Case Name: Ramna and Another v. State of Punjab and Others
Date of Judgment: 18 December 2025
Citation: CRWP-13402-2025
Bench: Hon’ble Ms. Justice Rupinderjit Chahal
Held: The Punjab and Haryana High Court disposed of a criminal writ petition seeking protection of life and liberty and held that even persons living in a live-in relationship are entitled to constitutional protection under Article 21 of the Constitution. The Court ruled that the legality or otherwise of the relationship, including issues of subsisting marriage or marriageable age, cannot be a ground to deny protection where a genuine apprehension to life and liberty is made out. The police were directed to assess threat perception and take appropriate protective measures in accordance with law.
Summary: The petitioners approached the High Court seeking protection from private respondents, asserting a real and imminent threat to their life and liberty on account of their live-in relationship. It was disclosed that petitioner No.1 had a subsisting marriage with another person and that petitioner No.2 was not of marriageable age. The petitioners had already submitted a detailed representation to the Senior Superintendent of Police seeking protection.
The Court examined the settled constitutional position that the right to life and personal liberty is a basic feature of the Constitution and extends to all individuals irrespective of societal approval of their personal relationships. Relying upon earlier decisions of the Court, including Pardeep Singh v. State of Haryana and the Division Bench ruling in Ishrat Bano v. State of Punjab, the Court reiterated that live-in relationships are not prohibited by law and that persons in such relationships are entitled to equal protection of law.
The Court clarified that the purpose of granting protection is not to confer legitimacy on the relationship, nor to shield parties from lawful criminal proceedings, but solely to ensure that no individual or group takes the law into their own hands. Even where allegations exist regarding illegality of marriage or other statutory violations, the State’s obligation to protect life and liberty remains paramount.
Without entering into the merits or legality of the relationship between the petitioners, the Court held that once a prima facie threat perception is established, constitutional courts are duty-bound to issue protective directions. The Court balanced this by expressly preserving the liberty of the State or any aggrieved person to initiate appropriate proceedings in accordance with law, if any cause of action arises.
Decision: The criminal writ petition was disposed of with a direction to the Senior Superintendent of Police to consider the petitioners’ representation, assess the threat perception, and take appropriate steps to protect their life and liberty in accordance with law. The Court clarified that the order would not bar initiation of any lawful proceedings against the petitioners, if warranted.