Right of Major Partners Below Marriageable Age to Cohabit and Seek Police Protection:
A Detailed Commentary on Priya Suman v. State of Rajasthan, 2025 RJ-JP 48775
Court: High Court of Judicature for Rajasthan, Jaipur Bench
Case: Priya Suman D/o Shri Giriraj Suman & Anr. v. State of Rajasthan & Ors.
Case No.: S.B. Criminal Writ Petition No. 1537/2025
Judge: Hon’ble Mr. Justice Anoop Kumar Dhand
Date of Order: 01 December 2025
Disposition: Writ petition disposed of with directions to the Nodal Officer (SHO) to consider petitioners’ representation and, if threat is found genuine, to provide protection.
I. Introduction
The decision in Priya Suman v. State of Rajasthan is a significant addition to the growing body of jurisprudence on the rights of consenting adults in live-in relationships, particularly where one partner has not yet attained the statutory “marriageable age” under personal law but has crossed the threshold of legal majority.
The petitioners, Priya Suman, an 18-year-old woman, and Rahul Prajapati, a 19-year-old man, approached the Rajasthan High Court seeking protection for their lives and personal liberty. They intend to marry after Rahul attains the age of 21 years (the statutory age for a Hindu male to marry), but until then, they have chosen to live together in a live-in relationship, supported by a written live-in relationship agreement dated 27.10.2025.
Priya’s family members (respondents 6–8) strongly oppose this decision and allegedly issued threats to the couple. Despite approaching the Nodal Officer/SHO, Police Station Kunadi, Kota, with written representations on 13.11.2025 and 17.11.2025, no effective protection was provided. The couple therefore invoked the High Court’s writ jurisdiction, seeking:
- Protection from harm at the hands of Priya’s family members and their associates; and
- Directions that the police not harass or unduly detain them against their will.
The State opposed the petition, arguing that because Rahul is below 21 years, he is not legally eligible to marry under the Hindu Marriage Act, 1955, and, by extension, should not be allowed to live in a live-in relationship with Priya.
The central issue may be framed thus:
- Whether two individuals, both above 18 years of age but where the male partner has not yet attained 21 years (the statutory marriageable age for a Hindu male), are entitled to cohabit in a live-in relationship and claim police protection for their life and liberty under Article 21 of the Constitution?
Justice Anoop Kumar Dhand’s decision firmly answers this in the affirmative and aligns Rajasthan’s jurisprudence with a strong line of Supreme Court and High Court authority emphasizing the primacy of Article 21 and individual autonomy over social disapproval or technical violations of marriage laws.
II. Summary of the Judgment
A. Factual Matrix
- Petitioner No. 1, Priya Suman, is 18 years old.
- Petitioner No. 2, Rahul Prajapati, is 19 years old.
- Both are Hindus, living together in a live-in relationship, supported by an agreement dated 27.10.2025.
- They intend to marry after Rahul turns 21 and acquires the statutory capacity to marry under Section 5(iii) of the Hindu Marriage Act, 1955.
- Priya’s family strongly opposes the relationship and has allegedly threatened the couple with harm to their life and liberty.
- The couple submitted protection representations to the Nodal Officer/SHO on 13.11.2025 and 17.11.2025, but no action followed.
B. Arguments
1. Petitioners’ Contentions
- Both petitioners have attained the age of majority (18+), and therefore have the capacity to decide where and with whom to live.
- They rely on Nandakumar & Anr. v. State of Kerala & Ors., Criminal Appeal No. 597/2018, where the Supreme Court held:
- A marriage where the groom is below 21 is not void but at best voidable under Sections 5 and 12 of the Hindu Marriage Act.
- Even if not lawfully married, two adults have a right to live together in a live-in relationship, which is recognized under the Protection of Women from Domestic Violence Act, 2005.
- The petitioners argue that threats from family members directly impinge upon their Article 21 right to life and personal liberty.
- They seek protection from the police against these threats.
2. State’s/Prosecution’s Contentions
- The learned Public Prosecutor contended that:
- Under Section 5 of the Hindu Marriage Act, minimum marriageable age is:
- 21 years for a male bridegroom,
- 18 years for a female bride.
- Since Rahul has not yet attained 21 years, he is not eligible to marry.
- By extension, he should neither be permitted to solemnize marriage nor to cohabit in a live-in relationship.
- Therefore, the writ petition seeking police protection should be rejected.
- Under Section 5 of the Hindu Marriage Act, minimum marriageable age is:
C. Court’s Findings and Directions
The Court’s key conclusions can be summarised as follows:
- Both petitioners are majors (above 18) and have attained the age of majority and maturity sufficient to make life choices.
- The only legal “rider” is that Rahul has not attained the statutory marriageable age of 21 for a Hindu male.
- This statutory bar on marriage does not extinguish their fundamental right under Article 21 to live together or to seek protection of life and liberty.
- Relying on Supreme Court and High Court precedents, the Court holds that:
- A live-in relationship between two consenting adults does not constitute an offence (Lata Singh).
- Even if a marriage is invalid, void or voidable, or even if there is no marriage at all, the State’s obligation to protect life and liberty under Article 21 remains intact.
- Live-in relationships are legally recognized for certain purposes – notably under the Protection of Women from Domestic Violence Act, 2005.
- The Court reiterates that:
- Article 21 stands on a “much higher pedestal” and is to be protected regardless of the validity of marriage.
- Under Section 29 of the Rajasthan Police Act, 2007, every police officer has a statutory duty to protect life and personal liberty.
- On this basis, the Court:
- Disposes of the writ petition,
- Directs/expects the Nodal Officer (SHO, Police Station Kunadi, Kota) to:
- Consider and decide the petitioners’ representations in accordance with law; and
- After analysing threat perception, if necessary, provide adequate security and protection to the petitioners.
- Clarifies that nothing said in this order shall prejudice any existing or future civil or criminal proceedings against the petitioners.
III. Detailed Analysis
A. Core Legal Questions
The case effectively posed three interconnected questions:
- Whether two adults, both above 18 but where the male is below 21, are entitled to cohabit in a live-in relationship without attracting criminality or illegality.
- Whether such individuals can validly invoke Article 21 to claim protection of life and personal liberty from threats posed by their families or others opposed to their relationship.
- Whether the police can lawfully refuse or delay providing protection on the ground that their relationship may violate or conflict with the statutory scheme governing marriageable age under the Hindu Marriage Act, 1955.
The Court answers these questions by emphasizing the distinction between marriage law (Hindu Marriage Act, etc.) and fundamental rights (Article 21), holding that the latter cannot be eclipsed merely because of technical non-compliance with the former.
B. Precedents and Authorities Relied Upon
1. Nandakumar & Anr. v. State of Kerala & Ors. (Criminal Appeal No. 597 of 2018)
This Supreme Court judgment is a cornerstone of the reasoning in Priya Suman. In Nandakumar:
- The groom was below 21 at the time of marriage, and a habeas corpus petition by the bride’s father had led to the High Court delivering custody of the girl to her father.
- The Supreme Court reversed that outcome, noting:
- Both parties were majors.
- A marriage where the groom is under 21 is not a void marriage under the Hindu Marriage Act; at most, it may be a voidable marriage.
- Even assuming some defect in the marriage, the couple had a right to live together even outside wedlock.
- The Court crucially observed:
“Even if they were not competent to enter into wedlock (which position itself is disputed), they have right to live together even outside wedlock. It would not be out of place to mention that ‘live-in relationship’ is now recognized by the Legislature itself which has found its place under the provisions of the Protection of Women from Domestic Violence Act, 2005.”
In Priya Suman, the Rajasthan High Court uses this reasoning to demolish the State’s argument that lack of marriageable age automatically bars live-in cohabitation. Once both individuals are 18+, their decision to live together enjoys constitutional protection.
2. Lata Singh v. State Of U.P. & Anr., AIR 2006 SC 2522
In Lata Singh, the Supreme Court strongly defended the right of a major woman to marry or cohabit with a partner of her choice, denounced “honour” crimes, and directed the police to protect such couples. The key takeaway:
- A live-in relationship between two consenting adults does not amount to any offence.
- Family members have no legal right to threaten or harm adult children for their choices in marriage or relationships.
Justice Dhand invokes Lata Singh to reaffirm that a live-in relationship between two major individuals is not criminal per se, and that police protection cannot be denied on that basis.
3. Rekha Meghwanshi & Anr. v. State of Rajasthan & Ors., S.B. Cr. Writ Petition No. 1730/2024 (Rajasthan HC, Jodhpur)
This coordinate bench decision at the Principal Seat, Jodhpur, dealt with a similar factual situation:
- Petitioner No. 1 was born on 02.01.2004; Petitioner No. 2 on 08.05.2005.
- Both were in a live-in relationship, intending to marry once the younger partner attained marriageable age.
- They faced threats from their families and sought police protection.
The Jodhpur Bench held, in emphatic terms:
“Constitutional Fundamental Right under Article 21 of Constitution of India stands on a much higher pedestal. Being sacrosanct under the Constitutional Scheme it must be protected, regardless of the solemnization of an invalid or void marriage or even the absence of any marriage between the parties.”
And further:
“Mere fact that petitioners are not of marriageable age in the present case would not deprive them of their fundamental right, as envisaged in Constitution of India, being citizens of India.”
Justice Dhand explicitly quotes and follows this reasoning, indicating a conscious effort to create consistency within the Rajasthan High Court across its benches.
4. Punjab & Haryana High Court Precedents
The Jodhpur Bench in Rekha Meghwanshi, and by extension Justice Dhand in Priya Suman, cite multiple P&H High Court decisions, especially:
- Seema Kaur & Anr. v. State of Punjab & Ors., CRWP No. 4725/2021
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As well as references in that judgment to earlier P&H decisions:
- Rajwinder Kaur & Anr. v. State of Punjab, 2014 (4) RCR (Criminal) 785
- Rajveer Kaur v. State of Punjab, 2019 (3) RCR (Civil) 478
- Priyapreet Kaur v. State Of Punjab, 2021 (1) RCR (Civil) 604
The core principles emerging from these cases:
- Runaway couples, even those merely in live-in relationships and not formally married, are entitled to police protection if they are majors.
- The validity of the marriage (or its absence) is irrelevant to the question of granting protection for life and liberty.
- “Marriage is not a must for security to be provided to a runaway couple.”
These decisions powerfully support the proposition that:
“The issue in hand, however, is not marriage of the petitioners, but the deprivation of fundamental right of seeking protection of life and liberty.”
5. Mafi & Anr. v. State of Haryana & Ors., CRWP No. 691/2021 (Punjab & Haryana HC)
In Mafi, the P&H High Court held that:
- A woman above 18 is a major and “well within her right to decide what is good for her and what is not.”
- Even if the male partner has not attained marriageable age but is a major (18+), their live-in relationship cannot be a ground to deny protection.
- Parents and relatives cannot dictate an adult child’s life choices; society too cannot determine with whom an individual should live.
- The right to choose a partner is an important facet of Article 21’s guarantee of the right to life.
Justice Dhand quotes this passage to reinforce two propositions:
- Fundamental rights under Article 21 are triggered once individuals are majors (18 years and above); and
- Such rights cannot be abridged merely because one partner is not of “marriageable age” per personal law.
6. Other Supreme Court Authorities on Autonomy and Live-in Relationships
The Court also refers to several landmark Supreme Court judgments:
- S. Khushboo v. Kanniammal & Ors., (2010) 5 SCC 600
- Recognized that live-in relationships between consenting adults, or even pre-marital sexual relationships, are not criminal per se.
- Emphasized that the criminal law cannot be used to enforce subjective notions of morality.
- Indra Sarma v. V.K.V. Sarma, (2013) 15 SCC 755
- Analysed when a live-in relationship amounts to a “relationship in the nature of marriage” under the Protection of Women from Domestic Violence Act, 2005.
- Recognized statutory protection for women in such relationships.
- Shafin Jahan v. Asokan K.M. & Ors., (2018) 16 SCC 368 (Hadiya case)
- Affirmed an adult woman’s absolute right to choose her religion and spouse.
- Held that parental authority cannot override the autonomy of an adult daughter in such matters.
- Shakti Vahini v. Union Of India & Ors., (2018) 7 SCC 192 (cited in Seema Kaur)
- Condemned “honour killings” and issued detailed guidelines to prevent violence against couples marrying against familial or community norms.
- Described the right to choose a life partner as an inalienable facet of liberty and dignity under Article 21.
- Bhagwan Dass v. State (Nct Of Delhi), (2011) 6 SCC 396 (referred to in Seema Kaur)
- Described killings in the name of “honour” as the rarest of rare category of murders.
- Reiterated that personal autonomy in marital and relationship choices cannot be suppressed by familial notions of honour.
7. Rajasthan Police Act, 2007 – Section 29
The High Court reiterates that Section 29 of the Rajasthan Police Act, 2007 casts a statutory duty on every police officer to protect the life and personal liberty of citizens. This statutory obligation is read harmoniously with Article 21, reinforcing the duty of police officers (including the Nodal Officer) to respond positively to protection requests.
8. Earlier Rajasthan HC Decision: Suman Meena v. State of Rajasthan (S.B. Cr. Writ Petition No. 792/2024)
While details of this case are not fully reproduced, the judgment notes that a Co-ordinate Bench had already held that the protection of life and liberty of individuals is mandatory under Article 21 and that the police are duty-bound under Section 29 of the Rajasthan Police Act.
By aligning its reasoning with Suman Meena, the Court underscores a consistent institutional stance of the Rajasthan High Court: police protection cannot be refused because of perceived illegality, immorality, or social unacceptability of a consensual adult relationship.
C. The Court’s Legal Reasoning
1. Majority vs. Marriageable Age: Distinct Legal Thresholds
A critical aspect of the reasoning is the distinction between:
- Age of Majority (18 years): the age at which a person is legally competent to manage his/her own affairs, including decisions about residence and relationships; and
- Marriageable Age under Hindu Marriage Act:
- 21 years for a Hindu male,
- 18 years for a Hindu female (Section 5(iii) of the Hindu Marriage Act, 1955).
The State conflated these two and argued that if Rahul cannot lawfully marry, he should also not be allowed to live in a live-in relationship. The Court rejects this:
- Once both individuals are 18+, they are majors and entitled to exercise personal autonomy under Article 21.
- The statutory bar on marriage at 19 (for males) does not erase their competence to decide where and with whom to live.
- Marriage law may regulate the validity/effects of a marriage, but it does not permit the State or families to threaten or injure their basic right to life and liberty.
2. Article 21 as the Controlling Constitutional Principle
The Court repeatedly returns to Article 21 of the Constitution, which provides:
“No person shall be deprived of his life or personal liberty except according to procedure established by law.”
Two important ideas flow from this, as per the Court’s reasoning and the precedents it cites:
- Substantive Scope: Article 21 does not merely protect against physical deprivation of life or bodily restraint. It encompasses the right to choose a partner, right to cohabit, autonomy in intimate life, dignity, and privacy.
- Procedural Constraint: Deprivation of life or liberty can only occur through a valid law and due process. Threats, violence, or coercive interference from family or community are patently unlawful. The State’s inaction in the face of known threats can itself amount to a violation of Article 21.
As the Jodhpur Bench in Rekha Meghwanshi put it (a passage adopted in effect here):
“The issue in hand, however, is not marriage of the petitioners, but the deprivation of fundamental right of seeking protection of life and liberty.”
3. Live-in Relationships: Legal Recognition and Non-criminality
The Court situates live-in relationships within the broader legal landscape:
- Not an Offence: Citing Lata Singh and S. Khushboo, the Court affirms that a consensual live-in relationship between adults is not criminal.
- Statutory Recognition:
- The Protection of Women from Domestic Violence Act, 2005, uses the concept of a “domestic relationship,” which explicitly includes: “a relationship in the nature of marriage.”
- This statutory inclusion, examined in detail by Indra Sarma, means Parliament has recognized the reality of live-in relationships, particularly for conferring protection on women.
Against this backdrop, the Court observes (echoing Nandakumar) that the couple’s relationship, even if not legally recognized as a marriage, still falls within the legally acknowledged sphere of live-in relationships. That status is sufficient to attract constitutional and statutory protection for life and liberty.
4. Rejecting Moral Policing and Familial Control
The judgment, through its reliance on P&H and Supreme Court precedents, implicitly rejects:
- Familial veto over adult children’s choice of residence or partner.
- Societal diktats about acceptable forms of living, marriage, caste or community endogamy.
Quoting with approval from Seema Kaur:
“It would be a travesty of justice in case protection is denied to persons who have opted to reside together without the sanctity of marriage and such persons have to face dire consequences at the hands of persons from whom protection is sought.”
And from Mafi:
“Parents cannot compel a child to live a life on their terms. Every adult individual has a right to live his or her life as he or she deems fit.... The society cannot determine how an individual should live her or his life.”
These formulations directly undercut the argument, sometimes advanced by authorities, that refusal to grant protection can be justified because the relationship “offends” local customs, familial expectations, or statutory ideals around marriage.
5. Role and Duty of the Police (Particularly the Nodal Officer)
The judgment places significant emphasis on the police duty under Section 29 of the Rajasthan Police Act, 2007:
- Police are not merely law-enforcers but protectors of life and liberty.
- This duty is heightened where individuals approach the police with credible apprehensions of threat.
- The existence of a designated Nodal Officer-cum-Dy. Superintendent of Police for such matters underscores the institutional obligation to respond.
In practical terms, the Court:
- Does not itself assess the factual seriousness of the threat in detail.
- Instead, directs the Nodal Officer to:
- Verify the contents of the representation,
- Assess “threat perception,” and
- If warranted, “provide adequate security and protection to the petitioners.”
This model respects the separation between judicial and executive functions while ensuring that fundamental rights receive effective protection.
6. Limited Scope: No Adjudication on Civil/Criminal Liability
Finally, the Court carefully clarifies:
“Whatever has been observed by this Court in the present order is only for the purpose of disposal of the instant criminal writ petition and the same shall not affect any criminal and civil proceedings initiated, if any, against the petitioners.”
This ensures that:
- The order is not misinterpreted as immunizing the petitioners from any unrelated civil or criminal liability.
- The Court’s ruling is confined to Article 21 protection and cannot be used to pre-empt proceedings under other statutes where genuinely applicable.
D. Right to Live-in Relationships vis-à-vis Marriage Age
The crucial doctrinal advancement in this judgment – building upon earlier cases – can be distilled as follows:
- Threshold for Fundamental Rights: For purposes of Article 21 and the right to cohabit or choose a partner, the relevant age threshold is 18 years (majority), not the higher age of 21 prescribed for male marriage under the Hindu Marriage Act.
- Independence from Marriage Law: Even if a marriage is invalid, voidable, or non-existent, the right to protection of life and liberty persists.
- No “Penalty” for Non-Marriage: The State cannot “penalize” couples for not being able to marry (because the male is under 21) by denying them basic protection from violence or threats.
- Recognition of Cohabitation Rights: Once two individuals are majors, they can cohabit in a live-in relationship, and the law cannot be used as an instrument of coercion to separate them simply to conform to personal-law marriage norms.
In this sense, the judgment cements the principle that personal autonomy in intimate partnership and cohabitation is not merely derivative of formal marriage but stands on independent constitutional footing.
IV. Impact and Significance
A. Impact on Rajasthan’s Legal Landscape
- Consistent High Court Position: Along with Rekha Meghwanshi and Suman Meena,
this judgment consolidates a clear and consistent position within the Rajasthan High Court that:
- Adult couples are entitled to protection of life and liberty,
- Irrespective of the validity of their marriage or the existence of marriage at all.
- Guidance to Police: Police authorities in Rajasthan can no longer legitimately refuse protection to major live-in partners on the basis that:
- They are not married; or
- One partner (male) is below the marriageable age of 21.
B. Protection Against Honour-Based Violence and Coercion
By clearly connecting its reasoning to Shakti Vahini, Bhagwan Dass, and Lata Singh, the Court situates this case within the broader fight against honour-based violence. The explicit message is:
- Family displeasure or community disapproval is no justification for threatening or harming adult couples.
- State authorities have a positive obligation to intervene when such threats arise.
C. Clarifying Live-in Relationship Jurisprudence
The judgment strengthens the following doctrinal points in Indian law:
- Live-in relationships between consenting adults are legally permissible and non-criminal.
- The Domestic Violence Act recognizes and regulates such relationships, particularly to protect women.
- Courts must separate questions of:
- Validity of marriage under personal law; and
- Fundamental right to life, liberty, and protection from violence.
D. Potential Influence on Future Cases
This judgment is likely to influence future cases in several ways:
- Runaway and Live-in Couples: Future petitions by runaway or live-in couples facing threats will cite this decision to argue for protection, especially where the male partner is between 18 and 21.
- Administrative Practice: The role of Nodal Officers and SPs in assessing threats and providing protection will be further crystallized, with courts expecting procedural fairness and prompt action.
- Doctrinal Evolution: It strengthens the jurisprudential trend that marital status is not a precondition for enjoying full protection of Article 21 in intimate relationship contexts.
V. Complex Concepts Simplified
1. Void vs. Voidable Marriage under the Hindu Marriage Act
- Void Marriage:
- A marriage treated as non-existent in the eyes of law from the very beginning (e.g., bigamous marriages, prohibited degrees of relationship under Section 11 HMA).
- No legal rights typically flow from such a marriage.
- Voidable Marriage:
- A marriage which is valid until it is set aside by a court decree (Section 12 HMA).
- Grounds include impotence, prohibited degree under specific conditions, fraud, or pregnancy by another man at the time of marriage.
- The Supreme Court in Nandakumar interpreted the provisions to indicate that a marriage with a groom under 21 is not inherently void.
In Priya Suman, the Court notes that even if there is some doubt about the validity of marriage in cases where the groom is under 21, that issue is not decisive for the question of protection of life and liberty.
2. Live-in Relationship
A live-in relationship is an arrangement in which an unmarried couple lives together in a long-term relationship resembling marriage. Key legal points:
- Not per se an offence in India when between consenting adults.
- The Protection of Women from Domestic Violence Act, 2005, recognizes “relationships in the nature of marriage” for the purpose of granting protection orders, maintenance, etc.
- The Supreme Court in Indra Sarma laid out criteria to determine whether a live-in relationship is “in the nature of marriage”.
- Even if a particular live-in relationship does not meet those criteria, the underlying cohabitation between consenting adults remains non-criminal.
3. Article 21 – Right to Life and Personal Liberty
Article 21 is one of the most important fundamental rights in the Indian Constitution. Over decades, the Supreme Court has interpreted “life” and “personal liberty” to include:
- Right to live with dignity.
- Right to privacy and autonomy in personal decisions (including choice of partner).
- Right to freely move and reside anywhere in India.
- Right to be free from arbitrary or extrajudicial interference with these freedoms.
In the context of intimate relationships, Article 21 shields adults’ decisions to marry, cohabit, or remain single from undue interference by:
- The State, and
- Private parties (family members, community groups), where the State has a duty to protect individuals from such interference.
4. Habeas Corpus (Context from Nandakumar)
A habeas corpus petition is a writ used to challenge unlawful detention. In the context of intimate relationships:
- Parents sometimes file habeas corpus petitions alleging that their adult daughter is unlawfully detained by her partner.
- Courts must then determine whether:
- The adult woman is staying with her partner out of free will; or
- Is being unlawfully confined or coerced.
In Nandakumar, the Supreme Court found the adult woman was with her partner by choice and refused to hand her over to her father, emphasizing her autonomy.
5. Nodal Officer in Runaway/Protection Cases
While not fully set out in this judgment, “Nodal Officer-cum-Dy. Superintendent of Police” refers to a designated police officer responsible for:
- Receiving and processing representations from couples seeking protection.
- Coordinating with local police stations.
- Ensuring timely assessment of threat and arranging security where warranted.
The High Court’s expectation that the Nodal Officer will expeditiously decide the petitioners’ representations underlines the institutional mechanism to implement Article 21 rights.
VI. Conclusion
Priya Suman v. State of Rajasthan firmly entrenches the principle that:
Once two individuals have attained the age of majority (18 years), their choice to live together in a live-in relationship is constitutionally protected under Article 21, even if one partner is below the statutory marriageable age under personal law. The State, through its police machinery, has a positive obligation to protect their life and liberty from familial or societal threats, and cannot deny such protection on the ground that their relationship does not conform to marriage norms.
In substance, the judgment:
- Reaffirms that live-in relationships between consenting adults are not an offence.
- Clarifies that the threshold for invoking Article 21 protection is majority (18+), not marriageable age.
- Confirms that even questionable or invalid marriages, or the complete absence of marriage, cannot strip individuals of the right to seek protection.
- Reiterates and applies a robust line of Supreme Court and High Court precedents affirming personal autonomy in intimate relationships.
- Emphasizes the statutory and constitutional duties of the police to protect life and liberty.
Within the broader legal context, this decision strengthens the jurisprudential shift away from marriage-centric protection towards a person-centric, autonomy-respecting model, where the State’s primary role is to safeguard individuals’ lives and choices rather than enforce social or familial morality.
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