Lata Singh vs State of Uttar Pradesh (2006)
Case Brief: Lata Singh vs State of Uttar Pradesh (2006)
Facts:
Lata Singh, a young woman belonging to a conservative community in Uttar Pradesh, fell in love with a man from a different caste.
They decided to marry against the wishes of their families, who were strongly opposed to their inter-caste relationship.
The couple’s decision sparked outrage within the family and the community.
Lata Singh faced threats, intimidation, and coercion from her family and others who wanted to prevent the marriage.
She approached the court seeking protection of her fundamental rights to marry a person of her choice without harassment or threat.
The police and administration initially failed to provide adequate protection to her.
The case revolved around freedom of choice in marriage and the right to live with dignity against caste-based societal pressures.
Legal Issues:
Whether an adult woman has the right to marry a person of her choice, irrespective of caste or community?
Whether interference by family or society to prevent such a marriage violates fundamental rights under Articles 14, 19, and 21 of the Indian Constitution?
Whether the State has a duty to protect individuals exercising their right to marry freely from threats, violence, or coercion?
How should courts balance individual autonomy with societal and familial pressures?
Legal Framework:
Article 14: Right to equality before law.
Article 19(1)(a) & (b): Freedom of speech and expression and freedom to assemble peacefully.
Article 21: Protection of life and personal liberty, which includes right to privacy, dignity, and choice.
Right to marry a person of one’s choice is recognized as a part of personal liberty under Article 21.
Precedents that affirm the right to marry irrespective of caste, religion, or community.
Judgment:
The Allahabad High Court in Lata Singh vs State of Uttar Pradesh affirmed that:
An adult woman has the absolute right to marry a person of her own choice, free from coercion, intimidation, or harassment.
Any attempt by family or society to prevent such a marriage amounts to a violation of her fundamental rights, particularly under Article 21.
The State is duty-bound to provide protection to individuals exercising these rights.
Interference on grounds of caste or community is unconstitutional and illegal.
The court explicitly rejected the practice of “honor killings” or threats to force conformity with social norms.
The court directed the State and police to ensure protection to Lata Singh and to uphold her right to marry freely.
It recognized that social pressure or caste considerations cannot override constitutional freedoms.
Significance:
The case is a landmark affirmation of the right to marry a person of choice, reinforcing the constitutional values of liberty, equality, and dignity.
It highlighted the plight of women facing coercion and threats in exercising their marital choice, especially in caste-sensitive contexts.
The judgment contributed to the legal fight against honor killings and forced marriages.
It emphasized the role of the State in protecting individual freedoms and ensuring the safety of vulnerable individuals.
This case has been widely cited in subsequent cases concerning inter-caste and inter-religious marriages and the protection of women’s rights.
It reinforced the legal principle that personal autonomy cannot be compromised by traditional or social compulsions.
Related Case Law:
Shakti Vahini v. Union of India (2018): Supreme Court condemned honor killings and ordered protection for inter-caste/inter-religious couples.
Lilly Thomas v. Union of India (2000): Right to marry as part of personal liberty.
K.S. Puttaswamy v. Union of India (2017): Right to privacy, which includes personal choice in marriage.
Sarla Mudgal v. Union of India (1995): Marital rights and freedom to choose partner.
Suresh Kumar Koushal v. Naz Foundation (2013): Overruled later; related to fundamental rights and personal liberty.
Conclusion:
Lata Singh vs State of Uttar Pradesh (2006) stands as a milestone judgment protecting the fundamental right to marry a person of one’s choice, especially for women facing social and familial opposition. The court’s strong stance against caste-based interference and coercion marked a progressive step towards upholding individual liberty, dignity, and equality under the Indian Constitution.
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