Question

What is the scope of analysis required to determine if a relationship falls within the expression “relationship in the nature of marriage” under Section 2(f) of the DV Act?

• A. Considering the number of children born in a live in relationship.
• B. Considering only the cohabitation period of the relationship and their emotional connectivity.
• C. Conducting a close analysis of the entire interpersonal relationship, taking into account all facets.
• D. Evaluating only the financial aspects and mutual agreements of the relationship, and if there is any written agreement between the partner.
• A. Indra Sarma v. V.K.V. Sarma (2013) 15 SCC 755)
• B. Hiral P Harsora v. Kusum Harsora, (Manu/SC/1269/2016)
• C. Uma Narayanan v. Priya Krishna Prasad, (Laws (Mad) 2008-8-28)
• D. D Velusamy v. D Patchaiammal (AIR 2011 SC 479)
• A. Live a life that meets at least the bare minimum needs for survival and basic well. being.
• B. Live a life that is consistent with her standard of living which she is accustomed.
• C. Live a life that is consistent with her parent's standard of living.
• D. Live a life which can cover her medical expenses and expenses incurred due to litigation of domestic violence.
• A. Satish Chander Ahuja v. Sneha Ahuja, AIR 2020 SC 2483
• B. Rupa Ashok Hurra v. Ashok Hurra AIR 2002 SC 177
• C. S.R. Batra v. Tarun Batra (2007) 3 SCC 169
• D. B.R. Mehta Vs. Atma Devi (1987) 4 SCC 183
• A. No, as per the interpretation of statute 'wife' means legally wedded wife and includes who has been divorced by, or has obtained a divorce from her husband.
• B. Yes, a woman in a live in relationship can claim maintenance u/s 125, CrPC as strict proof of marriage is not necessary and maintenance cannot be denied if evidence suggests cohabitation.
• C. A woman in live in relationship can only claim maintenance if she has been cohabiting for more than five years and dependent children from the relationship.
• D. A woman in live in relationship can claim maintenance only through a civil suit as the protection of women from domestic violence act 2005 (PWDVA) does not apply to live in relationships.

Answer 1

The Correct Option is C

Step 1: Understanding the Question:
The question asks what kind of examination a court must undertake to decide if a live-in relationship qualifies as a "relationship in the nature of marriage" under the Protection of Women from Domestic Violence Act, 2005 (DV Act).
Step 2: Detailed Explanation:
The provided passage from {Indra Sarma v. V.K.V. Sarma} gives a direct answer. The Supreme Court states: "...when we examine whether a relationship will fall within the expression 'relationship in the nature of marriage' ... we should have a close analysis of the entire relationship Invariably, it may be a question of fact and degree...".
This means the court cannot look at isolated factors. It must conduct a holistic review of the relationship. Option (C) perfectly captures this requirement. Options (A), (B), and (D) are too narrow as they focus on specific aspects (children, cohabitation period, finances) rather than the "entire interpersonal relationship" with "all facets."
Step 3: Final Answer:
The court must conduct a close and holistic analysis of the entire relationship, considering all its facets, to determine if it is 'in the nature of marriage'.

Answer 2

The question asks how a court should decide whether a live-in relationship qualifies as one "in the nature of marriage" under Section 2(f) of the DV Act. Testing each proposed approach against what a fact-and-degree inquiry actually needs shows which one fits.

1. Considering the number of children born in the relationship: The number of children might be one piece of evidence about the relationship's stability, but it says nothing by itself about whether the couple lived as spouses in every other respect, so using it alone would miss most of what matters.
2. Considering only the cohabitation period and emotional connectivity: Duration and emotional closeness are relevant, but they are only two threads among many (financial arrangements, social perception, shared responsibilities, intention). Looking at only these two would leave out factors that could just as easily tip the analysis the other way.
3. Conducting a close analysis of the entire interpersonal relationship, taking into account all facets: Since whether a relationship is "in the nature of marriage" is a question of fact and degree, no single factor can be decisive on its own, everything about how the couple actually lived, presented themselves, and organised their lives together needs to be weighed together.
4. Evaluating only financial aspects, mutual agreements, and any written agreement: Financial interdependence is one relevant thread, but restricting the inquiry to money and paperwork ignores the social, domestic, and personal dimensions of a relationship that are just as relevant to whether it resembles a marriage.

Since no single factor, whether children, duration, emotion, or finances, can decide this question alone, the only approach that actually fits a fact-and-degree test is one that weighs the relationship as a whole.

Therefore, the correct answer is conducting a close analysis of the entire interpersonal relationship, taking into account all facets.

Answer 3

Step 1: Understanding the Question:
This is a direct, knowledge-based question asking to identify the landmark Supreme Court case that struck down the words "adult male" from the definition of "respondent" in the DV Act.
Step 2: Detailed Explanation:
Section 2(q) of the DV Act originally defined a "respondent" as any "adult male person" who is in a domestic relationship with the aggrieved person. This meant that a woman could not file a complaint against another woman (e.g., her mother-in-law or sister-in-law) or against a male who was not an adult.
In the case of Hiral P Harsora v. Kusum Harsora (2016), the Supreme Court found this definition to be discriminatory and violative of Article 14 of the Constitution. The court held that domestic violence is not gender-specific and can be perpetrated by any member of the family, regardless of their gender or age. Consequently, the court struck down the words "adult male" from Section 2(q), making the provision gender-neutral. This means a complaint can now be filed against any person, male or female, adult or minor, who is in a domestic relationship with the aggrieved woman.
Step 3: Final Answer:
The correct case is {Hiral P Harsora v. Kusum Harsora}.

Answer 4

The question is asking to identify the exact Supreme Court decision that struck down (read down) the words "adult male" appearing in the definition of "respondent" under Section 2(q) of the Protection of Women from Domestic Violence Act, 2005. Since all four options are case citations, the correct approach is to test what each case actually decided and check whether that holding matches the specific act of reading down these words.

1. Indra Sarma v. V.K.V. Sarma: This case dealt with whether a woman in a live-in relationship with a married man qualifies as being in a "relationship in the nature of marriage" and is therefore an "aggrieved person" entitled to protection under the Act. The Court laid down guiding factors to test such relationships. It did not touch upon, examine, or strike down the words "adult male" in Section 2(q); its subject matter is confined to who counts as an aggrieved person, not who can be a respondent.
2. Hiral P Harsora v. Kusum Harsora: This case directly confronted the definition of "respondent" in Section 2(q), which at the time restricted a complaint to being filed only against an "adult male person". The Court held that this restriction excluded relief against female relatives, such as a mother-in-law or sister-in-law, who may equally be perpetrators of domestic violence, and that this exclusion had no rational nexus with the object of the Act. On that basis, the words "adult male" were read down and removed from Section 2(q), making the provision gender and age neutral. This is an exact match for the case being asked about.
3. Uma Narayanan v. Priya Krishna Prasad: This is a Madras High Court decision, not a Supreme Court ruling, and it does not carry the constitutional force needed to read down a statutory provision across the country. Since the question specifically asks about a Supreme Court decision, this option can be ruled out purely on the forum in which it was decided.
4. D Velusamy v. D Patchaiammal: This case set out the essential ingredients a live-in relationship must satisfy to be treated as being "in the nature of marriage" for the purposes of claiming benefits under the Act. Like Indra Sarma, its focus is on the eligibility of the aggrieved woman's relationship status, not on the gender restriction placed on who can be proceeded against as a respondent.

Only the Harsora decision specifically addresses and removes the words "adult male" from Section 2(q); the other three cases deal with entirely different questions concerning live-in relationships or forum-related distinctions.

Therefore, the correct answer is Hiral P Harsora v. Kusum Harsora.

Answer 5

Step 1: Understanding the Question:
The question asks about the standard or purpose of monetary relief that can be granted under Section 20 of the DV Act.
Step 2: Detailed Explanation:
Section 20 of the DV Act allows the Magistrate to direct the respondent to pay monetary relief to meet the expenses incurred and losses suffered by the aggrieved person. The objective of such relief, particularly the maintenance component, is not just for bare subsistence but to enable the aggrieved person to maintain a lifestyle commensurate with the one she was used to in the shared household.


(A) This describes the standard of "bare subsistence," which is often associated with Section 125 CrPC, but the DV Act aims for a higher standard.
(B) This correctly states the established legal principle. The courts have consistently held that maintenance should befit the standard of living the person was accustomed to. Section 20(2) also states the relief must be "adequate, fair and reasonable and consistent with the standard of living to which the aggrieved person is accustomed."
(C) The parent's standard of living is irrelevant.
(D) While medical and litigation expenses can be covered under Section 20, this option is incomplete. It only lists some components of the relief, whereas option (B) describes the overall guiding principle or standard for the maintenance part of the relief.
Step 3: Final Answer:
The monetary relief under the DV Act is intended to allow the aggrieved person to maintain a standard of living she was accustomed to.

Answer 6

The question asks what standard of living the monetary relief under Section 20 of the Protection of Women from Domestic Violence Act, 2005 is meant to secure for the aggrieved person. Each option proposes a different benchmark, so testing each benchmark against the actual wording and purpose of Section 20 will identify the correct one.

1. Live a life that meets at least the bare minimum needs for survival and basic well-being: This describes a subsistence-level standard, similar to the older approach taken under maintenance provisions such as Section 125 of the Code of Criminal Procedure, which was historically read as guarding against destitution rather than preserving a particular lifestyle. The Domestic Violence Act was drafted specifically to go beyond this bare subsistence approach, so this option understates the protection Section 20 offers.
2. Live a life that is consistent with her standard of living which she is accustomed to: Section 20(2) of the Act expressly requires that the monetary relief granted be "adequate, fair and reasonable and consistent with the standard of living to which the aggrieved person is accustomed." This option reproduces that statutory standard almost word for word, and courts have consistently applied it to mean that the aggrieved person's pre-existing lifestyle in the shared household is the benchmark, not mere survival.
3. Live a life that is consistent with her parent's standard of living: The statute anchors the standard to the aggrieved person's own accustomed lifestyle in the domestic relationship, not to any third party's lifestyle, including her parents. There is no provision in Section 20 that references the parental household as a benchmark, so this option has no statutory basis.
4. Live a life which can cover her medical expenses and expenses incurred due to litigation of domestic violence: Section 20(1) does list medical expenses and litigation costs as distinct heads of relief a Magistrate can order, but these are specific components alongside maintenance, not the overarching standard by which the maintenance component itself is measured. This option describes only part of what Section 20 covers, so it cannot be the complete answer to the standard-of-living question.

Testing the statutory text against each option shows that only the "accustomed standard of living" formulation matches Section 20(2) directly.

Therefore, the correct answer is Live a life that is consistent with her standard of living which she is accustomed to.

Answer 7

Step 1: Understanding the Question:
The question asks to identify a recent, landmark three-judge bench Supreme Court decision that gave a broad and purposeful interpretation to the term "shared household" under the DV Act.
Step 2: Detailed Explanation:
The interpretation of "shared household" under Section 2(s) of the DV Act has been a contentious issue.


In the earlier case of S.R. Batra v. Tarun Batra (2007), a two-judge bench had given a very restrictive interpretation, holding that a "shared household" would only mean a house owned or tenanted by the husband, or a house belonging to the joint family of which the husband is a member.
This restrictive view caused significant hardship to women, particularly those living in houses owned by their in-laws.
The issue was reconsidered by a larger three-judge bench in the case of Satish Chander Ahuja v. Sneha Ahuja (2020). This bench overruled the decision in *S.R. Batra*. It held that the term "shared household" should be interpreted literally and purposefully. A shared household is where the aggrieved person "lives or at any stage has lived in a domestic relationship," irrespective of whether she has any right, title, or interest in the said household. The court emphasized that the living must have some degree of permanency, not be merely fleeting or casual. The text in the question is a direct reflection of the ratio in this case.
Step 3: Final Answer:
The case that provided this expansive interpretation and overruled *S.R. Batra* is {Satish Chander Ahuja v. Sneha Ahuja}.

Answer 8

The question describes a specific ruling: a three-judge bench of the Supreme Court which interpreted "shared household" to require some degree of permanency in residence, rejecting mere fleeting or casual stays. Matching this description to each cited case will identify the correct one.

1. Satish Chander Ahuja v. Sneha Ahuja: decided by a three-judge bench of the Supreme Court, this ruling directly interpreted the phrase "lives or at any stage has lived in a domestic relationship" under Section 2(s) of the Domestic Violence Act, holding that the residence must have some permanency and that fleeting or casual stays would not qualify as a shared household. This matches the description in the question on every count, the bench strength, the statutory phrase interpreted, and the exact permanency requirement.
2. Rupa Ashok Hurra v. Ashok Hurra: this case is a constitutional law landmark that created the curative petition remedy for correcting errors even after a review petition is dismissed. It has no connection to domestic violence law or the concept of a shared household.
3. S.R. Batra v. Tarun Batra: decided by a two-judge bench, this earlier case took a narrow view, restricting a shared household to premises owned or rented by the husband or his joint family. It did not use the permanency-based test described in the question, and was in fact the decision later overturned by the reasoning the question describes.
4. B.R. Mehta v. Atma Devi: an older ruling dealing with the concept of a licensee's right to continue in occupation of premises under general property and tenancy principles, decided well before the Domestic Violence Act existed in 2005. It cannot be the source of an interpretation of a statutory term that did not yet exist at the time.

Only the Satish Chander Ahuja ruling fits the bench strength, statutory language, and permanency test described in the question.

Therefore, the correct answer is Satish Chander Ahuja v. Sneha Ahuja.

Answer 9

Step 1: Understanding the Question:
The question asks about the eligibility of a woman in a long-term live-in relationship to claim maintenance under Section 125 of the Code of Criminal Procedure.
Step 2: Detailed Explanation:
Section 125 of the CrPC is a social welfare provision designed to prevent vagrancy and destitution. While the section uses the word "wife," the Supreme Court has interpreted it broadly to achieve the object of the law.


In a series of judgments, including {Chanmuniya v. Virendra Kumar Singh Kushwaha} and {D. Velusamy v. D. Patchaiammal}, the Supreme Court has held that for the purpose of Section 125 CrPC, a woman who has been in a long-term live-in relationship, which is in the nature of marriage, is entitled to maintenance.
The reasoning is that strict proof of a formal wedding is not required in proceedings under Section 125. If a man and woman have cohabited for a long period as husband and wife, the law will presume them to be married, and the man will be estopped from denying the marriage solely to evade his duty to maintain her.
This makes option (B) the correct statement of the law. Option (A) reflects a very old and outdated literal interpretation. Option (C) imposes arbitrary conditions (like a five-year minimum) that are not required by law. Option (D) is incorrect as Section 125 CrPC provides a direct and speedy remedy.
Step 3: Final Answer:
The law has evolved to allow women in long-term live-in relationships to claim maintenance under Section 125 CrPC, based on the presumption of marriage arising from prolonged cohabitation.

Answer 10

The question asks whether a woman in a live-in relationship, despite not being a legally wedded wife, can claim maintenance under Section 125 of the Code of Criminal Procedure. Each option makes a different legal claim about this, so checking each against how courts have actually applied Section 125 will resolve it.

1. No, as 'wife' means only a legally wedded wife or a woman divorced by her husband: this reflects the literal, narrow reading of the word "wife" that existed before the Supreme Court expanded its scope through a series of decisions on long-term cohabitation. It no longer reflects the current position of law, so it cannot be the correct answer.
2. Yes, since strict proof of marriage is not necessary and maintenance cannot be denied where evidence shows cohabitation: in cases such as Chanmuniya v. Virendra Kumar Singh Kushwaha and D. Velusamy v. D. Patchaiammal, the Supreme Court held that Section 125, being a social welfare provision meant to prevent vagrancy and destitution, must be read broadly. Where a man and woman have cohabited for a long period in a manner resembling marriage, the law presumes a valid marriage and does not require formal documentary proof of a wedding ceremony before granting maintenance. This matches the current, correct legal position.
3. Only if cohabitation exceeds five years and there are dependent children: courts have never imposed a rigid five-year cohabitation threshold or a mandatory requirement of dependent children as preconditions for maintenance under Section 125; these are invented conditions with no statutory or judicial basis.
4. Only through a civil suit, since the Domestic Violence Act does not apply to live-in relationships: this is doubly incorrect, since the Domestic Violence Act does in fact extend protection to women in relationships "in the nature of marriage," and more importantly Section 125 CrPC itself, being a separate and faster criminal remedy, is available directly to such women without needing a civil suit.

Only the second option accurately reflects the judicially expanded scope of Section 125 for women in long-term live-in relationships.

Therefore, the correct answer is Yes, a woman in a live-in relationship can claim maintenance under Section 125 CrPC, as strict proof of marriage is not necessary and maintenance cannot be denied if evidence suggests cohabitation.