TheDaak review

Law, Love and Liberty: Dissecting Uttarakhand’s New Law on Live-in Relationships

By Bhavneet Kour and Aditya Thakur

On February 7, 2024, amidst loud chants of Jai Shree Ram and Bharat Mata Ki Jai, the Uttarakhand Legislative Assembly passed a Uniform Civil Code (UCC) without holding substantial debate or deliberation warranted by a legislation of such significance (Sharma 2023). The UCC seeks to govern and regulate laws concerning marriage and divorce, succession, and live-in relationships and is applicable to all residents irrespective of religion. However, members of Scheduled Tribes have been exempted from its purview due to constitutional protections to the community as well as political fear of encroachment in customary practices of tribals (Kumar 2024). While the government is celebrating the new law as a watershed development in advancing the cause of gender equality (Uma 2024), several women’s groups have rejected the legislation and have labelled it unconstitutional (Nigam 2024). In spite of these objections and the possibility of extraterritorial application (Ghose 2024), the UCC has received assent from the President under Article 254 and is set to be implemented across the state. More notably, states such as Rajasthan and Uttar Pradesh have valiantly claimed that they will follow Uttarakhand’s example, and the legislation is possibly a template for a nationwide UCC (Pal 2024; Matthew 2023).     

While the Code has many contentious features, one of the most problematic aspects is its provisions concerning live-in relationships contained in Part III of the UCC. Section 387 of the UCC mandates the registration of all live-in relationships before a Registrar within a month, failing which punishment extending to three months imprisonment or a fine up to ten thousand rupees or both is prescribed. Not only are these provisions devoid of any rational objective or legitimate state interest, they give rise to a host of legal and constitutional issues and leave women more vulnerable than before. Rather than being a guarantor of personal and sexual autonomy, the new law is a parochial, paternalistic and patriarchal attempt at endorsing the institution of marriage, while simultaneously decrying other forms of intimate associations. By criminalising non-registration of live-ins and allowing excessive state and societal say in personal matters, the Code encourages vigilantism and essentially views live-in relationships as a public order concern. In this vein, the Code is part of a series of legislations which exemplify the law’s conflicted relationship with sexuality. 

This commentary is an attempt to critically evaluate and analyse the provisions of UCC which govern live-in relationships. Firstly, the rationale behind the enactment of Part III of UCC is analysed, followed by an examination of the ambiguous definition and unclear scope of the legislation, with special reference to the issue of domestic violence. Secondly, various empirical ramifications of the code are discussed in terms of- increasing vulnerability towards honour crimes and harassment, infringement of the right to privacy under Article 21 and, a growing culture of over-criminalisation and executive encroachment in the personal realm. Finally, and most notably, the commentary seeks to establish how the Uttarakhand UCC essentially prioritises marital institution over sexual autonomy and reaffirms heteronormativity. 

Evaluating the Rationale behind the Enactment of Part III of  UCC

The Uttarakhand UCC is based on the report of an Expert Committee for Uniform Civil Code, which was constituted by the Uttarakhand government under the chairpersonship of Justice Ranjana Prakash Desai in order to make recommendations on personal civil law and to prepare a draft of the UCC. While this Committee recommended an entire part devoted to the regulation of live-in relationships in the Draft UCC, it is astonishing that the report barely contains any discussion on the provisions relating to live-in relationships. The Report of the Expert Committee (2013) devotes only one page to live-in relationships. The report mentions that “since there is no legal recognition according to their union, the partners in a live-in relationship go unnoticed even when they violate the law”. The report (2023, 153) then mentions that there are rising incidences of crime as a consequence of live-in relationships, and thus it has been found necessary to “keep a record of individuals involved in live-in relationships”. Such justification reveals several underlying issues.

First, while the report mentions violations of law by partners in live-in relationships, it is silent on what exactly these violations are. It should be noted that the Supreme Court, in cases such as S. Khushboo v. Kanniammal (2010), has clarified that staying in live-in relationships does not violate the law and does not amount to an offence. Second, the justification provided for compulsory registration of live-in relationships reveals that the state essentially views such relationships as a concern of public order, and the UCC is not an ameliorative legislation designed to safeguard the interests of women. Third, the overall tone in which the Report talks about live-in relationships suggests a contemptuous attitude against such relationships. This is indicated by the connections drawn between live-in relationships and crime and by using terms such as ‘keep records’ and ‘individuals involved in live-in relationships’, terms with mostly negative connotations. Lastly, while the report claims to have extensively relied on public consultations to frame its recommendations, several everal of the suggestions received regarding live-in relationships, were of regressive nature. For instance, it was suggested that live-in relationships should only be permitted for a limited time period, after which marriage should be mandatory. Although not all of these suggestions were accepted by the Expert Committee, the heavy influence of these public suggestions on the Committee’s report raises questions about the predominance of ‘public morality’ over ‘constitutional morality.’ Also, while the Expert Committee undertook specific consultations with conservative elements of society, such as religious heads and community elders, it is unclear whether youth and people who are actually in live-in relationships were also consulted before preparing a draft of the UCC.         

Ambiguities in Definition and Scope 

Women in live-in relationships face unique issues, such as financial dependency on their partners without commensurate maintenance obligation and lack of legal protection against domestic violence (Narayan 2021). Further, such relationships frequently generate controversy and are heavily stigmatised (Titzmann 2017). However, rather than addressing these issues, the Code does little to alleviate women’s position. The ambiguous definition of a live-in relationship under the Code makes it both overinclusive and underinclusive. Section 3(4)(b) of the UCC defines a ‘live-in relationship’ as “a relationship between a man and a woman, who cohabit in a shared household through a relationship in the nature of marriage”. While the term ‘shared household’ has been defined by the code, the phrase ‘relationship in the nature of marriage’ has not been defined. Previously, the meaning of ‘relationships in nature of marriage’ was discussed by the Supreme Court in D Veluswamy v. D Patchaimamal (2010) and Indra Sarma v. V.K.V. Sarma (2013), in the context of the Domestic Violence Act, 2005, wherein such relationships have been recognised as ‘domestic relationships’. In these judgments, the court held that only a limited number of live-in relationships which fulfilled a set criteria would be considered to be ‘relationships in nature of marriage’. This set criteria included that the couple must hold themselves out to society as being akin to spouses, they must have voluntarily cohabited for a significant period of time, and there should be a pooling of resources and adequate financial and domestic arrangements, all indicating the existence of a ‘long-standing relationship’. Consequently, it may be contended that only those cohabitations or relationships which fulfil these requirements should then fall within the ambit of the live-in relationships under the Code.

Although, the use of the phrase ‘relationship in nature of marriage’ inherently implies a long-term association, simultaneously making registration of live-in relationships mandatory within a month creates confusion about the true meaning of such relationships and about the scope of their regulation. Thus, it is possible that couples living together voluntarily, but not interested in long-term association or marriage, or ones intending to stay in a relationship without holding themselves out to society as being akin to spouses will also be covered under the ambit of the Code, with obligations of registration and maintenance, which the couple did not envisage. This leads to a situation where women who might not wish to be included under the ambit of the law will have their personal and sexual autonomy policed through provisions like compulsory registration. 

On the other hand, several women in need of protection would be left out, since now maintenance rights will be hinged on mandatory registration in Uttarakhand. These include women who have cohabited with a married man for a long time and are totally dependent on their partner. Such women have already been excluded by the courts from the category of ‘relationships in nature of marriage’ and face significant disadvantages, possibly to protect the interests of the first wife (Gupta 2017). In the Indian legal system, such women are often labelled ‘adulterous’ by the courts (Indra Sarma 2013, para 63) and are denied protection on account of not falling within the contours of ‘good women’ (Ramanathan 1999). The UCC has further entrenched this position by excluding such relationships from the ambit of registration under the code as per Section 380. 

The Code is also silent on the issue of domestic violence within live-in relationships. While there are no specific data regarding domestic violence faced by women in live-in relationships, data from the National Family Health Survey (NFHS-5) reveal that 30 per cent of women between ages 18-49 in India have faced physical violence, up to 6 per cent of such women have faced sexual violence, and that such violence is far more common in intimate relationships (Prasad 2023). This makes it imperative to provide for legal safeguards against domestic violence to women in live-in relationships. However, the existing position of law under the Domestic Violence Act 2005 (DV Act) is patchy; and as the judgments in Veluswamy (2010) and Indra Sarma (2013) indicate, only limited categories of relationships in the nature of marriage are given protection under the domestic violence law. The Uttarakhand legislature also has not considered this aspect in the code, and the UCC offers no clarity on whether live-in relationships which have been registered under the Code would also be considered as ‘domestic relationships’ under the DV Act (2005). In fact, Section 382 of the Code states that the registration regarding live-in relationships shall be only for the purposes of record. This indicates that the Code seeks to make little to no improvement in the position of women in registered live-in relationships.

Although in a positive development, Section 388 of the Code creates a provision which entitles the woman to claim maintenance from her live-in partner in case she is deserted by her partner, the latitude and breadth of this provision is uncertain. Section 25 of the UCC defines desertion only in reference to married couples, wherein it means abandonment or facing unique issues such as financial dependency on their partners without commensurate maintenance obligation and lack of legal protection against domestic violence, neglect without reasonable cause and without consent. Since live-in relationships can be unilaterally terminated by either partner by giving a statement of termination to the Registrar and providing a copy of the statement to the other party, the concept of desertion seems inapplicable and alien, rendering the benefits of the maintenance provision inconclusive. Concurrently, the position of women in unregistered live-in relationships may become even more precarious because they would not be entitled to maintenance under Section 388. This goes against the spirit of gender equality, professed as the guiding principle of the law. Thus, the Code is more of a lip service to the cause of women’s rights rather than an actual advancement. 

Increased Vulnerability to Harassment and Honour crimes 

Section 381 of the UCC makes it obligatory for partners in a live-in relationship within the state to submit a statement of their relationship to a concerned Registrar, who then exercises extensive powers to conduct a summary enquiry, resulting in either an issuance of a ‘relationship certificate’ or a rejection. Moreover, under Section 386, in cases where the partners fail to submit the statement of their relationship, the Registrar can require the partners to submit it within thirty days. In such cases, the Registrar can act either on his own volition or on receipt of a complaint or information. It is noteworthy here that these complaints or information can come from unconnected persons or vigilante groups who have no real interest in the existence or continuance of the live-in relationship, a more plausible reality in cases of socially despised inter-religious and inter-caste couples. This can be evidenced by numerous instances of harassment of couples around Valentine’s Day when moral policing by vigilante groups threatens free expressions of love and sexuality (Rath 2018).  

The UCC emboldens almost anyone to interfere in an individual’s personal space by allowing them to complain to the registrar regarding unregistered relationships and also, by allowing them to pursue criminal cases against such couples. Even if two people of opposite genders share a joint roof, without having a romantic or sexual relationship, the authorities might intervene and call upon them to explain the exact nature of their relationship to the world at large. Whether the two people were actually in a live-in relationship would emerge later from the facts, but the individuals can still be subjected to an intrusive process where the state encroaches in their private spaces, often acting under the influence of society’s arbiters of morality. 

The Uttarakhand Code’s scheme regarding live-in relationships goes against the letter and spirit of the Supreme Court’s orders in Lata Singh v. State of UP (2006) and Shakti Vahini v Union of India (2018), wherein the court recognised the right of adult individuals to consensually choose their partners as being implicit in Articles 19 and 21. The Court in Shakti Vahini also issued directions and guidelines to protect couples from honour killings and diktats of extra-legal social institutions such as khap panchayats. The Allahabad High Court, in a recent case, extended protection to live-in relationships maintaining that no person, including parents, shall be permitted to interfere in a peaceful live-in relationship (Razia v. State of Uttar Pradesh, 2023). However, the Code has the tendency to make couples more vulnerable to harassment and honour crimes. For instance, Section 385, which mandates the registrar to inform parents about the relationship in case one of the partners is less than twenty-one years old, conflicts with both the legal age of majority and age of consent, which is eighteen years at present, as per the Indian Majority Act, 1875 and the Indian Penal Code, 1860. Thus in a way, adults between the ages of 18 to 21 years become citizens with circumscribed fundamental rights, and while already fearing persecution from family and society, the state now helps to trace these non-conforming adults and bring them before the judgement of society. 

The Code also increases the likelihood of harassment of inter-religious couples, which can be inferred if one examines the provision of pre-registration of live-in relationships in the context of the spate of anti-conversion and ‘love-jihad’ legislations enacted by several states, including Uttarakhand (Singh 2022). Section 380 of the UCC lists certain conditions in which live-in relationships are not to be registered. This includes relationships where the consent of either partner was defective by reason of being obtained by force, coercion, undue influence, misrepresentation or fraud of factors including identity. The registrar has been given extensive powers to verify that the relationship is not a prohibited one and in case the relationship is found impermissible or suspicious, he has to inform the local police for ‘appropriate action’. On the face of it, these provisions appear to be not only innocuous but also necessary to preserve mutual consent between the partners. However, the power of enquiring whether the relationship is permissible, coupled with space for state-legitimised vigilantism, may also be abused by further scrutiny of inter-religious couples under anti-conversion laws, making such relationships more vulnerable than ever. 

Right to Privacy and Proportionality Analysis  

This issue of mandatory registration raises the obvious question of encroachment into the right to privacy, which is protected by Article 21 of the Constitution. The Supreme Court in KS Puttaswamy v. Union of India (2017) held that the right to privacy is a fundamental right and that any intrusion into this right by the state must be just, fair and reasonable. Any state action which encroaches into the right to privacy would be unconstitutional, if it does not satisfy the four-fold test of proportionality. According to this test- first, the state action must be sanctioned by law; second, the proposed action must be in furtherance of a legitimate aim, and there should be no palpable or manifest arbitrariness in the aims of the law; third, the extent of interference must be proportionate to the need for such interference; and fourth, there must be procedural guarantees against abuse of such interference (Aditya AK 2018). 

The Uttarakhand UCC does not satisfy this four-fold test of proportionality. First, there appears to be no clear justification for the state to invade the personal space of couples, which falls within the ‘intimate zone of privacy’ (Supriyo v. Union of India, 2022, p 165). While the Expert Committee report mentions that the law has been recommended because of the rise in crimes emanating out of live-in relationships, as “highlighted in media reports” (2024, 153), this alone cannot be a legitimate justification for this encroachment because the link between live-in relationships and crime is mostly anecdotal and shaky in evidence, and there’s no rational nexus as to how registration would stop such crimes. Second, to assess proportionality, the state should also assess possible alternatives to the measure it employs and choose the least intrusive measure. In the case of UCC, alternative measures such as increasing the capacity of the police force and ensuring a gender-just legal system would be a better alternative to control crime. Third, prescribing a hefty punishment for non-registration is an unduly harsh and disproportionate response to any possible state interest necessitating the registration. Lastly, there is a marked absence of any safeguards to protect the privacy of affected individuals. For instance, there is no stated requirement to protect the personal data of people in live-in relationships or prohibition against disclosure of such data to third parties. Thus, the Code fails to pass muster of the test of proportionality and violates fundamental rights of the couples. 

Over-criminalisation and Executive encroachment in the personal sphere  

The provision which makes failure to register the live-in relationships a criminal offence is reflective of the problem of over-criminalisation, wherein the State utilises the criminal law too often to address social problems that can be best combatted in other ways. According to Sara Sun Beale (2004), over-criminalisation can result in excessive unchecked discretion in enforcement authorities, potential for abuse, and misdirection of scarce resources. In the context of live-in relationships, even if there is some legitimate state interest in regulating these relationships, the use of criminal law to further regulation is unwarranted. The creation of a new social offence without prior Judicial Impact Assessment to consider the likely costs and its impact on an already overburdened judicial system is also concerning.

The involvement of police authorities in the registration process raises alarm. It appears that the state views ‘live-in relationships’ as a possible threat to social and public order. This is exemplified by the fact that the same Code makes no analogous provisions regarding the criminalisation of non-registration or mandatory information to police while dealing with marriage registrations. In a society wherein live-in relationships already face significant social stigma and partners in such relationships often face difficulty in accessing basic services such as rented accommodation (Menon 2012), the discriminatory attitude against live-ins, which underlies the Uttarakhand law, cannot be neglected.   

Furthermore, extensive powers, including quasi-judicial powers, have been given to the registrar, who is an executive functionary. Notably, this seems to be part of a larger legislative trend wherein the executive is being given more powers in the realm of personal laws. For instance, a number of new laws by different states related to religious conversion and inter-religious marriages give powers to District Magistrates to enquire into such conversions and marriages, and in many cases, their approval is necessary for the marriage to be solemnised. All these developments indicate a thoughtless enlargement of powers of the executive branch to the extent that it encroaches into the personal and intimate space of the individual.

Prioritising Marital Institution over Sexual Autonomy 

Feminist movements in the 1960s and 1970s contested the dominant ‘public-private’ dichotomy and declared that ‘the personal is political’ (Hanisch 2006). This meant the liberation of sexual matters from the sphere of ‘the personal’ and a repudiation of the existing notions of bourgeois sexual morality. In other words, women were to exercise choice in making decisions related to sexual matters and would contest all those structures and patriarchal practices that suppressed their sexual freedom. In a broader realm, sexual autonomy entails “the guarantee of freedom from sexual violence, coercion and discrimination, as well as control over one’s own body and over the involvement in sexual interactions with others.” (Valentiner 2021, 703)

In this context, the Uttarakhand code is an evident manifestation of limiting sexual autonomy through the legislative endorsement of ‘marital supremacy’, or the notion that marriage is the only acceptable way of leading a family life (Mayeri 2015). This raises two primary concerns. First, many scholars have offered a deconstructionist perspective on marriage which views marriage as a “meta-narrative”, which itself is a gendered idea, historically used as a means to ensure the dependency of the wife on the husband (Yadav 2016, 91). Second, this marginalises certain choices regarding family life while valuing and preferring some choices over others, and stymies the proliferation of alternative family structures (Murray 2012, 462). Such marginalisation impairs personal choices and disproportionately impacts certain people, such as the LGBTQ community.

While the UCC remains novel in giving legal recognition to live-in relationships and affirming the legitimacy of children born out of such unions, the legal status accorded to live-in relationships is far inferior. This is evident from the differential treatment of live-in relationships vis-à-vis marriage. For instance, while anyone can initiate legal action against an unregistered live-in relationship, this may be contrasted with the position in the case of offences against marriage, such as bigamy and cruelty by husband, wherein Section 219 and 220 of the Bhartiya Nagrik Suraksha Samhita, 2023 prescribe that the courts can only take cognisance of the offence on a complaint made by the aggrieved party or a person closely related to the victim. It is quite paradoxical that by not allowing third persons to intervene in these cases, the state is committed to protecting the privacy of persons in marriage, which by nature is a social institution, but does not accord similar protection to live-in relationships, which by nature were meant to be private. 

This legislative approach is consistent with several other laws, such as restitution of conjugal rights, non-criminalisation of marital rape, and the recent Section 69 of the Bhartiya Nyaya Sanhita, 2023, which punishes sexual intercourse under false promises of marriage. The underlying assumption here is that ‘good women’ must perform sex within marriage and, if voluntarily, only for the purpose of marriage. These provisions, in their content and application, thus prioritise the institution of marriage over the dignity and sexual autonomy of women (Vishwanath 2023). In a similar vein, we often find judgments in which the Court is willing to acquit the accused, who, by way of a compromise, agrees to marry his victim (Gupta 2020). In such cases, what drives the court is the patriarchal notion that ‘marriage condones rape’. The social opposition to the criminalisation of marital rape and the law’s acceptance of such rape also enforces the same notion. Similarly, saying that not marrying someone makes the otherwise consensual act an offence is a backwards extension of the above notion; because the social construction behind both the arguments is the notion that ‘marriage is the only justification for sex’ or marriage legitimises sex. 

Further, the Code affirms heteronormativity by limiting legal recognition to heterosexual couples and excluding LGBTQ couples. This is another setback in the road for LGBTQ rights and marriage equality. Furthermore, by only mentioning relationships between a man and a woman, the Code goes against the directions of the Supreme Court in NALSA v. Union of India (2014) and Supriyo v. Union of India (2022), wherein equal rights for transgender people were affirmed, including the right to marriage (Rajagopal 2023). While excluding same-sex and LGBTQ couples from the requirement of compulsory registration can be a blessing in disguise because they are exempted from the harsh requirements that the law imposes on heterosexual couples, there are downsides to it too. First, although the legal system is based on the principle of ‘what is not forbidden is permitted’, India’s state machinery and vigilante groups do not always take this adage seriously. Thus exclusion of such couples can also be interpreted by some to mean that the law does not permit these couples, leading to their further harassment and marginalisation. Second, the exclusion of LGBTQ does not seem to be done out of grace or as a result of oversight but appears to be a result of the state’s wilful blindness towards acknowledging the existence of the LGBTQ community.

By enforcing heteronormativity and prioritising marital supremacy over sexual autonomy, the Uttarakhand UCC offers a perfect testimony of how the law regulates sex and sexuality. Madhavi Menon, in The Law of Desire (2021), writes that “law promises official recognition if desire can be reduced from multiplicity to a specific category of identity…for instance, you are rewarded for being heterosexual and for marrying within your caste, religion, and community. If you do not abide by the constraints of hetero-sexual, binary gender, and caste and religious endogamy, then you are punished with administrative burdens…Being legally recognised also means being legally policed”. While the law has started to recognise live-in relationships, it has been heavily policed. This results in what Foucault would call the ‘production of docile bodies’ through the normalisation and legitimisation of surveillance (Bayraktar 2021, 27).    

Conclusion

The new law does not seem to be driven by any legitimate state interest and is an arbitrary and unwarranted incursion in individual privacy, purely motivated by notions of popular morality. It results in the disciplining of love and is inspired by questionable state objectives. If the law intends to protect the safety and sexual rights of women, then does the question of these rights automatically dissolve as she enters the institution of marriage? If it seeks to protect the rights of children born out of wedlock, then can the registration not wait until, and in cases where the womanactually gets pregnant? If the new law posits itself as a progressive force in normalising live-in relationships, then does the associated penalisation not run the risk of state (and also society) convincingly entering the bedrooms? Therefore, the new code requires reconsideration. 

References

AK, Aditya. “Proportionality Test for Aadhaar: The Supreme Court’s two approaches”. Bar and Bench. September 26, 2018. https://www.barandbench.com/columns/proportionality-test-for-aadhaar-the-supreme-courts-two-approaches. 

Bayraktar, Müge and Tezcan, Esma. “Docile Bodies, Subjectivity and Self- Self-Constitution in Women On The Edge of Time.” International Journal of Media, Culture and Literature, 7, 1 (2021): 27-42.  

Beale, Sara Sun. “The Many Faces of Overcriminalization: From Morals and Mattress Tags to Overfederalization.” American University Law Review, 54 (2004): 747.   

Ghose, Sanjoy. “Uniform Cut and Paste? A quick appraisal of Uttarakhand’s Uniform Civil Code.” Bar and Bench. February 6, 2024. https://www.barandbench.com/columns/uniform-cut-and-paste-quick-appraisal-uttarakhand-uniform-civil-code-bill. 

Kumar, Alok Prasanna and Ullal, Prathiksha. “Excluding STs from Uttarakhand UCC exposes a fundamental problem in its concept.” The Print. February 28, 2024. https://theprint.in/opinion/excluding-sts-from-uttarakhand-ucc-exposes-a-fundamental-problem-in-its-concept/1980948/

Gupta, Nidhi. “Myth of Live in Relationships in India.” NLUJ Law Review, 4, no 2 (2017): 19.

Gupta, Poorvi. “How India’s Rape-Survivors End Up Marrying Their Rapists.” Article 14. August  25, 2020. https://www.article-14.com/post/how-india-s-rape-survivors-end-up-marrying-their-rapists.   

Hanisch, Carol. “The Personal is Political.” In Notes from the Second Year: Women’s Liberation: Major writings of the radical feminists, edited by Shulamith Firestone and Anne Koedt, 76-77. New York: Radical Feminism, 1970.  https://repository.duke.edu/dc/wlmpc/wlmms01039 

Matthew, Liz. “Uttarakhand UCC draft ready, likely template for Centre law.” Indian Express. July 1, 2023. https://indianexpress.com/article/political-pulse/uttarakhand-ucc-draft-template-centre-law-8694786/.   

Mayeri, Serena.“Marital Supremacy and the Constitution of the Nonmarital Family.” California Law Review 103, no. 5 (2015): 1277–1352. http://www.jstor.org/stable/24758541.

Menon, Aditya. “Delhi landlords will not rent homes to Muslims, live-in couples.” India Today. October 1, 2012. https://www.indiatoday.in/india/north/story/delhi-landlords-will-not-rent-homes-to-muslims-live-in-couples-117469-2012-09-30. 

Menon, Madhavi. The Law of Desire: Rulings on Sex and Sexuality in India. New Delhi: Speaking Tiger, 2021.

Murray, Melissa. “What’s So New about the New Illegitimacy”, American University Journal Of Gender Social Policy And Law, no 20(3), (2012): 387-436.

Narayan, CL, Narayan M and Deepanshu M. “Live-In Relationships in India—Legal and Psychological Implications.” Journal of Psychosexual Health, 3, no 1, (2021): 18-23. 

Nigam, Aditya. “Uttarakhand Women’s Groups’ Statement on the Uttarakhand UCC Draft Bill.” Kafila. February 8, 2024. https://kafila.online/2024/02/08/uttarakhand-womens-groups-statement-on-the-uttarakhand-ucc-draft-bill/.  

Pal, Pragati. “After Uttarakhand, UCC Likely to be Introduced in Rajasthan, Uttar Pradesh Soon.” News18. February 06, 2024. https://www.news18.com/india/after-uttarakhand-ucc-likely-to-be-introduced-in-rajasthan-uttar-pradesh-soon-8768864.html.  

Prasad, Ravi D and Vivekananda A. Gender-Based Violence: A Shred of Evidence from National Family Health Survey-5. Pune: Population Research Centre, Gokhale Institute of Public Economics, 2023. https://gipe.ac.in/wp-content/uploads/2024/03/Gender-Based-Violence-A-Shred-of-Evidence-from-NFHS-5.pdf   

Rajagopal, Krishnadas. “Same-sex marriage: Supreme Court’s majority view holds that it cannot legalise queer unions.” The Hindu. October 17, 2023. https://www.thehindu.com/news/national/same-sex-marriage-sc-against-legalising-queer-unions-leaves-task-to-parliament/article67429963.ece.   

Ramanathan, Usha. “IMAGES (1920–1950): Reasonable Man, Reasonable Woman and Reasonable Expectations.” In Engendering Law: Essays in Honour of Lokita Sarkar edited by Amita Dhanda and Archana Parashar, 33.  Lucknow: Eastern Book Company, 1999.   

Rath, Basant. “Valentine’s Day Violence In India, A Culture And Policing Divide.” WorldCrunch. February 14, 2018. https://worldcrunch.com/culture-society/valentines-day-violence-in-india-a-culture-and-policing-divide.  

Sharma, Ankit. “Uniform Civil Code bill tabled in Uttarakhand Assembly amid ‘Jai Shri Ram’ chants.” India Today. February 6, 2023. https://www.indiatoday.in/india/story/uniform-civil-code-uttarakhand-assembly-bjp-pushkar-singh-dhami-2498094-2024-02-06.   

Singh, Chander Uday. “Lies, Insistence and Disregard for Evidence: The Journey of ‘Love Jihad’ Laws.” The Wire. December 30, 2022. https://thewire.in/communalism/lies-insistence-and-disregard-for-evidence-the-journey-of-love-jihad-laws. 

The Expert Committee on Uniform Civil Code, The Uttarakhand Uniform Civil Code: Report of the Expert Committee, 2024. https://ucc.uk.gov.in/. 

Titzmann, Fritzi-Marie. “Contesting the Norm? Live-in Relationships in Indian Media Discourses.” South Asia Multidisciplinary Academic Journal, 16, (2017). http://journals.openedition.org/samaj/4371. 

Uma, Saumya. “Not in the Name of Gender Justice: Reflections on Uttarakhand’s UCC.” The Wire. February 9, 2024. https://thewire.in/government/not-in-the-name-of-gender-justice-reflections-on-the-uttarakhands-ucc. 

Valentiner, Dana Sophia. “The Human Right to Sexual Autonomy”. German Law Journal, no 22, (2021): 703–717. https:// doi.org/10.1017/glj.2021.35. 

Vishwanath, Neetika. “Controlling women’s sexual autonomy.” The Hindu. August 31, 2023. https://www.thehindu.com/opinion/op-ed/controlling-womens-sexual-autonomy/article67251409.ece

Yadav, Radhika. “Illegitimacy: An Illegitimate Concept”, Indian Journal of Law and Public Policy, no 3, (2016): 87.