Madhya Pradesh High Court

Right of major individuals to choose their life partner is an essential facet of personal dignity and liberty.

Sakshi Jain vs The State Of Madhya Pradesh

Madhya Pradesh High CourtJUDGMENT: April 24, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioners, both being of legal age (major), solemnized their marriage against the wishes of the family members of Petitioner No. 1

Source reference: para 2

They provided evidence of their majority through educational certificates and submitted a marriage certificate issued by Nagar Nigam Jabalpur dated 10.04.2026

Source reference: para 2, 5

The petitioners alleged that the family of Petitioner No. 1 is threatening to kill them or falsely implicate them in criminal proceedings to disrupt their peaceful matrimonial life in Firozabad, U.P.

Source reference: para 2

Consequently, they approached the High Court seeking police protection and a direction to restrain authorities from taking coercive action based on private complaints

Source reference: para 1
02

Issues

1. Whether adult citizens have a fundamental right to choose their life partner and live together without interference from family or State authorities

Source reference: para 2

2. Whether the court should direct police authorities to provide protection to a couple apprehending violence due to an inter-caste or non-consensual (by parents) marriage

Source reference: para 7
03

Law Applied

The court primarily applied the constitutional principle of personal liberty and dignity as interpreted by the Supreme Court of India.

Source reference: no citation

Lata Singh v. State of U.P. and Another (2006) 5 SCC 475, which established that a major is free to marry anyone they like and that "honour" killings or harassment by parents for inter-caste marriages are illegal acts that must be sternly dealt with

Source reference: para 6

Shakti Vahini v. Union of India and Others (2018) 7 SCC 192, reinforcing that the right to choose a partner is an integral part of the right to life and liberty

Source reference: para 2
04

Reasoning

The court observed that since the petitioners’ majority was undisputed and the marriage was evidenced by a valid certificate, no person or authority had the legal right to interfere with their choice

Source reference: para 2, 5

The court reasoned that any obstruction to an individual's choice of partner constitutes a direct assault on human dignity

Source reference: para 2

Following the mandate in Lata Singh, the court determined that the administration has a duty to ensure that such couples are not subjected to threats or acts of violence

Source reference: para 6

The court found that the petitioners’ apprehension of harm necessitated judicial intervention to safeguard their life and liberty under Article 21 of the Constitution

Source reference: para 7
05

Holding

As the petitioners are majors, they are legally entitled to reside together, and the police must ensure they are not harassed or threatened by anyone, including family members

The Court disposed of the petition by directing the Superintendent of Police, Jabalpur, and the Station House Officer of Police Station Madhotal, Jabalpur, to take appropriate steps to provide protection to the petitioners’ life and liberty upon their approach

Source reference: para 7
Madhya Pradesh High Court

Original Court PDF

Sakshi JainvsThe State Of Madhya Pradesh

Madhya Pradesh High Court · April 24, 2026

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