Supreme Court Extends S.498A IPC To Live-In Relationships Which Are 'Relationships In The Nature Of...
CLAT PG ● Lower importance 3 August 2026
Supreme Court Extends S.498A IPC To Live-In Relationships Which Are 'Relationships In The Nature Of...

What happened

The Supreme Court ruled that Section 498A IPC, which penalises cruelty by a husband or his relatives, applies to live-in relationships that qualify as 'relationships in the nature of marriage.' A formal marriage ceremony is not a prerequisite to file a domestic cruelty complaint. This extends the Protection of Women from Domestic Violence Act's definitional framework into the IPC cruelty provision, significantly expanding protection for women in long-term cohabitation arrangements recognised under law.

Why it matters

Section 498A IPC (now Section 84 BNS) criminalises cruelty inflicted by a husband or his relatives upon a wife. Traditionally, its application required proof of a legally valid marriage. This ruling disrupts that prerequisite by holding that women in 'relationships in the nature of marriage' — a phrase already embedded in the Protection of Women from Domestic Violence Act, 2005 (PWDVA) — can invoke S.498A protection.

The PWDVA's Section 2(f) defines 'domestic relationship' to include 'relationships in the nature of marriage,' which the Supreme Court has previously interpreted in D. Velusamy v. D. Patchaiammal (2010) to require cohabitation, shared household, and public representation as a couple, among other factors. That case excluded casual liaisons or 'keep' relationships from this definition.

The present ruling imports this PWDVA standard into the S.498A IPC framework. The constitutional underpinning is Article 21 — the right to life with dignity — and Article 14's guarantee of equal protection, ensuring women in long-term cohabitation are not left without criminal remedy merely because a marriage registration is absent.

For CLAT PG aspirants, this ruling sits at the intersection of constitutional rights (Art. 14, 21), statutory interpretation (S.498A IPC / S.84 BNS, PWDVA S.2(f)), and landmark precedent (Velusamy). The examiner can test the doctrinal standard, the Velusamy conditions, or the constitutional basis of the extension.
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