Live-In Relationship–An Analysis Through Cases

Dr. SangitaLaha

Professor & Dy Director, Amity Law School,Amity University, Lucknow

ABSTRACT

Live - in - relationship is a living arrangement in which an unmarried couple lives together

under the same roof in a long term relationship that resembles a marriage. This
is nowadays being taken as an alternative to marriage especially in the metropolitan cities.
Although there is no legal definition of living together, it generally means to live together as a
couple without being married. This form of living together is not recognized by Hindu Marriage
Act, 1955 or any other statutory law. The Indian law does not provide any rights or obligations
on the parties in live relationship. The status of the children born during such relationship is
also unclear and therefore, the court has provided clarification to the concept of live in
relationships through various judgments. The article seeks to gauge the current legal status of
live-in relationship in India. The article also tries to look into recent developments in the attitude
of the Courts in granting various rights to live-in partners in India through judgments and also
makes a comparative analysis of the trend in other legal systems and jurisdictions.

Key words-Marriage, Parties, Children, Indian laws, Courts

In India, there exists only one kind of relationship between an unrelated couple of a male and
female and that is “Marriage”.Marriage, also called as matrimony or wedlock, is a
socially/ritually recognized union or contract between spouses that establishes certain rights and
legal obligations towards each other. Marriage is more of a sacrament and a divine concept and
has been practiced since ages. But for number of reasons, this concept is losing its divineness.
Love cannot be the only reason to marry. Sometimesin arranged marriages couples do get
married but have no compatibility and marriage becomes more or less a compromise. While the
institution of marriage promotes adjustment; the foundation of live in relationships is individual
freedom. Times are changing and we are in the twenty first century. Traditional forms of
relationships and institutions are slowly losing their foothold. No more are the notions of
celibacy until marriage or even marriage as prevalent as they were. Women and men are slowly
embracing other, non-conventional, non-traditional forms of relationships, most of which are still
seen as a freak concept b mostly by the older generation, but also a surprising amount of younger
47

generation. As is the case with most new things, it is seen with fear and is not really understood.
As an example of this, we can see the paranoia and misconceptions around live in relationships.
Page

CONCEPT OF LIVE IN RELATIONSHIP:

Live - in - relationship is a living arrangement in which an unmarried couple lives together under
the same roof in a long term relationship that resembles a marriage. This is nowadays being

Volume 02, No.06, June 2016

taken as an alternative to marriage especially in the metropolitan cities.Although there is no legal
definition of living together, it generally means to live together as a couple without being
married. This form of living together is not recognized by Hindu Marriage Act, 1955 or any
other statutory law. Therefore, there is no specific law on the subject of live in relationships in
India. There is no legislation to define the rights and obligations of the parties to a live in
relationships, the status of children born to such couples.There is no legal definition of live in
relationship and therefore the legal status of such type of relationships is also unsubstantiated.
The Indian law does not provide any rights or obligations on the parties in live relationship. The
status of the children born during such relationship is also unclear and therefore, the court has
provided clarification to the concept of live in relationships through various judgments. The
court has liberally professed that any man and women cohabiting for a long term will be
presumed as legally married under the law unless proved contrary. Currently, the law is unclear
about the status of such relationship though a few rights have been granted to prevent gross
misuse of the relationship by the partners.
Legalizing live in relationship means that a totally new set of laws need to be framed for
governing the relations including protection in case of desertion, cheating in such relationships,
maintenance, inheritance etc. Litigation would drastically increase in this case.The article seeks
to clarify the current legal status of live-in relationship in India. The article also tries to look into
recent developments in the attitude of the Courts in granting various rights to live-in partners in
India through judgments and also makes a comparative analysis of the trend in other legal
systems and jurisdictions

JUDICIAL TRENDS OF LIVE-IN-RELATIONSHIPS

The Fundamental right under Article 21 of the Constitution of India grants to all its citizens
“right to life and personal liberty” which means that one is free to live the way one wants. Live
in relationship may be immoral in the eyes of the conservative Indian society but it
is not “illegal” in the eyes of law. 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. The judiciary in deciding the cases keeps in mind the social mores and
constitutional values.
The first case in which the Supreme Court of India first recognized the live in relationship as a
valid marriage was that of Badri Prasad vs. Dy. Director of Consolidationi, in which the Court
gave legal validity to the a 50 year live in relationship of a couple.
The Allahabad High Curt again recognized the concept of live in relationship in the case of
PayalKatara vs. Superintendent, NariNiketanand othersii, wherein it held that live in
relationship is not illegal. The Court said that a man and a woman can live together as per their
48

wish even without getting married. It further said that it may be immoral for the society but is not
Page

illegal.
Again in the case of Patel and Othersiii, the Supreme Court has held that live in relationship
between two adults without marriage cannot be construed as an offence. It further held that there

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is no law which postulates that live in relationships are illegal. The concept of live in relationship
was again recognized in the case of Tulsa v. Durghatiyaiv.
In case ofS. KhushboovsKanniammal&Anr.v, the south Indian actressKhushboo Had endorsed
live in relationship, 22 criminal appeals were filed against her which the Supreme Court
quashed saying that how can it be illegal if two adults live together, in their words “living
together cannot be illegal. If two adult people want to live together what is the offence?” “If two
people, man and woman, want to live together, who can oppose them? What is the offence they
commit here? This happens because of the cultural exchange between people,” a special three-
judge bench of chief justice of India K.G. Balakrishnan, justices Deepak Verma and B.S.
Chauhan observed.
The Supreme Court of India had thrown its weight behind live in relationships – a practice
that is often frowned upon because of what could perhaps be called miscomprehended
notion amongst a large chunk of our population about morality and ethical values. Despite
its inevitable failure to change such mindset amongst a sizable chunk of the population, the SC‟s
ruling was rather a significant one because it provided couples living in such arrangement with
the much needed protection of the law of the land.
While the year 2010 saw a number of judgments related to live-in relationships, which includes,
clear declaration by the Supreme Court that a live-in relationship is not illegal and grant of
maintenance to a woman in live-in relationship. Live-in relationship is one of the areas which is
under criticism and highly debated regarding its legality and implication on the societal
relationships. Long term cohabitation between two major man and woman has long been equated
to a valid marriage. The Courts have taken the view that where a man and a woman live together
as husband and wife for a long term, the law will presume that they were legally married unless
proved contrary as laid down long back by the Privy Council in the case of A DinohamyvsWL
Blahamanvi.In InndraSarma vs. V.K.V.Sarma,2013vii
The recent judgment of the Supreme Court has illustrated five categories where the concept of
live in relationships can be considered and proved in the court of law. Following are the
categories:
1. Domestic relationship between an adult male and an adult female, both unmarried. It is
the most uncomplicated sort of relationship
2. Domestic relationship between a married man and an adult unmarried woman, entered
knowingly.
3. Domestic relationship between an adult unmarried man and a married woman, entered
knowingly. Such relationship can lead to a conviction under Indian Penal Code for the
crime of adultery
49

4. Domestic relationship between an unmarried adult female and a married male, entered
unknowingly
Page

5. Domestic relationship between same sex partners ( gay or lesbian)

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POSITION OF FEMALE PARTNERS

The status of the female partner remains vulnerable in a live in relationship given the fact she is
exploited emotionally and physically during the relationship. Different court judgments have
discussed on different disputes pertaining to live-in relationships.TheDomestic Violence Act
provides protection to the woman if the relationship is “in the nature of marriage”. First time by
Protection of Women from Domestic Violence Act, 2005 the legislator has accepted live in
relationship by giving those female who are not formally married, but are living with a male
person in a relationship, which is in the nature of marriage, also akin to wife, though not
equivalent to wife. This proviso, therefore, caters for wife or a female in a live in relationship.
Live-in relationships are now considered at par with marriage under a new Indian law pertaining
to domestic violence. The provisions of the Domestic Violence Act, 2005 are now extended to
those who are in live-in relationships as well. The amendments intend to protect the victims of
domestic abuse in live-in relationships. Section 2 (g) of the aforementioned Act provides that a
relationship between two individuals who live together or have lived together in the past is
considered as a domestic relationship. A woman who is in a live-in relationship can seek legal
relief against her partner in case of abuse and harassment. Further, the new law also protects
Indian women who are trapped in fraudulent or invalid marriages.
In June, 2008, The National Commission for Women recommended to Ministry of Women and
Child Development made suggestion to include live in female partners for the right of
maintenance under Section 125 of Code of Criminal Procedure. This view was supported by the
judgment in AbhijitBhikasethAuti v. State Of Maharashtra andOthersviii.The positive opinion
in favour of live in relationship was also seconded by Maharashtra Government in October, 2008
when it accepted the proposal made by Malimath Committee and Law Commission of India
which suggested that if a woman has been in a live-in relationship for considerably long time,
she ought to enjoy the legal status as given to wife. However, recently it was observed that it is
divorced wife who is treated as a wife in context of Section 125 of Code of Criminal Procedure
and if a person has not even been married i.e. the case of live in partners, they cannot be
divorced, and hence cannot claim maintenance under Section 125 of Code of Criminal
Procedure.
Section 125 Cr.P.C. provides for giving maintenance to the wife and some other relatives. The
word `wife' has been defined in Explanation (b) to Section 125(1) of the Cr.P.C. as follows;
“Wife includes a woman who has been divorced by, or has obtained a divorce from, her
husband and has not remarried.”It was stated, “Law inclines in the interest of legitimacy and
thumbs down „whoreson‟ or „fruit of adultery.” Four important grounds are laid for live-in
relationship to be recognized as a relationship in the nature of Marriage. When a live-in partner
satisfies these four conditions in addition to living together under one roof, only then a deserted
woman can seek Maintenance. This judgement is drawn the Ruling of a California Court in the
50

US which had ordered similar relief by invoking the doctrine of a “Palimony”.

Page

These four conditions are:

1. A live-in couple must hold themselves out to Society as being akin to spouses.
2. They must be of legal age to marry.

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 3. They must be unmarried or
4. Be otherwise qualified to enter into a legal marriage.
They must have voluntarily cohabited and held themselves out to World as being akin to spouses
for a significant period of time. But, inVarshaKapoorvs UOI & Ors.ix, the Delhi High Court has
held that female living in a relationship in the nature of marriage has right to file complaint not
only against husband or male partner, but also against his relatives.
At present there is no existing legal framework which regulates the concept of live in
relationships in India. The Hindu Marriage Act, 1955 does not recognise live in relations and
nor does the Code of Criminal Procedure of India. The only act which has implied the existence
of live in relationships is the protection of women from Domestic Violence Act, 2005 (PWDV).
For the purpose of protection and maintenance to women, an aggrieved live in partner may be
granted alimony under the act.
A bare reading of this act reveals to us the following:
Section 2(f) of the act defines a „domestic relationship‟ to mean “a relationship between two
persons who live, or have, at any point of time, lived together in a shared household, when they
are related by consanguinity, marriage or through a relationship in the nature of marriage,
adoption or are family members living together as a joint family.”
The phrase „in the nature of marriage‟ covers in its ambit live in relations or cohabiting.
Unfortunately, it has not been defined in the act but left to the courts for interpretation.
The Supreme Court in the case of D.Velusamy v. D. Patchaiammalx, held that, a „relationship in
the nature of marriage‟ under the 2005 Act must also fulfil some basic criteria. Merely spending
weekends together or a one night stand would not make it a „domestic relationship‟. It also held
that if a man has a „keep‟ whom he maintains financially and uses mainly for sexual purpose
and/or as a servant it would not, in our opinion, be a relationship in the nature of marriage‟. The
Supreme Court further opined that the Parliament has drawn a distinction between the
relationship of marriage and the relationship in the nature of marriage, and has provided that in
either case the person is entitled to benefits under the Domestic Violence Act,2005(PWDV). The
court reflecting upon live-in relationships becoming frequent in India, the Court has pointed out
that no legal entitlements occur by such relationship. It is clear that no maintenance is available
to a concubine under law in India.
The Supreme Court was dealing with the claim of maintenance by a woman claiming to be a
wife in view of a live-in relationship for some year (about which we have already written noting
a High Court decision). The Court ruled that the concept of palimony which applied to such
relationships was not recognized in India and even though the Domestic Violence Actrecognized
live-in relationship to some degree, not all such relationships were entitled for maintenance
unless they satisfied the conditions stipulated by the Court.
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In the Act of 2005, the Parliament has taken notice of a new social phenomenon which has
emerged in our country known as live-in relationship. This new relationship is still rare in our
Page

country, and is sometimes found in big urban cities in India, but it is very common in North
America and Europe. It has been commented upon by Supreme Court in the case of S. Khushboo
vs. Kanniammal&Anr)xi.

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The recent judgment of the Supreme Court IndraSarma vs. V.K.V.Sarma,in 2013 the Supreme
Court has clarified several points and given a few guidelines to be followed in the absence of a
dedicated law. These guidelines will serve the purpose of bringing such relationships under the
Domestic Violence Act, 2005.
The Supreme Court illustrated five categories where the concept of live in relationships can be
considered and proved in the court of law. Following are the categories:
1. Domestic relationship between an adult male and an adult female, both unmarried. It is
the most uncomplicated sort of relationship
2. Domestic relationship between a married man and an adult unmarried woman, entered
knowingly.
3. Domestic relationship between an adult unmarried man and a married woman, entered
knowingly. Such relationship can lead to a conviction under Indian Penal Code for the
crime of adultery
4. Domestic relationship between an unmarried adult female and a married male, entered
unknowingly
5. Domestic relationship between same sex partners ( gay or lesbian)
The Court stated that a live-in relationship will fall within the expression “relationship in the
nature of marriage” under Section 2(f) of the Protection of women Against Domestic Violence
Act, 2005and provided certain guidelines to get an insight of such relationships. Also, there
should be a close analysis of the entire relationship, in other words, all facets of the interpersonal
relationship need to be taken into account, including the individual factors.

STATUS OF THE CHILD

But at the same time the court has considered important to protect child rights in particular in
live-in relationships. In January 2008, a Supreme Court bench that was headed by Justice
ArijitPasayat held that children who are born out of live-in relationships will not be considered
illegitimate.In August 2010, the Supreme Court held that a live-in relationship that has existed
for a long time will be considered a marriage and that the children born to such a couple will not
be illegitimate. Justice P Sathasivam and Justice BS Chauhan of the Supreme Court passed this
judgment and it will have strong legal implications on disputes relating to the legitimacy of
children who are born to live-in partners.xii

INTERNATIONAL SCENARIO
52

United States of America:

Page

Prior to 1970, live-in relationship i.e. Cohabitation was illegal in US, but went on to gain status
as a Common Law, subject to certain requirements prescribed under law. The American legal
history is a witness to several consensual sex legislations, which paved the way for living
together contracts and their cousins, the "prenuptial agreements".

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In USA, the expression `palimony' was coined which means grant of maintenance to a woman
who has lived for a substantial period of time with a man without marrying him, and is then
deserted by him.Partners in a live-in relationship do not have the right to inherit each other's
property, as is the case for married couples. However, property can be willed to each other.
InUnites Statesin 1976, the California Supreme Court decidedMichelleMarvin v. Lee Marvinxiii,
holding that agreements between cohabiting couples to share income received during the time
they live together can be legally binding and enforceable. The highly publicized suit between
actor Lee Marvin and his live-in companion, Michelle Triola Marvin, was the first of a series of
"palimony" suits that have become more numerous since the 1980s. After their breakup,
Michelle Triola legally adopted the surname Marvin despite never having been married to him,
and claimed he had promised to support her for the rest of her life. In the end, in Marvin
v.Marvin, the California Supreme Court ruled that Triola had not proven the existence of a
contract between herself and Mr. Marvin that gave her an interest in his property. Thus, the
common law rule applied to the situation without alteration, and she took away from the
relationship and the household what she brought to it.
However, the New Jersey Supreme Court in Devaney vs. L' Esperancexivheld that cohabitation is
not necessary to claim palimony, rather it is the promise to support, expressed or implied,
coupled with a marital type relationship, that are indispensable elements to support a valid claim
for palimony, A law has now been passed in 2010 by the State legislature of New Jersey that
there must be a written agreement between the parties to claim palimony.

In Trimble v. Gordonxv, the court held that a signed statement establishing paternity of a child
born out of wedlock is adequate protection of the child's inheritance rights.
In Braschi v. Stahl Associatesxvi, New York State's highest court found the term family should
be construed broadly and should encompass contemporary realities, including unmarried adult
partners in a long-term, committed relationship that shows mutual sharing of the mundane tasks
of everyday life.
Since the 1980s, a growing number of states and municipalities have passed laws allowing
unmarried couples, both heterosexual and homosexual, to register as domestic partners. Some
cities have established a domestic partner registry, while others extend certain benefits to
domestic partners even if the city does not provide a registry. In the USA, the proportion of
births outside of marriage has risen to almost 40 percent, according to recent federal data.
Couples can agree to a Cohabitation Agreement, which outlines their financial responsibilities
towards each other as well as remedies for a split
Some states have common-law marriage laws. These refer to legal marriage by default due to an
unmarried couple‟s actions. These normally involve living together for more than a year and
presenting themselves to the outside world as husband and wife.The country hasinstitutionalized
53

cohabitation by giving cohabiters essentially the same rights and obligations as married couples,
a situation similar to Sweden and Denmark
Page

Canada:
In Canada, cohabitation is officially recognized as “common law marriage”. In a lot of cases, the
federal law of the country grants common law couples the same rights as married couples. All

Volume 02, No.06, June 2016

common law live in couples enjoy legal sanctity if they have lived together for a minimum of 12
consecutive months, or they give birth to/adopt a child.

France:
In France, a pacte civil de solidarité or a civil pact of solidarity commonly known as a PACS, is
a form of civil union between two adults (same-sex or opposite-sex) for organising their joint
life. It brings rights and responsibilities, but less so than marriage. From a legal standpoint, a
PACS is a contract drawn up between the two individuals, which is stamped and registered by
the clerk of the court. Since 2006, individuals who have registered a PACS are no longer
considered single in terms of their marital status. Their birth records will be amended to show
their status as pacsé (in a PACS) as well.

Phillippines:
In Philippines, live in relationship couple‟s right to each other‟s property is governed by co-
ownership rule. Article 147, of the Family Code, Philippines provides that when a man and a
woman who are capacitated to marry each other, live exclusively with each other as husband and
wife without the benefit of marriage or under a void marriage, their wages and salaries shall be
owned by them in equal shares and the property acquired by both of them through their work or
industry shall be governed by the rules on co-ownership. It mainly concerns itself with properties
acquired through their actual joint contribution, which could be money, property or industry
owned by them in common. The Family Code expressly governs the property of persons
cohabiting without the benefit of marriage. It is required, however, that both must be capacitated,
or have no legal impediment, to marry each other.xvii

United Kingdom:
In United Kingdom, both parents are financially responsible for the children whether they were
married, co-habiting or separated. Parents do not generally have the inheritance rights over each
other‟s property unless they are in the Will. This, however, can be contested. Live-in couples are
not legally obliged to support each other financially even if they are sharing a house or raising a
family together. Unlike married couples, they are not entitled to receive Maintenance from their
partners even if they have lived together for a number of years or given up their career to look
after the home and children. An unmarried couple can formalise aspects of their status by
drawing up a cohabitation contract or living together agreement, which outlines the rights and
obligations of the partners toward each other. The Lesbian, Gay, Bisexual and Transgender
(LGBT) community which doesn‟t have marriage rights can enter into a civil partnership. Every
child born to a married woman is assumed to be her husband‟s child and both have parental
responsibility whereas in the case of a live in relationship, the unmarried mother or father has
54

responsibility of a child but can enter into a parental responsibility agreement with the partner for
shared responsibility. Both married and cohabitating couples can apply to adopt a child jointly.
Page

With regard to inheritance, even if there is no will, the child of unmarried or married parents has
a legal right to inherit form both parents and families of both parents. If either married partner
dies without making a will, the other will inherit all or some of the estate whereas in case of
cohabitating couples if one partner dies without leaving a will, the surviving partner will not

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automatically inherit anything unless the couple owned property jointly. If one inherits money or
property from an unmarried partner, they are not exempt from paying inheritance tax, as married
couples are. Thus, we see that the concept of a live in relationship has been acknowledged and
dealt with in the UK.

Scotland:
The live in relation were conferred legal sanctity in Scotland under Family Law (Scotland) Act
2006. Section 25 (2) of the Act postulates that a court of law can consider aperson as a co-
habitant of another by checking on three factors, namely,

a. The length of the period during which they lived together,

b. The nature of the relationship during that period and
c. The nature and extent of any financial arrangements.

Ireland:
Even though living together is legally recognized in Ireland, public opinions are strictly against a
new legislation that aims to facilitate legal rights for “separated” cohabitating couples to demand
maintenance and/or share their property with the financially dependent partners. The legislation
is applicable to same sex unmarried couples as well as couples from opposite sexes, provided
they have been cohabitating for at least 3 years (or 2 years if they have children). The
government, with this new legislation, plans to fetch financial and legal protection for financially
dependent and vulnerable cohabitants in the event of break up or death.

Australia:
The Family LawAct of Australia states that a “de facto relationship” can existbetween two
people of different or of the same sex and that a person can be in a de-factorelationship even if
legally married to another person or in a defacto relationship withsomeone else.

China:
In China, there is no legal procedure required to end a live-in-relationship. Children born out to
wedlock have equal rights to those born to parents who are married. Contracts are made between
couples in a live-in relationship.

CONCLUSION
55
Page

Live in relationship has always been the focus of debates and discussions as it ischallenging our
fundamental societal system. To encourage marriages, Government hasreserved many rights for
the married people. Although live in relationship is not considered as an offense but there is no
law until the date that prohibits this kind of relationship. Courts often refused to make any kind
of obligatory agreements between these unmarried couples asthis could go against the public

Volume 02, No.06, June 2016

policy. In India, presently there is no law defining live-in relationship. To sum up, let me write
what Swami Vivekananda hadsaid “It is very difficult to understand why in this country so much
difference is made between men and women, whereas the Vedanta declares that one and the
same conscious self is present in all beings. You always criticize women, but say what you have
done for their upliftment”.

REFERENCES:
i. American Bar Association. 1994. Family Legal Guide. New York: Random House.
ii. Dailey, Patricia A. 1994. "Domestic Partnerships in the Nineties." Delaware Lawyer
(summer).
iii. Duff, Johnette, and George G. Truitt. 1992. The Spousal Equivalent Handbook: A Legal
and Financial Guide to Living Together. New York: Penguin, NAL/Dutton.
iv. Ihara, Toni, Robin Leonard, and Ralph Warner. 1994. The Living Together Kit. 7th ed.
Berkeley, Calif.: Nolo Press.
v. Richardson, David G. 1993. "Family Rights for Unmarried Couples." Kansas Journal of
Law and Public Policy (spring).
vi. Samuels, M. Dee. 1995. "You Don't Have to Be Married to Be Legal." Compleat Lawyer
(winter).
vii. Wallman, Lester. 1994. Cupid, Couples, and Contracts: A Guide to Living Together,
Prenuptial Agreements, and Divorce. New York: MasterMedia.
viii. Duff, Johnette, and George G. Truitt. 1992. The Spousal Equivalent Handbook: A Legal
and Financial Guide to Living Together. New York: Penguin, NAL/Dutton.
ix. Richardson, David G. 1993. "Family Rights for Unmarried Couples." Kansas Journal of
Law and Public Policy (spring).
x. ChetanTripathy : Live in relationship–review and anlysis :
xi. Hindu Marriage act 1955

Cases
1. Badri Prasad vs. Dy. Director of Consolidation,AIR 1978 SC 1557.
2. PayalKatara vs. Superintendent, NariNiketanand others, 2001(3) AWC 1778.
3. Patel and Others, 2006 (8) SCC 726.
56

4. Tulsa v. Durghatiya, 2008(4) SCC 520.

5. S. KhushboovsKanniammal&Anr, JT 2010 (4) SC 478.
Page

6. A DinohamyvsWL Blahaman, (1928) MLJ 388 PC

7. AbhijitBhikasethAuti v. State Of Maharashtra andOthers ,AIR 2009 (NOC) 808 (Bom).
8. VarshaKapoorvs UOI & Ors, 146 (2008) DLT 445 (DB).

Volume 02, No.06, June 2016

 9. D. Velusamy v. D. Patchaiammal, AIR 2011 SC 479.
10. S. Khushboo vs. Kanniammal&Anr), 2010 (5) SCC 600 vide para 31
11. Michelle Marvin v. Lee Marvin, 18 Cal.3d 660 (1976).
12. Devaney vs. L' Esperance, 195 N.J., 247 (2008).
13. Trimble v. Gordon, Decided on Apr. 26, 1977; 430 US 762.
14. Braschi v. Stahl Associates, 74 N.Y.2d 201,543 N.E.2d 49,544 N.Y.S.2d 784,1989 N.Y.
Websites:

15. http://www.legalservicesindia.com.
16. Court Judgments: Live in Relationships and Related isputes‟
<http://www.lawisgreek.com/ court-judgments-live-relationships-and-related-disputes>.

ENDNOTES

i
AIR 1978 SC 1557.
ii
2001(3) AWC 1778.
iii
2006 (8) SCC 726.
iv
2008(4) SCC 520.
v
JT 2010 (4) SC 478.
vi
(1928) MLJ 388 PC
vii
AIR 2009 (NOC) 808 (Bom).
viii
AIR 2009 (NOC) 808 (Bom).
ix
146 (2008) DLT 445 (DB).
x
AIR 2011 SC 479.
xi
2010 (5) SCC 600 vide para 31.
xii
„Court Judgments: Live in Relationships and Related
Disputes’,<http://www.lawisgreek.com/court-judgments-live-relationships-and-related-
disputes>.
xiii
18 Cal.3d 660 (1976).
xiv
57

195 N.J., 247 (2008).

xv
Decided on Apr. 26, 1977; 430 US 762.
Page

xvi
74 N.Y.2d 201,543 N.E.2d 49,544 N.Y.S.2d 784,1989 N.Y.
xvii
http://www.legalservicesindia.com.

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