P&H HC : Declines Police Protection To Live-In Couple As Girl Is A Minor, Sends Her To Child Welfare Committee

punjab-haryana
⚖️ Order Date: 01 May 2026
Headnotes

Live-in relationship - Protection of life and liberty sought by couple where one partner is minor - Court is not inclined to grant protection since a live-in relationship with minor is illegal and protecting it would defeat the purpose of special child protection statutes. (Paras 7-10)

Live-in relationship - Protection of life and liberty sought by couple where one partner is minor -Instead of granting couple protection the Court directs the petitioners to appear before the SSP for production of the minor before the Child Welfare Committee - Committee shall inquire and pass appropriate interim and final orders including decisions on placement safety and well being - Police shall protect the petitioners from physical harm but this will not impede lawful action against other partner. (Para 11)


Facts of the Case

P&H HC : Declines Police Protection To Live-In Couple As Girl Is A Minor, Sends Her To Child Welfare Committee

The Punjab and Haryana High Court has refused to grant police protection to a live-in couple after noting that the girl is below 18 years of age, and directed that she be produced before the Child Welfare Committee.

In petition under Article 226 seeking protection of life and liberty from the girl’s family. The petitioners said they had been living together and feared threats from private respondents. The girl claimed to be 17 and a half years old while the boy is 18 and a half. The State informed the Court that an FIR had been registered against the boy and that the girl had not yet been traced.

The legal question was whether a court can extend protection under Article 21 to a live-in couple when one partner is a minor. Citing Supreme Court rulings in D. Velusamy v. D. Patchaiammal and Indra Sarma v. V.K.V. Sarma, the High Court noted that a “relationship in the nature of marriage” requires both partners to be of legal age to marry. Relying on Independent Thought v. Union of India, the Court reiterated that the age of consent is 18 years in all cases. It emphasized that the Prohibition of Child Marriage Act, the POCSO Act, and the Juvenile Justice Act are secular, welfare-oriented laws that override personal laws and criminalize child marriage and sexual activity with minors. Granting protection to a live-in relationship involving a minor would defeat these statutes, the Court said.

Declining the prayer for protection to the couple, the Court invoked its parens patriae role to protect the minor. It directed the petitioners to appear before the Senior Superintendent of Police within seven days so the girl can be produced before the Child Welfare Committee. The Committee must conduct an inquiry under Section 36 of the JJ Act, take interim measures, and pass final orders under Section 37 regarding her placement and welfare. The Court also directed the police to guard against any physical harm to the petitioners from private parties but clarified that such protection will not stand in the way of any lawful action against the boy in the pending criminal case.

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