Remedies For Domestic Violence In Live-in Relationships Under The Protection Of Women From Domestic Violence Act

1. Introduction

2. Understanding the Protection of Women from Domestic Violence Act, 2005:

• Objective and Scope of the Act:
• Aimed at protecting women from domestic violence.
• Broad definition of domestic violence, including physical, emotional, sexual, and economic abuse.

3. Key Provisions and Practical Implications 

• Definition of “domestic relationship” under Section 2(f).
• Reliefs available under the Act, such as protection orders, residence orders, and monetary relief.
• Filing a Complaint: Procedure for filing a complaint under the Domestic Violence Act.

4. Live-in Relationships: Case Laws 

• Definition and Social Context: Understanding live-in relationships and their social acceptance.
• Legal Status: Judicial recognition of live-in relationships in India.
• Relevant case laws affirming the legality of live-in relationships.

6. Types of Reliefs Available

• Protection orders, residence orders, custody orders, and monetary relief.
• Ensuring enforcement of orders and providing support services
• Challenges and Future Directions

7. Recommendations for Legal and Social Reforms

• Enhancing awareness and sensitization.
• Strengthening legal provisions and support mechanisms for women in live-in relationships.

8. Conclusion

9. FAQs

Introduction: 

Marriage, which has always been the apple of the society's eye in India, is regarded as a deep-set religious and legal institution. In Hindu Law especially marriage is considered as the conflict of the two Pyres of which one represented the woman and the other her recently deceased husband before it is lighted. It turns the woman into a mere wick." But marriage is much more than that. It is a lifelong commitment to be the place where two people can help each other to become "pyres" which are burnt in the process of achieving moksha by which the relations in the body disappear or the ultimate reality is realized which leads them to mean "pyres" in this broad sense to pass into the state of existence in the house of the ineffable. Yet marriage is the one institution that symbolizes love with this law not being thoroughly encoded into the contract as a requirement. Rather, it introduces the process of internal integrity into the public recognition of love which has become the basis for the formation and breakdown of all relationships in the world. She, hence, is unable to change anything related to her love but to be the great help and the source of the initial stages that will help the process of familiarizing with the law.
It is often the case in India that live-in relationships are looked down upon and sometimes are not even accepted by the society as they are seen as something that has gone against cultural norms. The concept of marriage is constantly challenged as we now have people who prefer to live together first and marry later. On the contrary, despite the fact that more and more people are in favor of live-in relationships, such relationships are not legally binding under the rules of all the key Indian laws including Hindu Marriage Act, Criminal Procedure Code, and Indian Succession Act. It is still the brunt of the law that remains the same from day one.
Even if it is a difficult road, Women's arrested freedom is one of the advantages of the Protection Help to Women from Domestic Violence in India in 2005. "Relationships in the nature of marriage" is also included in the definition of the PWDVA bill that it. The Act regains the status of the abused person after the years which they had allowed themselves to be in a situation of violence and finally get reinforcement. It actually then in a domestic relationship refers to a couple who live together or have lived together in a common household no matter of blood relationships, a legal one alike to marriage or the intention of having or adopting a child. It may also include long-term unmarried couples living together.
This piece will focus on the legal solutions that the women in live-in relationships have during times of domestic violence under the Protection of Women from Domestic Violence Act (PWDVA). It will describe the Act's aims and limits, analyze its key provisions, and discuss the authorized as well as social position of the live-in relationships in India. The article will explore the statutory interpretations and the judicial decisions, thus, it will explain the practical consequences and the rights of women in these relationships. It will also be concerned with the challenges they face and propose the legal and social dimensions to be reinforced in order to give them better protection. The main point of the article being the provision of strong legal protection against domestic violence to all women, irrespective of their marital status, is highlighted.

Societal perception of the Live-in-Relationship: 

India's attitude towards live-in relationships is a product of very big and difficult to understand weave of cultural, religious, and economic factors. In the light of legal frameworks that are being adopted to consider and govern the rights of people in these arrangements, society's viewpoints are very different among others. Both pros and cons are attached.

On the other hand, in urban areas, globalization together with modernization has broken new ground for live-in arrangements, thereby increasing acc. Standing the two sides for a moment, it is likely that residential areas will maintain their standards more and live-in relationships formed in traditional ways will be willingly protected. There are such concepts as the growing strength of family and society, which is largely dependent upon marriage being the priority, the recognition of gender roles that come alongside this issue, and the teachings of such religious institutions as the Christian faith. One of the side effects of this is that single people who decide to live outside of marriage may be denied the respect and support of the community. 

Even if much progress has been made in the law's acceptance and illumination of the rights of live-in relationships holders, discrimination and stigmatization, especially towards women, still exist. It is a well-known fact that prejudice in society always labels women who cohabit outside of marriage as the ones without morals or promiscuity, which can affect.

However, there is now a movement aiming to destroy stereotypes and secure the individual rights of cohabiting partners. Civil society organizations, local activists, and advocacy groups are engaged in the process of creating an environment of awareness raising, de-stigmatization, and gender normalization in intimate partnerships. Legal aid clinics and support services remain essential in solving the discrimination or violence problems of an individual and thus in turn let them express their rights to seek refuge in court.

The media, on the other hand, greatly affects the public's view and conversations about live-in relationships. Diverse models of relationships shown in a positive light can help decay these biases of people and thus gain more acceptance in society. It must be remembered that at the grassroots level, intentional interventions designed to give prominence to respect for autonomy and diversity alongside the more top-down programs is indispensable.

In essence, social attitudes towards Indian live-ins are informed by the intricate balance of cultural traditions, economic inequalities, and gender power dynamics. While there has been improvement in the legal area to acknowledge the rights of people in such relationships, discrimination, and stigma are still rife, especially against women. The continual campaigns against opinion mobility and for gender equality are crucial for fostering the acceptance of the diversity of relationship patterns. Education, advocacy, and empowerment schemes can lead to a society that is more inclusive and fairer wherein each individual is recognized and appreciated no matter what their relationship choices are.

Laws related to Live-in Relationships in India: 

Back in 2008, the Maharashtra government made an effort to amend Section 125 of the Criminal Procedure Code (CrPC), which focused on the legal status of cohabitation. This amendment aimed to enlarge the definition of "wife" to include a woman who has lived with a man "like his wife" for a significant duration. This program Has been the result of the suggestions of the Malimath Committee, which was the body that had recommended the revision of the legal system for the safety of the women folk in 2003. The mentioned committee was of the view that the meaning of the word wife be broadened to incorporate women who are in live-in-relationship or the man who may still be married to someone else. The notion won the backing of the Supreme Court in the 2013 case of Deoki Panjhiyara v. Shashi Bhushan Narayan Azad.

The Maharashtra amendment also threw light on the legal recognition of two types of relationships: one that is secondary (where the man has a relationship with a woman other than his wife) and the other which is a modern live-in relationship (where a couple chooses to live together without marriage). According to the media the proposed bill was designed in such a way that after a certain period of residence of a woman with a man he should be given the status of a wife.

Understanding the Protection of Women from Domestic Violence Act, 2005:

The Protection of Women from Domestic Violence Act 2005 (PWDVA) is an important Act that gives equal status to adult non-marital heterosexual relationships. It defines an "aggrieved person" as any woman who is or has been in a domestic relationship with the respondent and claims to have faced domestic violence. The Act describes a "domestic relationship" as one where individuals live or have lived together in a shared household, regardless of blood, marriage, or through a relationship akin to marriage.

The PWDVA notes that through the general category of domestic violence--a bracket, which includes physical, sexual, emotional, verbal and economic abuse PWDVA aims to weigh the ground realities in the 21st century's Indian society. At the same time, the phrase "in the nature of marriage" is cited as being vague and leading to legal quarrels. Notwithstanding, the Grey area regarding the domestic violence Act was brought to light in the 2008 Delhi High Court case of Aruna Parmod Shah vs. Union of India, the petitioner contending that the Act was discriminating against men with the argument that it was equating the unrecognized relationships with legally recognized ones. The court discredited these claims by insisting that also women who live with their dependents should receive similar rights as to women in legally wedded relationships.

The court dispersed the phrase "a relationship in the nature of marriage" so as to include mutual law marriages and relationships with mistresses but the areas frieze of the legality and social implications of these terms was not clearly marked. According to the report entitled Staying Alive 2008 by Lawyers Collective and the International Center for Research on Women, a common law marriage is characterized by couples living together for an extended period of time and presenting themselves as married, considering factors such as cohabitation, shared children, and a common surname.

A major part of the Protection of Women from Domestic Violence Act (PWDVA) is the availability of protection orders, which are aimed at ending future incidents of domestic violence and assuring the safety of victims. These orders include, but are not limited to, prohibitions instructing an abuser to stop behaving violently, contacting a victim, or entering certain places. It is the legal orders, which are immediately available to the victims before the court and are therefore a primary tool in decreasing the possibility of harm whereas the discharge of the interim orders may be the next step to take for the continuance and utmost seriousness of the visitation of the wife with her husband and their small daughter Gamov residence raising]. The Act also makes a provision for residence orders, which puts in action where domestic violence implies the right for victims of violence to remissions or to return to the household regardless of the legal right to register. In this sense, they resolve problems that come up with the right of use of the house and ownership as well. Residence orders are a form of protection that will outline the accommodation rights of the victims, meaning they will surely find a safe place to live. Appealingly, besides other powers provided to them by the PWDVA the courts can also bestow financial assistance directly to the person who sustained the injury due to the crime, which will thus cover compensations for injuries, los genuas, and loss of the salary-term for the victims. Recognizing the material dimension of domestic violence is an urgent priority in both developing and developed countries. The given circumstance is quite pronounced in live-in relationships, which presents women to risk; thus the economic portion might be more dramatic. This is why the Act allocates the resources to the survivors, and hence they are able to start afresh and get free from the burden. The problem of economic dependence with sometimes extra hardness in live-in relations is being checked by this act, which financially assists persons, so as it is seen in the following example.

Key Provisions and Practical Implications: 

The Protection of Women from Domestic Violence Act, 2005 (PWDVA), law is significant in so far as for the first time it recognizes the concept of "relationships in the nature of marriage" within its definition of "domestic relationship." Section 2(a) of the PWDVA defines an "aggrieved person" as any woman who is or has been in a domestic relationship with the respondent and alleges to have been subjected to domestic violence. ‘Aggrieved person’ means any woman who is a victim of domestic violence or has been threatened to be a victim of domestic violence by the husband or his relative. In addition, under Section 2(f) of the Act, the term "domestic relationship" means a relationship between two people who live together at a shared household or who lived together as a couple and have had offspring and so on. It is not without reason that this particular definition has been used specifically given the context surrounding its promotion when one appreciates how multifaceted its very notion establishes the idea that such a relationship can be treated as primafacie a marriage in law. 

The Protection of Women from Domestic Violence Act, 2005 is a pivotal policy because it is the first law in India to recognize live-in relationships among adults of opposite sex who are not married. The aggrieved person is any woman who has been in a domestic relationship with the respondent or male partner and who claims to be subject to violence at the hands of the same. This widened interpretation of marriage includes "marriage like relationships" in a comprehensive manner and shows the contemporary society’s social differentiation collectively visualised within the Act, irrespective of whether a woman is married or not.

This act defined the domestic violence as, 

3. Definition of domestic violence.— 

For the purposes of this Act, any act, omission or commission or conduct of the respondent shall constitute domestic violence in case it— 

(a) harms or injures or endangers the health, safety, life, limb or well-being, whether mental or physical, of the aggrieved person or tends to do so and includes causing physical abuse, sexual abuse, verbal and emotional abuse and economic abuse; or 

(b) harasses, harms, injures or endangers the aggrieved person with a view to coerce her or any other person related to her to meet any unlawful demand for any dowry or other property or valuable security; or 

(c) has the effect of threatening the aggrieved person or any person related to her by any conduct mentioned in clause (a) or clause (b); or (d) otherwise injures or causes harm, whether physical or mental, to the aggrieved person. 

Explanation I.—For the purposes of this section,—

• (i)    “physical abuse” means any act or conduct which is of such a nature as to cause bodily pain, harm, or danger to life, limb, or health or impair the health or development of the aggrieved person and includes assault, criminal intimidation and criminal force;
• (ii)    “sexual abuse” includes any conduct of a sexual nature that abuses, humiliates, degrades or otherwise violates the dignity of woman;
• (iii)    “verbal and emotional abuse” includes— (a) insults, ridicule, humiliation, name calling and insults or ridicule specially with regard to not having a child or a male child; and (b) repeated threats to cause physical pain to any person in whom the aggrieved person is interested;
• (iv)    “economic abuse” includes— 
  a.    deprivation of all or any economic or financial resources to which the aggrieved person is entitled under any law or custom whether payable under an order of a court or otherwise or which the aggrieved person requires out of necessity including, but not limited to, house hold necessities for the aggrieved person and her children, if any, stridhan, property, jointly or separately owned by the aggrieved person, payment of rental related to the shared house hold and maintenance;  
  b.    disposal of household effects, any alienation of assets whether movable or immovable, valuables, shares, securities, bonds and the like or other property in which the aggrieved person has an interest or is entitled to use by virtue of the domestic relationship or which may be reasonably required by the aggrieved person or her children or her stridhan or any other property jointly or separately held by the aggrieved person; and 
  c.    prohibition or restriction to continued access to resources or facilities which the aggrieved person is entitled to use or enjoy by virtue of the domestic relationship including access to the shared household. 

Explanation II.—For the purpose of determining whether any act, omission, commission or conduct of the respondent constitutes “domestic violence” under this section, the overall facts and circumstances of the case shall be taken into consideration.

The commitment to recognising and protecting consensual adult relationships outside of traditional marriage is reflected in several Supreme Court judgments. One of them is S Khushboo vs Kanniammal & Anr (28 April 2010) where Justices Deepak Verma and B.S. Chauhan said that although society reserves sexual relations for married partners, consensual adult relationships outside marriage are not criminal by themselves.

Procedural Overview of the PWDVA

• Filing an Application: An aggrieved woman, a Protection Officer, or another person who can represent her may file an application to the Magistrate seeking relief under the Act (Section 12). The application of which is to be in a prescribed form and must be filled with the necessary details required for the case.
• Initial Hearing: The Magistrate is required to organize the first hearing within three days of the application submission (Section 12(4)) and it must not last for more than 60 days of the initial hearing (Section 12(5)) at the end.
• Service of Notice: The Magistrate will notify the Protection Officer, who will have to serve the notice to the respondent and other specified individuals, if any, within two days (Section 13). The Protection Officer's testimony of service is a form of evidence.
• Counseling: The Magistrate might order both parties to undergo counseling by a qualified service provider in any cases (Section 14).
• In-Camera Proceedings: The Magistrate holds the right to proceed in camera in the cases where it is the requirement or it is demanded by any of the parties (Section 16).
• Ex Parte and Interim Orders: The court allows the issuance of the interim order(s) in case of necessity (Section 23(1)). If the affidavit affidavit of the aggrieved person proves domestic violence as a prima facie element, then the ex-parte orders ought to be issued (Section 23(2))
• The protection order or residence order the Magistrate has the power to grant under the same (Sections 18-22). In fine The Magistrate is authorized to issue directions to the police officer in charge of the nearest police station to enable him to enforce the protection orders, the being ordered by the Magistrate (Section 19(5)). Such orders are issued for the entire state of India (Section 27(2)).
• Orders Broken: The order constituting breach of protection is a cognizable non-bailable offense (Sections 31, 32) and they can be tried by the same magistrate's who who issued the order.
• Judicial Review: 30 days after the service of an order, the Court of Sessions is allowed to receive the appeal against the orders of the Magistrate (Section 29).

The procedural framework of this process is intended to provide women with a quick and easy tool to get protection and relief from domestic violence problems while still allowing all the parties concerned to be able to exercise their rights. Additionally the preservation of the rights of women is a strong directive already brought by the Supreme Court through the verdict in the case of the South Indian actress Khushboo, which was that the relationships of adults outside of the matrimony-that are mutual consent are not inherently criminal, although in the traditional society it may seem to be so. 

Live-in Relationships: Case Laws 

The Protection of Women from Domestic Violence Act, 2005 (DV Act) was enacted to protect women in various domestic relationships. Section 2(f) of the DV Act defines a “domestic relationship” as a relationship between two persons who live or have lived together in a shared household, including those related by blood, marriage or through a relationship in the nature of marriage, those who are adopted or are family members living together as a joint family.

In D. Velusamy v. D. Patchiammal, AIR 2011 SC 479 the Supreme Court laid down four criteria for a relationship to be considered as a “domestic relationship” under Section 2(f) of the DV Act: 

1. The couple must present themselves to society as being like spouses.
2. They must have lived together in a shared household as defined in Section 2(s) of the DV Act.
3. Spending weekends together or having a one night stand does not qualify as a “domestic relationship”.

In Indra Sharma v. VKV Sharma, AIR 2014 SC 309 the Court dealt with a petition for protection under the Protection of Women from Act. The respondent claimed that he lived with the petitioner out of sympathy and provided her with moral and financial support. The Supreme Court invoked the doctrine of Constructive Trust and acknowledged the inherent inequalities in such relationships and said that women suffer when these relationships end. The Court asked Parliament to consider the reality of the society and the status of women and children born out of such relationships and make appropriate laws to protect them.

In Revanasiddappa & Anr. vs Mallikarjun & Ors., AIR 2011 SC 479 the Supreme Court said that children born out of such relationships are innocent and entitled to the same rights and privileges as children born out of valid marriages as per Section 16(3) of the amended Hindu Marriage Act, 1955.

Several other judgments have also clarified the legal status and protection of live-in relationships:

1. In Vidyadhari v. Sukhrana Bai (2008) the Supreme Court gave Succession Certificate to the live-in partner nominated by the deceased.
2. In Koppisetti Subbharao Subramaniam v. State of A.P. (2009) the Court extended the protection against dowry under Section 498A of the Indian Penal Code to those in marital relationship under the guise of being husband and wife.
3. The Patel and others case (2010) said that two adults in a live-in relationship without formal marriage are not criminal offenders.
4. In Tulsa v. Durghatiya (2008) the Court reiterated the presumption of marriage under Section 114 of the Indian Evidence Act, 1872 in cases of long term cohabitation.

The Supreme Court has laid down the following guidelines to assist Parliament in enacting provisions for protection in live-in relationships:

• Duration of Relationship: The relationship should be sustained over a period of time that is considered reasonable to keep the relationship going.
• Shared Household: As defined under Section 2(s) of the DV Act.
• Pooling of Resources and Financial Arrangements: The parties must have supported each other financially and acquired properties jointly.
• Domestic Arrangements: Parties entrusted with responsibilities concerning household management.
• Sexual Relationship: A relationship for emotional support, companionship, and procreation.
• Having Children: A demonstration of the fact that the relationship has been long term.
• Socialization in Public: Presenting themselves to society as man and wife.
• Intention and Conduct of the Parties: Common intention as to their relationship.

The judiciary has, in a manner of speaking, bridged the gap toward upholding the dignity and protection of individuals in live-in relationships, bringing legal interpretations abreast with changes in society. This will, however, require Parliament to further fine-tune and put in place comprehensive legislation recognizing and protecting such relationships and their offspring. 

Other Protections for Domestic Violence in Live-in Relationships:

• Section 125 of the CrPC

The principal issues in live-in relationships relating to the Criminal Procedure Code are on maintenance privileges. Section 125 of the CrPC grants the wife, children, and parents the right to maintenance; however, this statute does not cover partners living with each other. The courts have been dilemmatic about applying the above-said section to persons living with each other in such relationships. Whereas some judgments have held the right to maintenance for partners living in live-in relationships, others needed proof of a 'palpable domestic relationship' comparable to marriage, and vagueness has persisted over the form through which relief-seekers may acquire.
The expression 'wife' entitled to maintenance has been defined under Section 125(1)(b) of the CrPC as: "Wife includes a woman who has been divorced by, or has obtained a divorce from her husband and has not remarried."Thus, a woman who could not be termed a legally wedded wife could not claim maintenance from her partner or husband and was not entitled to claim maintenance. Therefore, a woman living in a live-in relationship or an illegitimate wife could not claim any right to maintenance under this provision. In 2014, the Supreme Court took up the issue and has ruled that an unmarried woman who is tricked into living with a married man, unaware of his marital status, can claim maintenance under Section 125 of the CrPC. It was a revolutionary verdict by the Supreme Court, which put women in live-in relationships on a higher status.

• The Indian Penal Code: 

Ex-fundamentals of the penal framework in India is the Indian Penal Code, extending from criminal offence at very minor levels to significant ones. Though IPC is mainly related to criminal acts, still its provisions do intersect with various aspects of intimate relationships including those in live-in arrangements. There are absolutely no provisions in IPC which explicitly criminalize live-in relationships. However, specific provisions relating to adultery, rape, and cruelty do apply to people who enter into such relationships.

• Adultery (Section 497 of the IPC): Section 497 dealt with adultery, which means sexual intercourse between a man and a married woman without the consent or connivance of the husband. This section dealt particularly with extramarital affairs in the context of marriage. This was, however, declared unconstitutional by the Supreme Court under the landmark judgment of Joseph Shine v. Union of India in 2018 and adultery was decriminalized, emphasizing individual autonomy over decisions pertaining to personal relationships.
• Rape (Sections 375 and 376 of the IPC): The IPC has enumerated sexual violence against any person without his/her consent as rape. Therefore, these provisions also protect the individual in a live-in relationship where the sexual act has been done without consent or under coercive circumstances. However, sometimes it becomes difficult for the enforcement agencies and the judiciary to differentiate between a consensual and non-consensual sexual act in a live-in relationship.
• Cruelty: Section 498-A Section 498A of the Indian Penal Code (IPC) relates to cruelty of a man towards his wife, either by himself or through a close relative or family member, and includes acts of such a nature for performing his desire of lust. The section, though related to marriage, has been applied in looser, informal relationships. The courts have equally read 'cruelty' widely to include acts of domestic violence within live-in arrangements and have provided protection to such individuals being so mis-treated regardless of their marital status. At the same time, the courts have also interpreted that the absence of specific provisions definitely recognizing live-in relationships under Section 498A has led to an inconsistency in the legal interpretation and enforcement.

Although live-in relationships are not specifically legalized with respect to the IPC, some provisions relate to adultery, rape, and cruelty as having a stake in the matter in some way, to serve those in such a relationship. As aforementioned, the judgment in Joseph Shine v. Union of India had also taken the step of decriminalizing adultery. However, in such cases, the rape laws and provisions related to cruelty within live-in also require application in a judicious and practical manner so that an individual's rights and dignity are not violated.

Uttarakhand and Uniform Civil Code

Under the Uttarakhand UCC, individuals engaging in a live-in relationship are required to register with district officials. At the same time, it requires consent from parents for individuals under the age of 21. Registration of relationships reflecting public policy negatively or relationships involving persons under the age of 21, married spouses, or relationships acquired through coercion or fraud is prohibited. Written statement is the only way to terminate it, but if suspicious, it is subject to police investigation. Unregistered or false declarations can attract fines and imprisonment. Children from live-in relationships are legally recognized and have equal inheritance rights. The UCC also provides for maintenance claims of women deserted by partners. The move is an attempt at a codified law on marriage, divorce, and inheritance, banning polygamy, child marriage, 'halala,' and 'iddat.' Similar implementation of UCC is planned in Assam, exempting tribal communities.

Reliefs: 

There are a few types of reliefs available under the PWDVA, 2005 for women under domestic violence including those in live-in relationships. The broad outline of the primary reliefs available is as follows:

• Protection Orders:

The courts have the power to grant orders that may restrain an abuser from continuing to commit acts of violence. Such orders can restrain an abuser from communicating with the victim or entering specific premises, or disposing of assets. Protection orders are supposed to ensure the immediate safety of a victim.

• Residence Orders:

These orders allow the victim to stay in or return to the shared home, regardless of ownership. This means the abuser is denied access to parts of the shared home or can be entirely excluded from it. This fact is very important in securing that the victim will have a safe place to live, which is an essential need whenever there is violence in the home.

• Monetary Relief:

The courts may, therefore, order compensation to be paid to cater for expenses related to the violence. That is to say, reimbursement for medical treatment costs, lost pay, or any other financial loss associated with abuse is possible. This may thus include financial provision that aids in the recovery and upkeep of independence for the victim.

• Custody Orders:

Temporary custody of the children may be given to the victim so that the children are safe from the violence and that their well-being is catered for during the process.

• Compensation Orders:

The court can ask the batterer to compensate for the injuries suffered, both mental agony and emotional stress.

• Interim and Ex-parte Orders:

Courts are empowered to pass interim orders before the leading of all evidence or even hearing from the opposite party. This would allow taking urgent measures so that the victim may be saved in urgent cases.

• Right to Reside in Shared Household:

Women have a right to safe accommodation in the shared household, irrespective of who holds title to the property.

• Right to Services of Protection Officers and Service Providers:

The Act entitles support services for aid in prosecuting their cases and other support services.
These reliefs are designed to protect and safeguard women from domestic violence on issues concerning their physical safety, economic needs, and their general well-being. Importantly, these protections extend to women who are in live-in relationships, recognizing that legal safeguards are needed for women in varied domestic partnerships.

Suggestions: 

• The Supreme Court's bold move in the cases of Velusamy vs. D. Patchaiammal and Indra Sarma vs. V.K.V. Sarma, which recommended expanding the definition of 'domestic relationship' in Section 2(f) of the Protection of Women from Domestic Violence Act (PWDVA), 2005. This expansion aims to include victims of illegal relationships, particularly poor and illiterate women, and their children born out of live-in relationships who lack their own income. Additionally, Parliament can enact new legislation based on the Supreme Court's guidelines from these judgments for the live-in-relationships.
• Regarding the Criminal Procedure Code, 1973 (Section 125), amending the definition of 'wife' to include a woman in a 'relationship in the nature of marriage' for a significant period.
• For the Indian Evidence Act, 1872 (Section 112), that the legitimacy of a child is currently recognized only if the child is born during a valid marriage. This should be reconsidered to include children born out of live-in relationships, aligning with similar recognition in Muslim law for children born to a man and his wife.

Conclusion: 

The Protection of Women from Domestic Violence Act, 2005, is perhaps the most epoch-making legislation insofar as the recognition and protection of the rights of women in live-in relationships in India are concerned. Expanding the protective ambit of the Act to "relationships in the nature of marriage," the Act identifies the changing dynamics of intimate partnerships in contemporary Indian society. Under the PWDVA, protection orders, residence orders, and monetary relief assume paramount consideration, hence making it an entire framework toward the redressal of domestic violence in all forms of domestic relationships, including live-in relationships. This recognition through legislation, along with judicial interpretation, has been a stepping stone toward better legal protection for women in non-traditional relationships.

However, problems remain in the actual implementation and acceptance by society of these protections. The vagueness of the term "relationship in the nature of marriage" has given way to different interpretations. It is consequently incumbent upon the legislature to provide more deliberation or enact amendments to the statute. Added to this is the fact that societal stigma and discrimination against women have constituted a barrier to justice availed of under the Act, more so in conservative backgrounds. The legal framework would require additional the following:

• Lucid legislative definitions of live-in relationship
• Improved awareness and sensitization campaigns
• Support mechanisms for women in live-in relationships to be made effective
• Judicial activism to interpret the law in favour of protection of vulnerable persons to continue

With the changing societal structures of India, its legal structures also need to evolve to protect everyone, be they relationships or not. The PWDVA is a step in this direction, but much work remains to be done in order that the letter of the law is translated into effective remedies and protection for all victims of domestic violence, including those in live-in relationships.

FAQs: 

1. Which committee recommended the expanded interpretation of the Section 125 CrPC to protect women in live-in-relationship from domestic violence? 
   Malimath committee recommended the meaning of the word wife be broadened to incorporate women who are in live-in-relationship.
2. Supreme court in which judgement gave the guidelines for the to assist Parliament in enacting provisions for protection in live-in relationships
   In Indra Sharma v. V.K.V Sharma AIR 2014 SC 309, the Supreme court gave the guidelines for guiding the live-in relationships and to assist Parliament in enacting provisions for protection in live-in relationships.
3. Under what section of the Protection of Women from Domestic Violence Act, 2005 “Domestic violence” is defined? 
   Under the Section 3 of the Protection of Women from Domestic Violence Act, 2005 Domestic violence is defined and many judgements describe the domestic violence application.
4. How to file an application for the domestic violence under the Protection of Women from Domestic Violence Act, 2005? 
   Filing an Application: An aggrieved woman, a Protection Officer, or another person who can represent her may file an application to the Magistrate seeking relief under the Act (Section 12). The application of which is to be in a prescribed form and must be filled with the necessary details required for the case.