This Article is written by Midha Fatima of Asian Law College, an intern under Legal Vidhiya
Abstract
In this article, the Supreme Court in 2018 considered the colonial legal criminalization of adultery under Section 497 of the Indian Penal Code (IPC)[1]. The paper delves into the historical foundations of this law, examining its patriarchal origins and discriminatory application. The core of the analysis focuses on the landmark ruling of the Supreme Court in Joseph Shine v. Union of India[2]. This judgment significantly impacted constitutional justification, case law, gender equality, individual liberty, and the institution of marriage. Through a comprehensive review of pre- and post-decriminalization case law, scholarly discourse, and socio-legal perspectives, the paper argues that decriminalization is a critical step in aligning Indian law with modern human rights standards, even while recognizing ongoing social debates and challenges.
Keywords
Adultery, India, Decriminalization, Section 497 IPC, Joseph Shine, Gender Equality, Personal Autonomy, Marital Law, Constitutional Law, Patriarchal Law.
Introduction
Adultery has historically and culturally been viewed through a complex lens, fluctuating between a moral transgression, a social taboo, and a legal crime[3]. For over a century and a half, in India, it was firmly covered under the criminal justice system, particularly Section 497 of the Indian Penal Code (IPC), 1860[4]. This provision, a relic of colonial Victorian morality, designated sexual intercourse between a married man and a married woman without her husband’s consent or concealment, while uniquely exempting the woman from criminal liability. This distinct legal framework, deeply rooted in patriarchal notions of marriage and women as chattel, sparked intermittent yet passionate debate about its constitutional validity and socio-ethical implications.
The landmark Supreme Court decision in Joseph Shine v. Union of India (2018) marked a high degree of legal landscape shift, bringing India’s jurisprudence closer to global human rights standards[5]. This decision did not merely strike down an old-fashioned law. The purpose of this article is to trace the historical origins of Section 497, analyze the judicial challenges it faced, analyze the inference of the Joseph Shine judgment, and conduct a detailed analysis of this transformational journey, examining the diverse implications for gender justice, marital dynamics, and broader social perceptions in India.
The Evolution of Section 497 IPC
Section 497 of the Indian Penal Code, 1860, stated: “Whoever has sexual intercourse with a person who is and whom he knows or has reason to believe to be the wife of another man, without the consent or connivance of that man, such sexual intercourse not amounting to the offence of rape, is guilty of the offence of adultery, and shall be punished with imprisonment of either description for a term which may extend to five years, or with fine, or with both. In such case the wife shall not be punishable as an abettor”[6].
The historical roots of Section 497 lie within the drafting of the Indian Penal Code by the Primary Law Commission, driven by Lord Macaulay. Interestingly, Macaulay himself was hesitant to criminalize infidelity at first, considering it primarily as a tort. He held that the law should not interfere into household affairs of devotion and that civil remedies were sufficient for the harmed party. His position, however, was inevitably overruled by later commissions and the prevailing social norms of the period, which sought to protect male proprietary rights over their spouses and the “holiness” of the marriage institution from an outsider’s intrusion. The addition of Section 497 was subsequently a compromise, expressing a desire to control female sexuality and prevent domestic violence by men, rather than out of a deep concern for women’s agency or equality within marriage.
Early Challenges and Case Studies
Case Study 1: Yusuf Abdul Aziz v. State of Bombay (1954)
This was the primary major post-independence challenge to the constitutional validity of Section 497. The petitioner, Yusuf Abdul Aziz, argued that the section violated Article 14 (equality before law) and Article 15(1) (prohibition of segregation on grounds of sex) of the Constitution in punishing only men for infidelity while saving ladies. The Supreme Court, in its ruling, upheld the legality of Section 497. The Court’s reasoning was that Article 15(3) of the Constitution, which grants the State to make “any extraordinary arrangement for ladies and children,” justified treating ladies as exempt from discipline. Justice Vivian Bose, on behalf of the consistent bench, opined that the arrangement was an “extraordinary arrangement” in the interest of women, aimed at shielding them. The Court did not touch upon the patriarchal establishment of the law and opted to see it as positive discrimination. This decision, in its apparent assurance, extended the idea of ladies as helpless subjects in need of state security, as opposed to equal rights and effective agents.
Case Study 2: Soumithri Vishnu v. Union of India (1985)
This challenge to Section 497 of the Indian Penal Code, which criminalized infidelity, is a crucial moment in the controversial history of the law. The petitioner in this case, a deserted wife, mounted a three-pronged attack on the provision, alleging discrimination against it on three important grounds.
For starters, she argued that Section 497 unjustly deprived wives of the right to prosecute their husbands for adultery. According to the existing law at the time, only a husband had the right to prosecute another man for sexual intercourse with his wife. The wife herself did not enjoy a legal right to file criminal charges against her errant husband, and this resulted in a stark disparity in the administration of justice within the institution of marriage.
Second, the petitioner drew attention to another perceived unfairness: the law did not allow a wife to prosecute the woman with whom her husband had an affair. While the “outsider” man who had an affair with the wife was held criminally liable, the “outsider” woman who had an affair with the husband was not. This also highlighted the gender-specificity of the offense, casting the criminal onus entirely on the male with whom a married woman had an affair.
Thirdly, the challenge indicated a serious gap in the law: it did not cover cases where the husband had been unfaithful to his wife with an unmarried woman. In particular, Section 497 made it illegal for a man to have sex with another man’s wife without that man’s consent. This had the effect that if a husband had sexual intercourse with one woman, no criminal act of adultery was committed, irrespective of the emotional or social effects on his marriage. This hiatus underscored the law’s concern with safeguarding the husband’s property rights over his wife, not with issues of marital loyalty or the emotional injury caused by adultery.
Despite these strong arguments, which the Supreme Court also recognized as possessing “sentimental attraction,” the Court nevertheless upheld the constitutional validity of Section 497. In its rationale, the Court reaffirmed that the basic legislative purpose behind Section 497 was to preserve the dignity of marriage. The reasoning of the Court was that the “outsider,” that is, the adulterous man, was the one who “poisons the peace and tranquility of a matrimonial home” and thus he alone should be punished.
Most importantly, the Court held that the wife was not meant to be punished by the law and thus giving her the right to prosecute her husband for adultery would go against the underlying philosophy of the statute. This interpretation effectively placed the wife in the position of victim to be safeguarded by the law, not an equal party capable of prosecuting the offense or committing it. The Court also underscored that civil remedies, including divorce, were already available to the offended spouse, thus establishing a clear demarcation between criminal responsibility and the civil problems arising out of marital conflict. This decision solidified the male-sided nature of the crime while also seemingly protecting women by exempting them from criminal liability for adultery. The patriarchal idea that a wife was property whose chastity needed to be protected by punishing the male “intruder,” rather than as a reciprocal act of adultery that either spouse could commit, was strengthened by this. The ruling reaffirmed the idea that the law was meant to protect the husband’s rights and reputation as the head of the marriage, not gender neutrality or to make up for the emotional damage that adultery had caused to either partner.
Case Study 3: V. Revathi v. Union of India (1988)
This petition once more questioned Section 497 and Section 198(2) of the Code of Criminal Procedure (CrPC), which had mandated that the husband alone could file a complaint for adultery. The petitioner, who was a wife, claimed that this took away her right to prosecute her adulterous husband equally.
The Supreme Court rejected the petition, assuring the previous one to stand out. The Court ruled that the law was not discriminatory towards women because it also kept a husband from prosecuting his wife for adultery. It posited that both spouses were “disabled from striking each other with the weapon of criminal law” and that the law sought to foster reconciliation among spouses by not permitting them to send one another to prison. The Court held that the legislation sought to punish the “outsider” intruder into the institution of marriage. Such a ruling, as its antecedents, gave precedence to the maintenance of the institution of marriage (according to the patriarchal understanding of the law) at the expense of individual equality and self-determination.
Rising Dissenting Voices and the Demand for Reform
Judicial pronouncements notwithstanding, Section 497 was coming under increasing fire from legal academicians, feminist activists, and human rights groups. They repeatedly brought out its inherent discriminatory character, its denigration of women’s dignity and autonomy, and its anachronism in a gender-equalizing society. The law was regarded as a Victorian legacy, classifying women as passive objects instead of active subjects with equal rights and duties in a marriage. The demand for reform grew stronger, with a focus that although adultery was a violation of trust in marriage, it must not be a state-criminalizable offense.
The Watershed Moment: Decriminalization in Joseph Shine v. Union of India (2018)
Joseph Shine v. Union of India, a landmark ruling in 2018, marked the culmination of the legal battle over Section 497 of the Indian Penal Code, which had made adultery a crime[7]. Joseph Shine, a foreign Indian resident, filed the historic case to test the constitutionality of the provision, opening the door for the dramatic reexamination of a law that had been in place for a century.
Shine’s petition raised some strong arguments against Section 497. He argued that the law was discriminatory in nature, going against Article 14 of the Constitution by making an arbitrary distinction between men and women in cases of adultery. The law punished the man who had committed an act of adultery with a married woman but gave immunity to the woman from any liability despite her equal role in the consensual act[8]. In addition, Shine maintained that the section violated Article 15, which outlaws discrimination based on sex alone, because it enforced gender stereotypes and buttressed the image of women as subservient to men in marriage. Most significantly, the petitioner claimed that Section 497 violated Article 21, the right of life and personal liberty, by diminishing the dignity, independence, and sexual privacy of married women. He pointed out the way the “consent or connivance” provision of the law essentially reduced women to the status of their husbands’ property, stripping them of their own identity and sexual agency. The petitioner also contended that the law did not recognize the sexual freedom of married women and implicitly presupposed that they could not be initiators or active parties to adultery and hence essentially represented them as passive objects[9].
In a landmark decision for Indian jurisprudence, a five-judge Constitution Bench of the Supreme Court, led by Chief Justice Dipak Misra and including Justices R.F. Nariman, A.M. Khanwilkar, D.Y. Chandrachud, and Indu Malhotra, unanimously declared Section 497 of the IPC unconstitutional on September 27, 2018[10]. This ruling marked a substantial shift from the Court’s earlier positions on the issue, indicating a greater dedication to gender equality and a resounding support for contemporary constitutional morality.
The justification of the Court in upholding Section 497 was multi-dimensional and embedded firmly in basic rights. In the context of the violation of Article 14 (Equality Before Law), the judges found that Section 497 created a discriminatory and irrational classification. It only criminalized the male, while the female, equal partner in the consensual sexual act, was excluded. The Court discovered no “intelligible differentia” by which it could rationally relate this categorization to any valid state purpose. The traditionally assumed paternalistic reason, that women needed to be protected, was strongly rejected; rather, the Court insisted that the law in effect treated women as inferior and unable to make decisions on their own.
The judgment is also emphatic on the “violation of Article 15 (Prohibition of Discrimination)”. The Court categorically declared that Section 497 discriminated on the basis of sex alone. In criminal proceedings only against the man and giving a special right to prosecute to the husband, the law strengthened the unhealthy gender stereotypes. It brought to the fore the ancient notion of women being controlled by men in a matrimonial relationship and thereby took away their agency. Justice D.Y. Chandrachud, in his concurring judgment, specifically pointed out that the law “destroys the dignity of the woman” and that “societal expectations that control women’s sexuality are violative of Article 14,” pointing out the wider societal ramifications of such discriminatory law.
A pillar of the Court’s reasoning was the violation of Article 21 (Right to Life and Personal Liberty). The judges firmly held that Section 497 violated the fundamental rights of dignity, personal liberty, and sexual autonomy of wedded women. The right to exercise independent choices relating to one’s body and private life, they argued, is an integral part of personal liberty. The law effectively curtailed a wife’s autonomy and subjected her to a form of ownership by requiring her husband’s consent or approval for her sexual choices. Section 497 “is an affront to the dignity of a woman as it treats her as a property of her husband,” according to Justice Indu Malhotra, who articulately outlined the patriarchal underpinnings of the clause.
Additionally, the Court repeatedly rejected the “sacred cow” defense that the sanctity of marriage required the criminalization of adultery. It clarified that while marriage is an essential social institution, its sanctity results from two consenting adults’ respect, trust, and loyalty to one another rather than from the possibility of criminal punishment or a husband’s ownership of his wife’s body. In conclusion, Chief Justice Dipak Misra decided that adultery is not a crime. He went on to say, “It is a matter between the two individuals,” adding that “marriage is a union of two souls and is not a commodity.” This school of thought firmly established adultery as a matter of personal moral choice and civil remedies, effectively removing it from the purview of state-imposed criminal punishment.
Finally, the decision was significant because it clearly distinguished between criminality and morality by designating adultery as a civil crime. The Court went on to specifically say that, under certain Indian personal laws, adultery can still be a legitimate reason for divorce even though it is no longer a crime. This distinction is important: the state has the authority to provide civil remedies for the dissolution of marriage, but it has no interest in criminalizing what is essentially a domestic violation of trust and fidelity between spouses. By reiterating that “adultery is a moral wrong but not a criminal wrong,” the Court drew precisely the correct boundaries around state action.
Previous Supreme Court rulings that had upheld Section 497—citing Yusuf Abdul Aziz, Soumithri Vishnu, and V. Revathi—were categorically overturned by the Joseph Shine ruling. The Court noted that earlier rulings relied on antiquated gender conceptions and had not adequately taken into account how Section 497 affected women’s constitutional rights. The decision was greatly influenced by paradigm shifts in jurisprudential thought, particularly the recognition of privacy as a constitutional right in K.S. Puttaswamy v. Union of India (2017). This earlier seminal ruling provided the Court in Joseph Shine with enough precedent to interpret marriage laws in a rights-based, progressive, and mature manner, ultimately decriminalizing adultery and establishing a more equitable legal system.
Post-Decriminalization Landscape: Implications and Challenges
The decriminalization of adultery through the Joseph Shine decision has opened a new chapter for marital law and gender relations in India, with opportunities and controversies arising.
Effect on Gender Justice and Women’s Rights
The far-reaching effect of the Joseph Shine decision is on gender justice. By striking down a law that treated women as their husbands’ property and withheld equal agency from women in intimate relationships, the Supreme Court made a gigantic leap towards giving power to women. It overruled a legal provision that reinforced deeply ingrained patriarchal stereotypes and reduced women’s dignity and autonomy to nothing. Women are now treated as autonomous beings who can make their own decisions, and their sexual loyalty is no longer regulated by the state through criminal law. This brings Indian law in line with international human rights norms that promote the decriminalization of adultery on the grounds of its discriminatory effect on women.
Adultery as a Ground for Divorce and Other Civil Remedies
Though adultery is no longer a crime in India, its legal position saw a dramatic change. It is no longer the criminal justice system’s concern to prosecute, yet it continues to be a central issue in the civil context of marriage dissolution disputes. This shift essentially changes the “site of redress,” from criminal courts to civil and family courts. There, the emphasis is on the termination of marriage and associated civil remedies, not penal sanctions.
Adultery is still a clear and specific reason for divorce under the Hindu Marriage Act of 1955. According to Section 13(1)(i), if one partner “has, after the solemnization of the marriage, had voluntary sexual intercourse with any person other than his or her spouse,” the other spouse may request the dissolution of the marriage. This provision gives the harmed party the legal right to file for divorce and recognizes the grave betrayal of marital trust brought about by adultery.
Equally, the Special Marriage Act, 1954, that made provision for civil marriages irrespective of religion, includes adultery as a sufficient ground for divorce under its Section 27. This is evidence of a uniform legal approach in various marriage structures in India on the consequences of adultery for the marriage.
For Indian Christians, the Indian Divorce Act, 1869, also lists adultery as a main reason for obtaining a divorce. This guarantees that in various personal laws managing different religious groups, adultery is seen as a valid reason for the end of a marriage.
Muslim Personal Law, without codifying adultery as an express direct, standalone ground for divorce in the same clear words of Hindu or Christian law, nevertheless permits acts of unfaithfulness to be dealt with within wider legal systems. For example, successive episodes of adultery or its effect on the marriage may be pleaded under broader claims like ‘cruelty’ or ‘breakdown of marriage’ cases based on the interpretation and application of Muslim law principles. What this implies is that although the word “adultery” may not necessarily call forth an immediate divorce provision, the causal behaviors themselves and their effect on the marital union can still be considered for a request for separation.
Decriminalization has further repercussions. Spouses who have been wronged may still seek additional legal remedies. These include maintenance, where an adulterous spouse’s behavior can significantly impact their entitlement. For example, under Section 125 of the Criminal Procedure Code, a wife who commits adultery may have her maintenance claim denied or significantly reduced. The important distinction is that now the ‘living in adultery’ condition, which could previously have been proven with the assistance of a criminal conviction, has to be established solely through civil procedures. This requires bringing substantial evidence in the family courts to prove the adulterous behavior, without the support of a criminal conviction. Adultery also becomes an important concern in child custody cases, as the court looks at the overall behavior and fitness of both parents before deciding what is best for the child.
Fundamentally, India’s legal picture with regard to adultery has been radically changed. Though no longer tainted by the stigma and intense penalties of a criminal act, its deep effects on marital relationships are wholly understood and dealt with under the civil justice system, providing an array of remedies for victims of adultery.
Moral Discussions and Perceptions in Society
Indian society had a range of reactions to the decriminalization of adultery. The ruling was hailed by progressives as a step toward a more equitable and free society that respects individual liberties and departs from the moral policing of the Victorian era. Conservative elements, however, were concerned that it would diminish morality, weaken the institution of marriage, and normalize adultery.
The argument usually focuses on the difference between law and morality. The Supreme Court explicitly stated that though the law need not criminalize all moral evils, morality in society and conscience in individuals are still significant. The ruling suggests that fidelity in marriage is an individual ethical decision, rather than an obligation imposed by the criminal law. The attention has now turned towards enhancing trust, communication, and respect for each other as the pillars of a secure marriage, instead of the option of being jailed.
Unintended Consequences or Grey Areas
A prominent exception from decriminalizing adultery is for military personnel. The Supreme Court, in its Joseph Shine ruling, explained that the decision would not extend to military legislation punishing “unbecoming conduct” or “breaches of good order and discipline,” which could encompass acts of adultery. This exemption is founded on the singular disciplinary necessities and chain of command inherent to the military.
In addition, although the law has become gender-neutral regarding who can obtain a divorce based on grounds of adultery, social prejudices and difficulties in establishing adultery in civil courts remain. Adultery is rarely capable of being directly proved, and courts have to rely heavily on circumstantial proof. Family courts interpret what constitutes “voluntary sexual intercourse” for the purposes of civil law.
Comparative Jurisprudence: Adultery Laws in Other Nations
In much of the world, especially countries that have a prevailing influence of religious law, e.g., most countries under Islamic influence such as Saudi Arabia, Iran, and Pakistan, adultery remains considered a serious criminal offense. The legal repercussions in these areas are normally severe, ranging from public flogging to, in the worst instances, stoning to death. Even within some US states, adultery technically remains a misdemeanor, albeit prosecutions are extremely rare, frequently owing to practical challenges in proving the act and shifting public mores regarding such affairs as private. These jurisdictions typically maintain a conservative attitude in which the state interferes in intimate affairs, typically with deeply embedded moral or religious precepts.
In contrast, a significant number of industrialized countries, such as most Western European nations, Australia, and Canada, have traditionally decriminalized adultery. Within these cultures, adultery is mainly treated as a civil issue, being a probable basis for divorce but not a criminal offense. This is part of a larger social movement within these societies away from disentangling state control from consensual private sex activity. The governing philosophy in such states is one of privacy and autonomy for the individual, understanding that sex relations, no matter if they involve adultery, are beyond the control of criminal law.
India’s recent decriminalization of adultery places it squarely among this latter group of progressive nations. By decriminalizing adultery, India has shown a progressive step further in giving precedence to personal privacy and dignity within personal relationships. This is a sign of change to acknowledge evolving social values and a response to uphold inherent human rights as shown by changes in the law of developed democracies across the world. It signals a shift away from a penal strategy to one more comprehending of individual relationships, in which the state’s duty is not to criminalize morality in private sexuality, but to make available civil remedies for the disintegration of marital ties.
Conclusion: The Direction of Indian Marital Law
The decriminalization of adultery in India, led by the Joseph Shine v. Union of India verdict, is a titanic leap towards legalizing its paradigm and upholding constitutional principles. This ruling firmly established individual dignity, autonomy, and gender equality at the center of marriage law, essentially decolonizing a colonial provision that reduced women to objects of male possession. The Supreme Court’s explicit pronouncement that adultery, though a moral fault, cannot be the basis for criminal penalty, represents a vital separation between private morality and public criminality.
The life cycle of Section 497, from its patriarchal birth to its ultimate obliteration, is reflective of India’s wider social and legal development. Though certain societal concerns regarding the “sanctity of marriage” remain, the judgment effectively redefines this sanctity, based it on mutual respect, trust, and personal autonomy rather than state-mandated chastity. The attention has appropriately turned towards civil remedies, giving the suffering spouses the right to sue for divorce and other marital relief in family courts, free from the retaliatory machinery of the criminal justice apparatus.
In the future, the difficulty is to create a better understanding and acceptance of this legal change in society. Now, efforts must be directed toward making support mechanisms for those going through marital strife more robust and ensuring that there is a culture of equality and respect in relationships. The Joseph Shine ruling is not just a legal modification; it’s a deeper assertion of personal freedom and gender equality, a harbinger of a newer, more rights-sensitive age for marital relations in India.
References
- Joseph Shine v. Union of India – Decriminalization of Adultery Background, Supreme Court Observer (July 11, 2025), https://www.scobserver.in/cases/joseph-shine-v-union-of-india-decriminalisation-of-adultery-background/.
- Joseph Shine v. Union of India – Decriminalization of Adultery Background, Supreme Court Observer (July 11, 2025), https://www.scobserver.in/cases/joseph-shine-v-union-of-india-decriminalisation-of-adultery-background/#:~:text=Judgment%3A%20Chandrachud%20J-,September%2027%2C%202018,September%2027%2C%202018.
- Adultery, Wikipedia (July 11, 2025), https://en.wikipedia.org/wiki/Adultery.
- Section 497 in The Indian Penal Code, Indian Kanoon (July 11, 2025), https://indiankanoon.org/doc/42184625/.
- Case Analysis- Joseph Shine v. Union of India, Scribd (July 11, 2025), https://www.scribd.com/document/830455806/Case-Analysis-Joseph-Shine-vs-Union-of-India.
- SC to examine 157-year-old law on adultery punishing only men, Times of India (Dec. 9, 2017), https://timesofindia.indiatimes.com/india/sc-to-examine-157-year-old-law-on-adultery-punishing-only-men/articleshow/61985435.cms. (Note: I corrected the ‘last visited’ date for this one to reflect the article’s publication date, as it’s a news report).
[1] Joseph Shine v. Union of India – Decriminalization of Adultery Background, Supreme Court Observer (July 11, 2025), https://www.scobserver.in/cases/joseph-shine-v-union-of-india-decriminalisation-of-adultery-background/
[2] Joseph Shine v. Union of India – Decriminalization of Adultery Background, Supreme Court Observer (July 11, 2025), https://www.scobserver.in/cases/joseph-shine-v-union-of-india-decriminalisation-of-adultery-background/#:~:text=Judgment%3A%20Chandrachud%20J-,September%2027%2C%202018,September%2027%2C%202018
[3] Adultery, Wikipedia (July 11, 2025), https://en.wikipedia.org/wiki/Adultery
[4] Section 497 in The Indian Penal Code, Indian Kanoon (July 11, 2025), https://indiankanoon.org/doc/42184625/
[5] Joseph Shine v. Union of India – Decriminalization of Adultery Background, Supreme Court Observer (July 11, 2025), https://www.scobserver.in/cases/joseph-shine-v-union-of-india-decriminalisation-of-adultery-background/#:~:text=Judgment%3A%20Chandrachud%20J-,September%2027%2C%202018,September%2027%2C%202018
[6] Section 497 in The Indian Penal Code, Indian Kanoon (July 11, 2025), https://indiankanoon.org/doc/42184625/
[7] Joseph Shine v. Union of India – Decriminalization of Adultery Background, Supreme Court Observer (July 11, 2025), https://www.scobserver.in/cases/joseph-shine-v-union-of-india-decriminalisation-of-adultery-background/#:~:text=Judgment%3A%20Chandrachud%20J-,September%2027%2C%202018,September%2027%2C%202018
[8] Case Analysis- Joseph Shine v. Union of India, Scribd (July 11, 2025), https://www.scribd.com/document/830455806/Case-Analysis-Joseph-Shine-vs-Union-of-India
[9] Case Analysis- Joseph Shine v. Union of India, Scribd (July 11, 2025), https://www.scribd.com/document/830455806/Case-Analysis-Joseph-Shine-vs-Union-of-India
[10] Joseph Shine v. Union of India – Decriminalization of Adultery Background, Supreme Court Observer (July 11, 2025), https://www.scobserver.in/cases/joseph-shine-v-union-of-india-decriminalisation-of-adultery-background/#:~:text=Judgment%3A%20Chandrachud%20J-,September%2027%2C%202018,September%2027%2C%202018.
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