SUPREME COURT CONJUGAL RIGHTS: POLITY

NEWS: Wife can get maintenance even if she defies court order to go back to husband: what SC has ruled and why

WHAT’S IN THE NEWS?

The Supreme Court of India has clarified that proceedings related to restitution of conjugal rights (Section 9, Hindu Marriage Act) and maintenance (Section 125, CrPC) are independent. A spouse is entitled to maintenance even if they refuse to comply with a court decree for restitution of conjugal rights, ensuring financial security for the dependent spouse.

Conjugal Rights: Definition and Legal Basis

  • Definition: Conjugal rights are the legal entitlements of married couples to cohabit and enjoy companionship. They stem from the marital bond and aim to preserve the institution of marriage.
  • Legal Provisions Across Laws:
  • Hindu Marriage Act, 1955: Section 9 permits a spouse to approach the court for restitution if the other spouse withdraws without valid reason.
  • Muslim Personal Law: Recognizes the concept and allows similar petitions.
  • Christian Divorce Act, 1869: Includes provisions for restoring conjugal rights.
  • Criminal Provisions: Section 125 of the Code of Criminal Procedure (CrPC) mandates maintenance for a spouse unable to sustain themselves, regardless of conjugal cohabitation.

Restitution of Conjugal Rights

  • Purpose: Aims to prevent marital breakdown by providing a legal remedy to an aggrieved spouse through court intervention.
  • Nature: Encourages reconciliation and resumption of cohabitation.
  • Procedure: Requires the petitioner to prove unjustified withdrawal by the other spouse.

Judicial Interpretations: Balancing Rights and Limitations

  1. T. Sareetha v. T. Venkata Subbaiah (1983):
    • The Andhra Pradesh High Court struck down Section 9 of the Hindu Marriage Act, terming it unconstitutional.
    • Reasoning: It violated individual freedoms, particularly the right to privacy and bodily autonomy.
  1. Saroj Rani v. Sudarshan Kumar Chadha (1984):
    • The Supreme Court overturned the earlier decision, upholding Section 9.
    • Justification: The provision was deemed essential for promoting marital reconciliation and preventing discord.

Maintenance: Independent of Restitution of Conjugal Rights

  • Section 125, CrPC: A spouse unable to support themselves can seek maintenance irrespective of their decision to cohabit.
  • Supreme Court Ruling:
  • Maintenance rights are not conditional upon fulfilling restitution decrees.
  • This ensures financial security and addresses dependency concerns, especially in cases of estranged relationships.

Criticism and Challenges

  1. Violation of Privacy and Autonomy: Compelling cohabitation may infringe upon individual rights to privacy and autonomy.
  2. Risk of Coercion: The provision can be misused to pressure estranged spouses, particularly women, into returning to potentially abusive environments.
  3. Patriarchal Roots: Critics argue it reflects outdated norms treating women as subordinate to their spouses.

Relevance in Modern Context

  • Evolving Marital Dynamics: Emphasis on individual freedoms and consent in marital relationships has sparked debates over restitution provisions.
  • Balancing Tradition and Rights: Legal systems must ensure fairness without compromising personal freedoms.

Source: https://indianexpress.com/article/explained/explained-law/wife-maintenance-court-order-9780480/#:~:text=The%20Supreme%20Court%20has%20ruled,decree%20for%20the%20restitution%20of