Punjab & Haryana High Court Refuses Police Protection to Live-in Couple Where Boy Has Not Attained Marriageable Age; Holds That Live-in Relationship Without Legal Eligibility Cannot Be Protected Under Article 21

Case Name: Lisha and another v. State of Punjab and others

Date of Judgment: 05 June 2026

Citation: CRWP-6747-2026

Bench: Justice Sandeep Moudgil

Held: The Punjab and Haryana High Court held that police protection cannot be granted merely on the basis of a claimed live-in relationship where the essential legal requirements of such a relationship are not fulfilled. The Court observed that directing the police to protect such a relationship would indirectly confer legitimacy upon an arrangement that does not satisfy the conditions recognized by law, particularly where one of the partners has not attained the marriageable age.

Summary: The petitioners invoked the writ jurisdiction of the High Court under Articles 226 and 227 of the Constitution seeking a direction to the police authorities not to harass them at the instance of their family members and to permit them to continue living together in a live-in relationship. They contended that both were majors above 18 years of age, intended to solemnize their marriage in future, and were presently residing together. They also submitted that they had already approached the Superintendent of Police through a representation seeking protection.

The Court observed that while Article 21 guarantees the right to life and personal liberty, including the right to live with dignity, such rights must operate within the framework of law. Referring to the Supreme Court’s decision in D. Velusamy v. D. Patchaiammal, the Court reiterated that a relationship in the nature of marriage must satisfy certain conditions, including that both partners must be legally competent to marry.

Upon examining the pleadings, the Court found that petitioner No. 2 had not yet attained the marriageable age and intended to marry petitioner No. 1 only after becoming eligible. The Court held that a mere assertion of living together for a short period was insufficient to establish a legally recognized live-in relationship. Granting police protection in such circumstances would amount to indirectly approving an illicit relationship, which could disturb the social fabric and would be contrary to the legal framework governing such relationships.

Decision: The High Court dismissed the writ petition, holding that the petitioners had failed to establish a legally recognizable live-in relationship warranting protection under Article 21 of the Constitution. The Court concluded that extending police protection in the facts of the case would indirectly lend legitimacy to a relationship that did not fulfil the legal prerequisites of a valid live-in relationship and, therefore, no relief could be granted.