Personal Liberty Over Social Convention: The Madhya Pradesh High Court’s Stand on Live-In Relationships

Ridham Verma & Others v. State of Madhya Pradesh & Others

WP No. 19028 of 2026 | High Court of M.P. at Indore | Decided: 3rd June 2026

Introduction

The intersection of personal liberty and social convention has long been a contested terrain in Indian jurisprudence. In a significant pronouncement delivered on 3rd June 2026, the High Court of Madhya Pradesh at Indore, in the matter of Ridham Verma and Others v. The State of Madhya Pradesh and Others (Writ Petition No. 19028 of 2026), reaffirmed the constitutional primacy of individual autonomy over societal norms by extending police protection to two adults residing together outside the institution of wedlock.

Background and Facts

The petitioners a 20-year-old woman (Petitioner No. 1) and a 26-year-old man (Petitioner No. 2) had chosen to reside together as partners against the expressed wishes of their respective families. Apprehending hostile and potentially violent intervention from the parents of Petitioner No. 1, the couple approached the High Court by way of a writ petition. They sought directions compelling the respondent police authorities to provide adequate protection, sought restrain against the filing of false cases against Petitioner No. 2, and prayed for punitive action against Respondent No. 4, who was alleged to be a source of threat and intimidation.

Submissions of the Petitioners

The petitioners, represented by Shri Rakesh Kumar Sharma, anchored their case firmly on the constitutional right to personal liberty guaranteed under Article 21 of the Constitution of India. Counsel placed reliance upon the Hon’ble Supreme Court’s decision in Nandakumar v. State of Kerala, reported as (2018) 16 SCC 602, wherein the Apex Court, while adjudicating a habeas corpus petition, unequivocally held that two adults have the right to live together even outside the institution of marriage, irrespective of whether they are legally competent to solemnise a valid marriage. It was argued that Petitioner No. 1, being above the age of eighteen years, is a major in law, and her voluntary and informed decision to reside with Petitioner No. 2 must be recognised and protected from external coercion.

Submissions of the Respondent/State

The State, represented by Government Advocate Shri Anshul Rajpurohit, opposed the reliefs sought on two principal grounds. First, it was contended that Petitioner No. 1, at 20 years of age, had not yet attained the legal marriageable age of 21 years, and accordingly, no ground for judicial interference was made out. Second, and notably, the State advanced a broader societal argument, submitting that the grant of protection in such circumstances would be contrary to the larger public interest.

Legal Precedent Relied Upon

The Court placed considerable weight upon Nandakumar v. State of Kerala [(2018) 16 SCC 602], extracting the operative portion of paragraph 10 of that judgment. The Supreme Court therein observed that as long as both individuals are majors, they possess the right to live together even outside wedlock, and that the legislature itself has recognised the concept of live-in relationships through the provisions of the Protection of Women from Domestic Violence Act, 2005. This legislative recognition, noted the Court, lends further institutional legitimacy to such relationships under Indian law.

Court’s Analysis and Reasoning

Justice Rajesh Kumar Gupta, after carefully weighing the rival contentions and examining the record, held that the decisive criterion is the legal status of majority, not the attainment of marriageable age. Since Petitioner No. 1 had crossed the threshold of eighteen years, she qualifies as a major under Indian law and is fully entitled to exercise her autonomy in matters of personal residence and companionship. The Court firmly held that her choice to reside with Petitioner No. 2 is a manifestation of her personal liberty, and such a choice must be insulated from interference by external forces, including family members. The State’s contention regarding the promotion of promiscuousness was implicitly rejected as constitutionally untenable in the face of established Supreme Court authority.

Final Order and Directions

The petition was allowed in its entirety. The respondent police authorities were directed to provide adequate protection to the petitioners. A copy of the order was directed to be forwarded to the office of the Advocate General for communication to the Deputy Commissioner of Police, Zone-1, Indore, for prompt compliance. Additionally, the concerned Station House Officer of the relevant Police Station was directed to share his or her mobile number with the petitioners to ensure their accessibility in any emergency situation. The petitioners’ counsel was also directed to apprise his clients of the concerns expressed by the Court.

Significance and Conclusion

This judgment represents a meaningful affirmation of the doctrine that personal liberty is not contingent upon social approval or compliance with matrimonial norms. By holding that majority and not marriageable age is the operative threshold for the exercise of the right to cohabit, the Madhya Pradesh High Court has reinforced a progressive interpretation of individual freedom. It underscores that the courts of India remain vigilant guardians of the fundamental rights of citizens against arbitrary and coercive interference, whether from private actors or the State.

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