In a cruelty prosecution arising from a relationship where the parties had cohabited and held themselves out as married, Justices Sanjay Karol and N.
Kotiswar Singh held that the protection against cruelty under Section 498A of the Indian Penal Code, 1860 is not confined to legally valid marriages, and extends to a live-in relationship that qualifies as a 'relationship in the nature of marriage' between consenting adults where an intent to marry formed an intrinsic part of the relationship. The Court reasoned that excluding women in such relationships from Section 498A's protection would be inconsistent with the provision's object of curbing cruelty against women and could offend Article 14, while clarifying that its ruling was confined to Section 498A and should not automatically govern the interpretation of other penal provisions.