The Legal Vidya Volume 2 Issue 1

THE LEGAL VIDYA

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The Legal Vidya

Volume 2 Issue 1, November 2021, Page Nos. 64 to 75

LEGAL RECOGNITION OF MARRIAGE WITHIN THE

LGBTQIA COMMUNITY IN INDIA

MR. PRATIK MAITRA

Student, Symbiosis Law School, Hyderabad

Abstract: Whether and how civil society should recognize committed romantic relationships between two
persons of the same sex has been a prominent and often contested policy issue in the last decade. Supporters
of legal recognition have frequently framed their arguments in terms of human rights and fairness, whereas
opponents have often relied on religious teachings and tradition to back up their claims. The argument has
generated factual questions regarding the nature of same-sex couples, their families, and the institution of
marriage in general, in addition to this collision of profoundly felt values. Indeed, many of the legal and
policy arguments made by both sides have relied on scientific evidence to support them. Although empirical
research cannot resolve essential moral disagreements such as those raised by the marriage debate, it can
answer factual questions. To provide credibility to their recommendations for optimal political and social
change techniques, various researchers frequently look to the experiences of European governments that
have passed laws allowing same-sex marriage. Some of these experts have come to the conclusion that the
legalization of same-sex marriage occurs in stages. They argue that it is possible to anticipate which state
would be the first to accept same-sex marriage based on certain visible social and legal processes or
quantifiable factors.

“The global attention to issues of human rights for lesbian, gay, bisexual, transgender, queer, asexual,
intersex (LGBTQAI) people and other sexual minorities has centred on the inherent importance of those

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rights from a legal, cultural, and ethical standpoint over the last several decades 1”. Understanding these
fundamentals that demonstrates a necessity for ensuring impartiality for this marginalized community of
the society as well as for the basic freedoms for these people has been the need of the hour. Thus in our
paper we will be understanding the steps taken to eliminate prejudice and abuse against this set of
community along with it the landmark judgements will also be taken into consideration, the basic base of
our paper is formed by the case of Kumar Koushal v. Naz Foundation2 landmark judgement where
homosexuality was decriminalised.

Since the period of colonial expansion, the western understanding of sexuality has been heavily influenced
in India. Puritanical beliefs and behaviours were mapped into colonial people's view and now India is
carving out its path in order to ensure the rights of the LGBTQAI community which is well illustrated in
State of Bombay v. Narasu Appa Mali3case. We will try to gage how the Indian psyche embraced the
Western moral and psychological' notion that “sexuality is 'pathological,' rather than the normal
manifestation of desire that was once part of Indian culture4”.

The way people think of homosexuality has changed dramatically over the last century in the world. Since
1974, homosexuality has no longer been regarded as an unnatural behaviour in our globe and is no longer
classified as a psychiatric condition. In certain nations, it has even been decriminalized. Since then, anti-
discrimination or equal opportunity laws and regulations have been passed in different jurisdictions around
the world to protect gay, lesbian, queer and transgender rights. In India, no such progressive reforms have
occurred, and homosexuals continue to be victims of various forms of violence sponsored by the state and
society. Thus in our paper, we will go into a deep analysis of the legal recognition of the LGBTQAI
community in India and unfold the reality in parts in our paper.

RESEARCH OBJECTIVE
The main goal of this study is to obtain an accurate information about the legal recognition of the LGBTQAI
community present in India. The researcher's main focus was on determining the legitimacy of marriage within
the LGBTQAI community followed by the Jurisdictional stance in India. The paper goes on to address the

1
Moorhead, Laura. “LGBTQ Visibility: in the K-12 Curriculum.” The Phi Delta Kappan, vol. 100, no. 2, 2018, pp. 22–26. 16 Apr. 2021,
JSTOR, www.jstor.org/stable/ 26552438..
2
Kumar Koushal v. Naz Foundation, Appeal No. 10972 OF 2013
3
State of Bombay v. Narasu Appa Mali, Air 1952 BOM 84
4
Vanita, Ruth. “Same-Sex Weddings, Hindu Traditions and Modern India.” Feminist Review, no. 91, 2009, pp. 47–60. JSTOR, 16
Apr. 2021 , www.jstor.org /stable/ 40663979. .

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nation’s responsibility to safeguard the community's rights and end up having a conclusive opinion on the
aforesaid topic.

RESEARCH QUESTIONS

• What is the stance of Official Recognition of Same-Sex Couples.?

• What is the legality of Same-sex Marriage in India .?
• How had been the activist movements and the Indian Reaction.?

RESEARCH METHODOLOGY

To better understand the subject under constitutional law, the present research topic necessitates a doctrinal
research process. The most popular approach used by those conducting legal research is doctrinal. The
doctrinal analysis approach focuses primarily on legal propositions and doctrines. The main goal of this
research approach is to define the evidence and achieve the study's goals. This study is focused on publicly
available information. It is solely a theoretical study based on legal statutes, case citations, case laws, and legal
review. The study is qualitative in nature, and it is subjected to a variety of analyses and observations. It entails
conducting a thorough review of the subject and weighing the various facts and data available. As a result, the
researcher recommends doctrinal research because it better suits the current subject's study.

LITERATURE REVIEW

According to the preliminary research, there are numerous sources available in the form of journals, papers,
textbooks, case laws and judgments, e-books, and other formats to evaluate, review, and efficiently conduct
research on the subject. The author chooses to go across some of the most famous journals and hence try to
provide deep understanding of the aforesaid topic and make an opinion on the same.
“The author reviewed legal recognition of same-sex relationships in India by Nayantara Ravichandran5”.
This paper has made an attempt to study the social-legal analysis of the LGBTQAI community, it mentioned

5
Nayantara Ravichandran, legal recognition of same sex relationships in India, 16 april 2021, https://docs.manupatra.in/

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the changes that are required for positive results in India and hence provided the public with a consolidated
opinion to restructure our societal norms.
The second article“Same-sex marriages cannot be given legal sanction by Samanwaya Rautray 6” has been
reviewed by the author to understand the stance of the government which illustrated that the Centre has been
a vocal opponent of any attempt to legalize same-gender marriages in India. It gave in depth explanation of
the Centre's counsel advise to the Delhi High Court that decriminalizing “Section 377 of the Indian Penal
Code”7 does not automatically translate into a constitutional right for same-sex couples to marry.
“The third article that has been reviewed by the author is homosexuality in India- the invisible conflict by
Anuradha Parasar8” This research paper examines homosexual marriages in India as an invisible conflict that
has been effectively concealed. It also tries to identify and justify different aspects of homosexuality, such as
its evolution, causes, and social attitudes and reactions to such relationships. The author also includes
information from countries that have legalized homosexual marriages, as well as the outcomes of such
legalization.
Forth article that has been reviewed is same-sex marriages in India: a socio-legal analysis by Rohit Beerapalli9
The basic and complex meanings of marriage are investigated in this article. The arguments made by critics
of same-sex marriage are dissected. The argument that , altering the components of marriage will drastically
alter its function and intent is investigated. Following this social research, the legitimacy of same-sex
marriages in different countries is investigated too.
“Recognition of foreign same-sex marriage in India: a legal exploratory analysis by Stellina Jolly and Ritika
Vohra”10 This paper discusses about Indian queer people's access to healthcare, it further suggest that rules
must be formulated and that it does not follow the social odds in numerous contexts, which leaves issue
unresolved, particularly in light of recent legal changes.
“A STUDY ON THE LEGAL RECOGNITION OF SAME-SEX MARRIAGE by R.Venkadesh kumar”11- The
article aims to look at the legal recognition of same-sex marriage under different acts. To prevent the spread
of STDs amongst humans and to safeguard the culture and heritage of the country.

6
Samanwaya Rautray, Same sex marriages cannot be given legal sanction, Feb 25, 2021,7
7
Indian Penal Code, ,§ 377
8
Anuradha Parasar, homosexuality in India, 15 April 2021, http://www.delhihighcourt.nic.in/
9
Rohit Beerapalli, same-sex marriages in India: a socio legal analysis , 15 April ,2021, https://thelawbrigade.com/
10
Jolly, Stellina, and Ritika Vohra. “RECOGNITION OF FOREIGN SAME-SEX MARRIAGE IN INDIA: A LEGAL
EXPLORATORY ANALYSIS.” Journal of the Indian Law Institute, vol. 59, no. 3, 2017, pp. 302–326. 16 Apr. 2021, JSTOR,
www.jstor.org/stable/ 26826609.
11
R.Venkadesh kumar, , A STUDY ON THE LEGAL RECOGNITION OF SAME SEX MARRIAGE 14 April 2021,
https://acadpubl.eu/

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“Reportage of Decriminalizing LGBTQ Community in India by Supreme Court: Content Study of Indian
Newspapers in English Language by Dr.Parasarathi12” this article aimed to better understand the role of the
media in shaping societal attitudes on topics that were previously considered taboo in society. It argues ,current
agents in the social milieu must engineer the shifting attitudes of society, which always stands as a major point
at a certain point based on many factors present within the vaccum of the society.
Decriminalizing homosexuality in India by Geetanjali Misra13 - This paper looks at the successful battle
against Section 377 of the Indian Penal Code, which made private consensual sex between adults of the same
sex legal. This legislation had resulted in severe prejudice against people who engaged in homosexual
activities, who were often beaten and blackmailed by cops who threatened them with arrest.
Douglas McDonald-Norman by Douglas McDonald-Norman14 This article used country information in
assessing claims for refugee status based on sexual orientation or gender identity .And argue about the
,limitations on country facts hinder oppressed people's ability to prove their claims.

INDIAN SOCIETY AND HOMOSEXUALITY

Although there have been considerable advances in India in terms of social and legal recognition, the
LGBTQAI community continue to be victims of various forms of violence that are supported by the state and
society. The LGBTQAI community in India have grown starting from over a small group of a few hundred to
a ten-crore-strong and ever growing community with its own nightlife and activities. Both online and offline,
they are weaving their way from metropolises to semi-urban societies. This number is steadily rising as more
and more people like them come out of the closet. This demonstrates that homosexual relationships are not
uncommon in India; nonetheless, they are more common in the country's major cities, where people are more
open about their sexuality. The homosexual communities of Calcutta, Mumbai, and Bangalore have all
organised gay pride marches in the recent past.

LEGALITY OF SAME-SEX MARRIAGE IN INDIA

12
Dr.Parasarathi, Reportage of Decriminalizing LGBTQ Community in India by Supreme Court: Content Study of Indian
Newspapers, 15 april 2021, https://www.readcube.com/
13
Misra, Geetanjali. “Decriminalising Homosexuality in India.” Reproductive Health Matters, vol. 17, no. 34, 2009, pp. 20–28. 17 Apr.
2021. JSTOR, www.jstor.org/stable /40647442..
14
Douglas McDonald-Norman, Douglas McDonald-Norman, 16 april 2021, https://refuge.journals.yorku.ca/

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Recognizing these rights reflects a necessity to achieving impartiality as well as universal freedoms for a
marginalised group of individuals. In order to achieve equality, working to reduce prejudice and violence
against LGBT people necessitates enacting those rights. Human rights organisations and scholars from around
the globe have documented human rights brutalities and violations, with LGBT people facing discrimination,
familial rejection, violence, imprisonment, and other forms of exclusion in every country assessed. The current
restrictions on same-sex marriage in India are constructed in such a way that they don't expressly forbid it.

CRIMINALIZATION OF HOMOSEXUAL ACTIVITIES

Despite the fact that there are no clear restrictions on same-sex marriages, there are additional aspects to
consider before entering one. The consummation of a marriage, for example, is regarded as one of the most
important aspects of Hindu marriage. Marriage consummation, on the other hand, would be a criminal offence
in the case of two guys being married. Even if same-sex partners were permitted to marry legally, there is
always the possibility that they would be prosecuted for their sexual relationship. As a result, any marriage
that may exist, at least in the instance of two guys marrying, would be devoid of sexual activity. If the pair
decides to have a sexual relationship, they will have to worry about being prosecuted under the Indian Penal
Code.
With such laws still that were being vigorously enforced, it was impossible for same-sex partners to marry
being constantly aware that they could be arrested and sentenced to prison under Section 377. This was
arguably a flagrant infringement of such people's rights to equality and life.
In Naz Foundation v. Govt. of NCT of Delhi15, the Delhi High Court ruled that Section 377 of the Indian Penal
Code was unconstitutional in terms of limitations on homosexual behaviour. The Supreme Court used a liberal
construction to the term "sex," incorporating biological sex as well as sexual orientation. This practically
meant that any law targeting homosexuals would be declared null and void.
In Suresh Kumar Koushal v. Naz Foundation16, the case was later overturned. The Supreme Court stated that
the legislature was responsible for changing the law, and that the judiciary could not overturn certain elements
of the statute. The bench, on the other hand, simply commented on the High Court's ability to strike down the
law; they did not overturn the Delhi High Court's decision that Section 377 was unconstitutional. The judiciary
has acknowledged, at least tacitly, that the marginalisation of same-sex couples would violate the fundamental

15
Naz Foundation V. Government of NCT of Delhi, 60 Delhi Law Times 277
16
Suresh Kumar Koushal vs. Naz Foundation ivil Appeal No. 10972 OF 2013

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rights of such individuals. No same-sex marriage would be safe from persecution until laws targeting such
people are struck down or repealed.

ACTIVISTS MOVEMENT

For a decade, gay rights advocates have been fighting Section 377. Lesbian and LGBT organisations petitioned
the Delhi High Court in 1994 to overturn the ban. The lawsuit went on for five years and had sparked a lot of
controversy. Even members of the Indian lesbian collective Stree Sangam spoke at a government conference
on marriage and family law in 1996 about domestic-partnership regulations. In a letter to the homosexual
magazine Trikone, the organisation claimed that it was "possibly the first time that a lesbian/gay group
[attempted] to create public opinion on the issues in such a venue." The second national LGBT conference,
the Indian National Gay Conference YAARIAN -99, took place in February 1999. Similarly, to the attacks on
the films "Fire" and "Girlfriend," a number of organisations have formed the Lesbian Rights Campaign.
The petition, submitted by a non-profit group, contended that homosexuality should not be a criminal offence
in 21st-century India.

MAINSTREAM REACTION

According to 2006 public opinion polling, 41% of Indians would not want a homosexual neighbour, and 64%
say homosexuality is never justified. Over time, negative sentiments have waned. In India, LGBT persons
report encounters with violence, rejection, and prejudice in a variety of settings, including employment,
education, health care, and social services. In several studies of LGBT people, high percentages of poverty
have been discovered. Health inequalities connected to stigma and exclusion have been discovered in public
health studies. Depression, suicide ideation, and HIV are all more common among LGBT people than they
are in the overall population. Result of society's harsh reaction, many people in India deny the reality of sexual
minorities, considering that the same-sex behaviour replicates a Western culture, upper-class phenomena.
Many others see it as a disease that needs to be treated, an abnormality that needs to be corrected, or a crime
that needs to be punished. As a result, gay men and lesbian women are largely unaccepted in Indian society,
and as a result, they are exceedingly secretive. However, in the last five years, the Indian homosexual
community has migrated to and thrived on the Internet, which is possibly the most tolerant environment they
could have wished for. As a result, people are founding non-governmental organisations (NGOs), establishing

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helplines, and holding monthly meetings to develop strategies for their cause. Even so, according to Ashok
Row Kavi an Indian journalist, sexual minorities in India are primarily stigmatised and disempowered socially,
culturally, politically, and, in certain cases, legally and economically. As a result, a huge proportion of lesbian
and homosexual teenagers experience solitude, which is frequently accompanied by feelings of self-loathing
and uncertainty about their future.

LACK OF OFFICIAL RECOGNITION OF SAME-SEX COUPLES

Starting off with an example Vinoda Adwekar and Rekha Chaudhary attended the Registrar of Marriages in
1993 to request a marriage certificate. The Registrar did not immediately turn the women away, but instead
convened an emergency meeting with the judges and law enforcement to assess whether such a certificate
could be provided. One of the women was persuaded not to marry in this situation. Regardless of the lack of
a firm decision, the Registrar's confusion indicates that there is a lack of clarity in the family laws. It's possible
that asking if there is a law that specifically outlaws same-sex marriage isn't the greatest approach. Rather, the
topic to consider is whether same-sex couples can marry under current rules.
One can wonder how crucial it is for a marriage to be recognised by the state. The origins of the State's marital
power must be explored in order to address this question. Marriage was a secular affair in pre-modern times,
at least in Europe, and religious involvement was not required. The clergy just gave their blessings to the
institution, as they did to other secular endeavours. With rising demand from the upper classes, the blessing
ceremony was transferred from the outdoors to the inside of the church. Over time, the ceremony that is now
observed evolved. The state's control of marriage was not complete until the French Revolution, when it was
decreed that only civil ceremonies registered by a state authority would be legal.
It is not uncommon in Hindu marriages for persons to get married without receiving official certification of
the marriage. Judges would evaluate proof of the marriage if it became necessary to seek judicial intervention.
Photographs and recordings are utilised to determine whether two persons were married. The importance of
adhering to the ceremonies is highlighted. If the ceremonies are not in accordance of the rules laid, the
marriage may be declared invalid. There can be no valid Hindu marriage if the rites cannot be proven. Same-
sex couples have been unable to obtain official recognition despite having completed all of the necessary
processes and rituals for marriage. The couples involved would have been married in every sense of the word,
according to religious rituals and ceremonies, but they would not have been considered wedded in the eyes of
the state. This would place same-sex couples in the same legal dilemma as homosexual marriages in the United
States, when same-sex marriages performed before a State ban put such unions in limbo. Due to their lack of
legal recognition, these couples will be denied the same rights and protections as other couples. Married
couples, for example, would be able to get greater financial aid than unmarried ones.

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People would be discriminated against purely because of their sexuality, which would be a breach of the
principles of equality.

ROLE OF JUDICIARY

The Indian judicial system has played an important role in recognising gay’s rights and partially
decriminalising Sec. 377 of the Indian Criminal Code, 1860. The Supreme Court's decision to decriminalise
gay behaviour is the first step in giving the LGBT population in India equal status and rights. It also allows
members of the community to assert their right to marry, adopt, and have children. Because the ruling only
addressed the criminalization portion of Section 377, it is likely that rules governing same-sex marriage,
adoption, and inheritance will soon follow.
Union of India v. National Legal Service Authority17 is a major Supreme Court of India ruling that deemed
transgender individuals to be a "third gender" and so granted them the right to gender identification. This
decision is a significant step toward gender equality.
The Delhi High Court has declared that Section 377 of the Indian Penal Code is unconstitutional because it
criminalises hidden consensual sexual actions between adults, which violates Articles 14, 15, and 21 of the
Constitution..
Suresh Kumar Koushal v. Naz Foundation overruled a decision. The Supreme Court stated that the legislative
was responsible for changing the law, and that the judiciary could not overturn certain elements of the statute.
The bench, on the other hand, simply commented on the High Court's ability to strike down the law; they did
not overturn the Delhi High Court's decision that Section 377 was unconstitutional.
However, the Supreme Court overturned the Delhi high court's decision, Those who engage in sexual
intercourse in the ordinary course are classed differently from those who participate in carnal intercourse
against the natural order, and those in the latter category cannot claim that Sec. 377 is arbitrary and irrational.
Sec.377 just defined a specific offence and specifies the punishment that may be imposed if the trial is
conducted in compliance with Crpc provisions. As a result, Sec.377 was free of any constitutional flaws.
Regardless of this ruling, the competent legislature is free to assess the appropriateness and desirability of
repealing or amending Section 377 of the Indian Penal Code.
A nine-judge Supreme Court bench hearing. In a dispute challenging the biometric programme Aadhar card,
the Supreme Court unanimously ruled that privacy is a fundamental right. in K.S.Putaswammy and Anr v.

17
Union of India v. National Legal Service Authority (2014)5 SCC 438

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18
Union of India. With the recent judgement condemning Section 377 of the Indian Penal Code as
"unconstitutional," there is a ray of hope for those seeking to legalise homosexuality in India. What happens
between two people of the same sex in their own private domain must be shielded from government and
official intrusion. The decision on the right to privacy is one step in achieving the goal.
In Navtej Singh Johar v. Union of India (2018), dancer Navtej Singh Johar filed a petition alleging that Sec.
377 of the Indian Penal Code infringed his constitutional rights to privacy. The court ruled that criminalising
private consensual sex between adults violated the right to privacy. Sexual orientation is a natural aspect of
self-identity, and to deny it would be a violation of one's right to life. As a result, Section 377 of the Indian
Penal Code was partially decriminalised, allowing consensual intercourse between two adults of any gender.
The Supreme Court dealt with a case (Fazal Rab Vs State of Bihar19) in which a man had gay relations with a
boy with the youngster's consent. 'The offence is one under Sec. 377, IPC, which entails sexual perversity,'
the Supreme Court stated in 1983. Because of the boy's assent, the Supreme Court lowered the punishment
from three years to six months of harsh incarceration.

CONCLUSION

It is undeniably true that the European experience with the legal recognition of same-sex partnerships allows
for a better knowledge of how social and legal changes occur, as well as for predicting future changes.
However, forecasts based on presented ideas about the path leading to the legalisation of same-sex marriage
have been debunked, demonstrating that applying a general rule fails in the face of a slew of outliers.
In India, same-sex marriages are frowned upon by the general public. This is due to the fact that many
individuals believe such relationships are "unnatural" or "unholy" according to their different beliefs and
cultures. As a result, the LGBT community is subjected to a system of institutionalised intolerance. While
same-sex marriages are not technically forbidden in India, there are laws now that makes it feasible to marry
without ambiguity. There have been cases of same-sex marriages taking place in India, despite the fact that
they are not socially recognised by the Indian government. Many religious academics believe that such
relationships were quite prevalent in ancient Indian society and that the scriptures do not condemn them.
However, post-colonial changes in how society views culture have resulted in a lack of understanding of this
knowledge, leading to some declaring such interactions as foreign and anti-Indian culture.

LIST OF CASES

18
K.S.Putaswammy and Anr v. Union of India. (2017) 10 SCC 1.
19
Fazal Rab Vs State of Bihar AIR 1983 SC 323, 1983 CriLJ 632, 1982 (1) SCALE 803, (1982) 3 SCC 9

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• National Legal Services Authority v. Union of India20

• State of Bombay v. Narasu Appa Mali21
• Fazal Rab Vs State of Bihar22
• Navtej Singh Johar v. Union of India (2018) 23
• Naz Foundation V. Government of NCT of Delhi,24
• Suresh Kumar Koushal vs. Naz Foundation25
• National Legal Services Authority v. Union of India26
• Justice K. S. Puttaswamy (Retd.) and Anr. vs Union Of India And Ors27
• Arun Kumar v Inspector general of Registration28

REFRENCES
• Moorhead, Laura. “LGBTQ Visibility: in the K-12 Curriculum.” The Phi Delta Kappan, vol. 100, no. 2,
2018, pp. 22–26. 16 Apr. 2021, JSTOR, www.jstor.org/stable/ 26552438
• Vanita, Ruth. “Same-Sex Weddings, Hindu Traditions and Modern India.” Feminist Review, no. 91,
2009, pp. 47–60. JSTOR, 16 Apr. 2021 , www.jstor.org /stable/ 40663979

• Nayantara Ravichandran, legal recognition of same sex relationships in India, 16 april 2021,
https://docs.manupatra.in/
• Anuradha Parasar, homosexuality in India, 15 April 2021, http://www.delhihighcourt.nic.in/

• Samanwaya Rautray, Same sex marriages cannot be given legal sanction, Feb 25, 2021,7
• Rohit Beerapalli, same-sex marriages in India: a socio legal analysis , 15 April ,2021,
https://thelawbrigade.com/

• 1
Jolly, Stellina, and Ritika Vohra. “RECOGNITION OF FOREIGN SAME-SEX MARRIAGE IN
INDIA: A LEGAL EXPLORATORY ANALYSIS.” Journal of the Indian Law Institute, vol. 59, no. 3,
2017, pp. 302–326. 16 Apr. 2021, JSTOR, www.jstor.org/stable/ 26826609.

20
National Legal Services Authority v. Union of India, WP (Civil) No 400 of 2012
21
State of Bombay v. Narasu Appa Mali, Air 1952 BOM 84
22
Fazal Rab Vs State of Bihar, AIR 1983 SC 323, 1983 CriLJ 632, 1982 (1) SCALE 803, (1982) 3 SCC 9
23
Navtej Singh Johar v. Union of India (2018), 1 SCC 1 3 (2009) 11 DRJ
24
Naz Foundation V. Government of NCT of Delhi, 60 Delhi Law Times 277
25
Suresh Kumar Koushal vs. Naz Foundation ivil Appeal No. 10972 OF 2013
26
National Legal Services Authority v. Union of India , WP (Civil) No 400 of 2012
27
Justice K. S. Puttaswamy (Retd.) and Anr. vs Union Of India And Ors, WRIT PETITION (CIVIL) NO 494 OF 2012
28
Arun Kumar v Inspector general of Registration, W.P. (MD) NO. 4125 OF 2019 AND W.M.P. (MD) NO. 3220 OF 2019

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• 1
R.Venkadesh kumar, , A STUDY ON THE LEGAL RECOGNITION OF SAME SEX
MARRIAGE 14 April 2021, https://acadpubl.eu/

• 1
Dr.Parasarathi, Reportage of Decriminalizing LGBTQ Community in India by Supreme Court:
Content Study of Indian Newspapers, 15 april 2021, https://www.readcube.com/

• 1
Misra, Geetanjali. “Decriminalising Homosexuality in India.” Reproductive Health Matters, vol. 17, no.
34, 2009, pp. 20–28. 17 Apr. 2021. JSTOR, www.jstor.org/stable /40647442..
• 1
Douglas McDonald-Norman, Douglas McDonald-Norman, 16 april 2021,
https://refuge.journals.yorku.ca/

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