formulating an opinion in regard to the manner in which an incident might have taken place and what penal provision to invoke.”

It further went on to say that, “The medico-legal report, if given clearly, can either endorse the incident as given by the eyewitnesses or can disprove the incident to a great extent. This is only possible if a detailed and clear medico-legal report is furnished by the doctors, with complete responsibility. The medical reports, however, are written in such shabby handwriting that they are not readable and decipherable by advocates or Judges. It is to be considered that the medico-legal reports and post-mortem reports are prepared to assist the persons involved in dispensation of criminal justice. If such a report is readable by medical practitioners only, it shall not serve the purpose for which it is made. This is despite the fact that computers are available in all medical facilities. In some of the States, practice is being followed where medico-legal reports and post-mortem reports are made on computers/printers”.

Noting that the conduct of the doctor, Dr. Ashish Saxena, in violating the 2012 Circular cannot be ignored, it imposed a cost of Rs 5,000/- on him to be deducted from his salary and deposited in Library Fund of Oudh Bar Association of the Court.

Surabhi Aggarwal

Senior Associate

The Indian Lawyer

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The Sabarimala case has been one of the most keenly awaited judgments. The Supreme Court, by 4:1 majority, in the Writ Petition titled Indian Young Lawyers Association & Ors. V. The State of Kerala & Ors., delivered its Judgment on 28.09.2018, permitting the entry of women of all age groups to the Sabarimala Temple, Kerala, holding that ‘devotion cannot be subjected to gender discrimination’.

Chief Justice Dipak Misra, Justice R F Nariman, Justice A M Khanwilkar and Justice D Y Chandrachud constituted the majority, while the lone woman in the Bench, Justice Indu Malhotra, dissented.

Justice Indu Malhotra, in her lone dissent, held that issues of deep religious sentiments should not be ordinarily be interfered by the Court. Court should not interfere unless if there is any aggrieved person from that section or religion. Notion of rationality should not be seen in matters of religion. She also held that shrine and the deity is protected by Article 25 of Constitution of India.

The Bench observed that, “Women is not lesser or inferior to man. Patriarchy of religion cannot be permitted to trump over faith. Biological or physiological reasons cannot be accepted in freedom for faith. Religion is basically way of life however certain practices create incongruities.”

The separate but concurring opinion of Justice Nariman held: “Anything destructive of individuality is anachronistic of Constitutionality. To treat women as lesser people blinks at the Constitution itself”.

Chief Justice Dipak Misra had reflected that one visits a temple by virtue of their belief and devotion, and that the onus to prove the rationality and reasonableness would be on those imposing the prohibition. Hence, Rule 3(b) of the Kerala Hindu Places of Public Worship (Authorization of Entry) Rules 1965, which prohibited entry of women in Sabarimala Temple, was struck down as unconstitutional.

Surabhi Aggarwal

Senior Associate

The Indian Lawyer

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A five Judge Bench consisting of Chief Justice of India Dipak Misra, Justice AM Khanwilkar, Justice Rohinton Nariman, Justice DY Chandrachud, and Justice Indu Malhotra passed a Judgement in conformity with Right to Equality by striking down Section 497 the Indian Penal Code (IPC),

“Section 497 in The Indian Penal Code

Adultery- Whoever has sexual intercourse with a person who is and whom he knows or has reason to believe to be the wife of another man, without the consent or connivance of that man, such sexual intercourse not amounting to the offence of rape, is guilty of the offence of adultery, and shall be punished with imprisonment of either description for a term which may extend to five years, or with fine, or with both. In such case the wife shall not be punishable as an abettor.”

After path breaking Judgements on Triple Talaq and Section 377  of the IPC, the five Judge Bench of the Supreme Court, on Thursday, 27th September 2018, in the matter of Joseph Shine vs. Union of India unanimously held that the offence of adultery is unconstitutional in the eyes of law.

However, the Court held that adultery will be a ground for divorce or dissolution of marriage.

In CJI Dipak Misra’s Judgement (for himself and on behalf of Justice AM Khanwilkar) referred to KS Puttaswamy and another v. Union of India and others (Judgement on Right to Privacy) and held that “…Privacy enables the individual to retain the autonomy of the body and mind. The autonomy of the individual is the ability to make decisions on vital matters of concern to life…Privacy of the body entitles an individual to the integrity of the physical aspects of personhood…when such an act adultery is treated as a crime and how is faces the frown of Article 14 and 21 of the Constitution.” and reiterated concept of dignity of a woman, in the context of autonomy, desire, choice and identity, the part of Judgement. The CJI further held that “adultery might not be the cause of an unhappy marriage, it could be the result of an unhappy marriage” and also while referring to another Judgement- stated, “marriage is in modern times regarded as a partnership of equals, and no longer one in which the wife must be the subservient chattel of the husband.

Justice R F Nariman in a separate Judgment concurred with the Judgments of CJI Misra and Justice Khanwilkar, referred to Shayara Bano v. Union of India and others case holding Section 497 was an archaic provision which had lost its rationale. “Ancient notion of man being the perpetrator and woman being victim of adultery no longer holds good.” and “…when such law falls foul of constitutional guarantees, it is this Court‘s solemn duty not to wait for legislation but to strike down such law. As recently as in Shayara Bano (supra), it is only the minority view of Khehar, C.J.I. and S. Abdul Nazeer, J., that one must wait for the law to change legislatively by way of social reform.”

Justice Chandrachud’s views sheds light on protection of privacy of an individual in institution of marriage and he states in his Judgement that “The right to privacy depends on the exercise of autonomy and agency by individuals. In situations where citizens are disabled from exercising these essential attributes, Courts must step in to ensure that dignity is realised in the fullest sense. Familial structures cannot be regarded as private spaces where constitutional rights are violated. To grant immunity in situations when rights of individuals are in siege, is to obstruct the unfolding vision of the Constitution.”

Therefore, the Supreme Court delivered its Judgement in parity with concept of individual liberty with no discrimination on the basis of gender and held that adultery undoubtedly is a moral wrong in capacity of husband and wife relationship but there is no sufficient element for adultery to come under the ambit of criminal law. Thus, adultery will be taken as a ground for divorce to maintain the dignity of husband and wife.

Taruna Verma

Senior Associate

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