On February 23, 2026, the Allahabad High Court delivered a significant ruling granting police protection to twelve interfaith live-in couples and directed that private respondents and state authorities refrain from interfering with their lives, liberty, and privacy. The ruling arose from a batch of twelve writ petitions, comprising seven cases where Muslim women were living with Hindu men and five cases where Hindu women were living with Muslim men. The court, led by Justice Vivek Kumar Singh, held that none of the twelve couples had converted from their respective religions and therefore the Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021, popularly known as the anti-conversion law, had no application to their relationships.
This judgment carries profound constitutional significance and sits at the intersection of several contested areas of Indian law and public policy — the right to privacy, the right to choose one’s partner, the scope of state anti-conversion legislation, the limits of state intervention in intimate personal choices, and the constitutional protections available to citizens regardless of their religious identity. The ruling comes at a time when interfaith relationships have been subjected to increasing social and administrative scrutiny in several states.
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Table of Contents
The Anti-Conversion Law Framework
Five Important Key Points
- The Uttar Pradesh Prohibition of Unlawful Conversion of Religion Act, 2021, requires individuals intending to convert to file a prior application with the district magistrate, and criminalises conversion through misrepresentation, force, coercion, undue influence, allurement, or fraud.
- The Allahabad High Court held that the anti-conversion law applies only when there is an actual conversion from one religion to another, and does not apply to interfaith relationships where no such conversion has occurred.
- The court drew upon Article 21 of the Constitution, affirming the right to life and personal liberty as extending to the choices individuals make in their intimate relationships.
- The court noted that even interfaith marriages are not prohibited under the 2021 Act, dismantling the state government’s argument that interfaith live-in relationships are unlawful.
- The judgment strengthens the line of constitutional jurisprudence running from Hadiya (2018) and Shakti Vahini (2018), affirming that the right to choose one’s partner is a fundamental aspect of personal liberty.
The Uttar Pradesh law, enacted under Section 4 of the Act of 2016 as revised, requires any person desiring to convert to submit an application to the district magistrate prior to the conversion. Sections 8 and 9 of the 2021 Act specify the procedure for such declarations. The state government’s argument in this case was that the couples had failed to comply with these provisions, and that their relationships were therefore “unlawful” and not entitled to legal protection.
The court rejected this argument comprehensively. It pointed out that the anti-conversion law is triggered only when an actual, bona fide conversion from one religion to another takes place through specified coercive means. Where no conversion has occurred — as was the case with all twelve petitioner couples — the law simply has no application. This is a textually straightforward but practically important clarification, because state authorities in several instances had been treating interfaith cohabitation itself as presumptive evidence of unlawful conversion.
Constitutional Foundations of the Judgment
The constitutional architecture underlying this ruling is rich and layered. The court grounded its judgment primarily in Article 21, which guarantees the right to life and personal liberty. The Supreme Court’s nine-judge bench ruling in K.S. Puttaswamy v. Union of India (2017) established privacy as a fundamental right under Article 21, and this includes the autonomy to make intimate personal choices including the choice of one’s partner, one’s form of cohabitation, and one’s relationship structure.
The court also invoked Articles 14 and 15, which guarantee equality before law and prohibit discrimination on grounds of religion, race, caste, sex, or place of birth. By treating interfaith couples differently — subjecting them to surveillance, social pressure, and administrative obstruction not applicable to same-faith couples — state and private respondents were effectively engaging in unconstitutional religious discrimination.
The ruling’s observation that “if the law permits two persons even of the same sex to live together peacefully, then neither any individual nor a family nor even the state can have objection to heterosexual relationship of two major individuals who out of their own free will are living together” is particularly significant. It places interfaith heterosexual cohabitation within the ambit of constitutionally protected freedom, drawing upon the Supreme Court’s decriminalisation of consensual same-sex relationships in Navtej Singh Johar v. Union of India (2018).
The concept of “unity in diversity” invoked by the court is not merely rhetorical. It connects the judgment to India’s constitutional identity as a pluralistic, secular republic where the co-existence of different religions, cultures, and ways of life is not merely tolerated but positively protected.
The Shakti Vahini and Hadiya Precedents
The Allahabad High Court’s ruling builds upon a line of Supreme Court jurisprudence on the right to choose one’s partner. In Shakti Vahini v. Union of India (2018), the Supreme Court held that the right to choose a life partner is a fundamental right under Articles 19 and 21, and that honour killings and social or familial interference with this choice are unconstitutional. The court directed states to take preventive and remedial measures to protect couples who marry across caste or community lines.
In Shafin Jahan v. Asokan (the Hadiya case, 2018), the Supreme Court upheld the right of a Hindu woman who had converted to Islam and married a Muslim man to live with her chosen partner, overturning a High Court order that had annulled the marriage. The court emphasised that the right to choose one’s faith and one’s partner are components of individual autonomy that are inseparable from human dignity.
The present Allahabad High Court ruling carries this jurisprudence forward in a specific direction: it clarifies that these protections apply not just to married interfaith couples but also to those in live-in relationships, and that administrative and legal mechanisms designed to regulate religious conversion cannot be weaponised against interfaith cohabitation as such.
The Governance and Social Context
The broader context of this ruling is important for understanding its significance. Several states, particularly those governed by the BJP, have enacted anti-conversion laws since 2018 — including Madhya Pradesh, Gujarat, Himachal Pradesh, Haryana, and Karnataka in addition to Uttar Pradesh. The scope and enforcement of these laws has been a subject of significant legal and social controversy.
Critics of these laws argue that their enforcement in practice has been directed disproportionately at interfaith couples, particularly those involving Muslim men and Hindu women, and that they are being used as tools of social control rather than genuine protections against coercive conversion. The present judgment, by drawing a sharp legal distinction between coercive conversion (which the law legitimately targets) and consensual interfaith cohabitation (which is constitutionally protected), attempts to discipline this enforcement overreach.
The involvement of organisations such as Vishwa Hindu Parishad and other groups in surveilling, harassing, and reporting interfaith couples has created a de facto extra-legal enforcement apparatus that operates outside the formal legal framework. The court’s direction to private respondents as well as state authorities to refrain from interfering with the couples’ privacy represents an important judicial pushback against this phenomenon.
Live-in Relationships in Indian Law
The legal status of live-in relationships in India has evolved significantly over the past two decades. The Supreme Court in D. Velusamy v. D. Patchaiammal (2010) held that a live-in relationship of sufficient duration and stability would be treated as a relationship in the nature of marriage for the purposes of the Protection of Women from Domestic Violence Act, 2005. This extended certain legal protections to women in live-in relationships.
However, live-in relationships do not confer the same legal rights as marriage in areas such as inheritance, maintenance, and adoption. The absence of a comprehensive legal framework governing these relationships creates significant vulnerability, particularly for women. The High Court’s ruling, by extending constitutional protection to interfaith live-in couples, does not resolve these substantive legal gaps but does establish a fundamental baseline — that the state cannot criminalise or obstruct consensual adult cohabitation on the basis of religious difference.
Challenges and Way Forward
The judgment raises important questions about the relationship between personal law reform, constitutional rights, and legislative sovereignty. The anti-conversion laws enacted by various states claim to protect vulnerable individuals from coercive religious conversion, which is a legitimate state interest. However, their implementation has frequently exceeded this mandate, creating constitutional problems.
A balanced way forward would involve clearer legislative drafting that explicitly confines the operation of anti-conversion laws to genuinely coercive situations, combined with robust enforcement mechanisms against harassment of interfaith couples by both state and non-state actors. The law commission and relevant ministries could examine whether a uniform national framework governing religious conversion — with explicit protections for consensual choices — would be preferable to the current patchwork of state laws with varying scopes and enforcement cultures.
Relevance for UPSC and SSC Examinations
This topic is directly relevant to UPSC GS Paper 2 (Judiciary, Fundamental Rights, Constitutional provisions relating to religious freedom under Articles 25–28, Federalism and state legislation) and GS Paper 1 (Social Issues, Women’s rights). It is also important for UPSC Mains Essay, where themes of constitutionalism, secularism, individual rights versus community interests, and the role of the judiciary frequently appear.
For SSC, the topic is relevant in the context of constitutional provisions, Supreme Court landmark judgments, and questions on fundamental rights that regularly appear in General Awareness sections. Candidates should be familiar with Article 21, the right to privacy jurisprudence, and the major Supreme Court rulings on personal autonomy.