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Critical Analysis Of Law Of Adultery In India 1

*Dr.Anjuli Sharma
**Neha Sharma

A. INTRODUCTION

Adultery is defined under law as a consensual physical correlation between two individuals who are not
married to each other and either or both are married to someone else. The actual definition of adultery may
vary in different jurisdictions but the basic theme is sexual relations outside marriage. Adultery, also known as
infidelity or extra-marital affair is certainly a moral crime and is thought-out a sin by almost all religions.

In the United Kingdom, these were ecclesiastical crimes and therefore not part of the common law. 2 Only
“open and notorious” fornication was considered a crime because it was a public nuisance.3 In the rest of the
western world and particularly few western countries like Finland, Belgium and Sweden doesn’t treat adultery
as a crime but the Indian jurisdiction considers adultery as a punishable and heinous crime. The union of
marriage has a spiritual, communal and lawful authorization in India. Hence, a sexual liaison that flouts this
sacred bond implies rebelliousness with common customs. It is a breach of trust as well as infringement of the
holy marital promises, conscientiously and ethically held to be revered and does carry a punishment under the
decree.

B. ADULTERY HISTORICAL PERSPECTIVE

Barring few exceptions of tribal communities, the evolutionary development of family institution in India
portrait patriarchal pattern, and thus, the permissible marital tie prescribe strict restriction on sexual behavior
of married couple, especially of woman. The reflection of such normative pattern in the sexual activities
reflected in many incidences. Formation of permissible sexual relationship need social sanction and only
monogamy, polygamy, polyandry types of sexual intercourse had social recognition. However, in few
societies’ practices like “keep”, “slave keeping”, “Muta marriage” has also observed as a practice. Thus, one
common, though not universal, feeling has been observed throughout the history about the adultery, that it is

1
*Dr,Anjuli Sharma (Asst Professor M.L.B Govt College Of Excellence Gwalior)
**Neha Sharma, LL.M, ( Amity University, Gwalior)
2
Carotti v. State, 42 Miss. 334, 346 (Miss. Err. & App. 1868); Martin J. Siegel, For Better or For Worse: Adultery, Crime
& the Constitution, 30 J. FAM. L. 45, 47 (1991-1992); see also State v. Whealey, 59 N.W. 211, 212 (S.D. 1894) (“It was
regarded as an offense so essentially wicked, so subversive of private and public morality, and so opposed to the precepts
and practice of religion, that its punishment was left to the ecclesiastical courts”).
3
Martin J. Siegel, For Better or For Worse: Adultery, Crime & the Constitution, 30 J. FAM. L. 45, 47 (1991-1992);
Richard Green, Fornication: Common Law Legacy and American Sexual Privacy, 17 ANGLO-AMERICAN L. REV.
226, 227 (1988).
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prohibited norms in one or the other form in every form of society.

This is to be noted down that adultery shall be put on different aspects of criminal behavior than other crime
mentioned under the penal statutes. Adultery does not have the grave effect on the society, or rather it does not
pose threat to the peaceful existence of society as in the other cases of crime such as murder, dacoit, theft,
grievous hurt, public tranquility, defamation, rape etc,. The similar is the thing about the punishment for
adultery. It can be argued that the punishment to the person committing adultery is not and cannot be a remedy
for a person aggrieved of adultery. The object of prosecution for adultery is more often to reach a settlement
with the offender at the mercenary level and seldom to send the offender to jail. In fact this was the very
reason why the offence of adultery did not figure in the very first draft. To this extent, the conditions are not
appreciably different even today. The existence of Section 497 has no apparent affect on society.
Acknowledging this most western countries have decriminalised adultery. It is not a crime in most countries of
the European Union, including Austria, the Netherlands, Belgium, Finland, Sweden and even Britain from
11
whom we have borrowed most of our laws. In the United States, in those states where adultery is still on the
statute books, offenders are rarely prosecuted. However, it still remains part of discussion in this research
st
paper that whether adultery shall be made punishable at all in 21 century or it shall be dealt in the like
manner such as other western countries by decriminalizing it.
Historically in India, ‘adultery’ had been considered as an anti-social activity and prohibited by law. However,
the concept and understanding about the adultery in ancient period and modern period is little bit different, and
punishment also differs. The ancient code of Manu merely provided for varying range of punishments for
offence of adultery ranging from simple repentance to the ghastly burning of the offender.

C. DEVELOPMENT OF LAW OF ADULTERY IN INDIA

In India, the provision on ‘adultery’ under the penal statutes has gained controversy from its inception. The
main architecture of Indian Penal Code, Lord Macaulay, was against the insertion of such section in the
original draft and wanted to keep it out of the purview of penal statutes. According to him, such inclusion will
unnecessary and unwarranted and shall be left to the society to take care for. Therefore the first proposed
original draft of Indian Penal Code did not have any such provision. But it was included latter on.
The enacted first penal legislation in India contained the offence of adultery which was put under Chapter XX
that deals with the Offences Relating to Marriage. It contained four sections 494-498. Thus the section as it
was stand in the penal statutes prescribed that if a man, married or unmarried has voluntary and consensual
sexual intercourse with a married woman, without the connivance of her husband, he would be criminal held
liable for the offence of adultery.
The plain reading of this section clearly manifested the original prejudices in the mind of the framer of this
section. Thus from the inception of S. 497, it was so drafted to make man guilty, and complete shield to the
wife, even she may be the active participant in the commission of an offence. The further analysis of this
section unequivocally conveys that a man alone can commit adultery and the woman (adulteress) is not liable
even as an abettor. Whatever may be justification, or social necessity, this section clearly from its inception put
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this presumption on legislative agenda that whether the woman is a victim of adultery or is herself an
adulteress, she is completely free of being penalized for offence of ‘adultery’.
The feminists also raise the objection on the S. 497 as it portrait prejudice of wife as property of her husband.
According an argument has been raised that dubious as all the meanings of the word are, the one chosen in S.
497 of IPC entrenches male control over women. The inferences that can draw from this law are twofold. One
that the man owns his wife sexually, and his consent is necessary to gain sexual access over her. Second, the
offence of adultery is legally equivalent to that of theft, the goods being the wife’s body. Women are therefore,
denied agency, whether they themselves have committed adultery (as understood generally) or are married to
men committing adultery. 4
It is pertinent to note that the original draft of IPC prepared by first Law Commission was silent about the
offence of ‘adultery’. Lord Macaulay, who was unwilling to add the provision criminisling the adultery as an
offence, observed, "There are some peculiarities in the state of society in this country which may well lead a
humane man to pause before he determines to punish the infidelity of wives. 5 The basic objective of keeping
‘adultery’ out of the penal statute was the social norms which has already provided the values and norms
which take care of such instances. The circumstances he referred to included child marriage and polygamy.
Macaulay, hence, advised that it would be enough to treat it as a civil injury. Thus, framers of the Code did not
include adultery as a crime; it was only after the recommendation of the Second Law Commission it was
added to the Code. 6
Thus, it is on the record that the framers of the Code did not make adultery an offence punishable under the
Code. But the Second Law Commission, after giving mature consideration to the subject, came to the
conclusion that it was not advisable to exclude this offence from the Code. 7
The Second Law Commission thought otherwise and said it would not be proper to leave the offence out of the
IPC and suggested that only the man be punished, again keeping in mind the condition of women in the
country.
The argument given that why the wife would not be punished has been provided as follows :—
“Though we well know that the dearest interests of the human race are closely connected with the chastity of
woman and the sacredness of the nuptial contract, we cannot but feel that there are some peculiarities in the
state of society in this country which may well lead a humane man to pause before he determines to punish the
infidelity of wives. The condition of the women of this country is, unhappily, very different from that of the
women of England and France; they are married while still children; they are often neglected for other wives
while still young. They share the attention of a husband with several rivals. to make laws for punishing the
inconsistency of the wife, while the law admits the privilege of the husband to fill his ‘zenana’ with woman, is

4
Gangoli Geetanjali, Indian Feminisms : Law patriarchies and violence in India, Ashgate Publishing Company USA, 1st
Ed.2007. pg. 61
5
See, Comment on the draft of first Law Commission Report. Gaur K.D., Indian Penal Code. Eastern Law Publication,
2nd Ed. Pg. 388
6
Ratanlal & Dhirajlal, 2 Law of Crimes at 2710 (Bharat Law House 26th ed 2007) (C.K. Thakker and M.C. Thakker, eds)
7
RatanLal and Dhiraj Lal’s Indian Penal Code (Enlarged Edition) 29th Edition, 2002, page 2305
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a course which we are most reluctant to adopt. We are not so visionary as to think of attacking by law an evil
so deeply rooted in the manners of the people of this country as polygamy. We leave it to the slow, but we
trust the certain, operation of education and of time. But while it exists, while it continues to produce its never
failing effects on the happiness and respectability of women, we are not inclined to throw into a scale, already
too much depressed, the additional weight of penal law.” 8

The object of making ‘adultery’ as an offence and restricting it to ‘Man’ alone was to deter ‘Man’ from taking
advantage of woman starved of the love and affection of her husband and deter Man from having sexual
relations with the wife of other man. Since men had the social sanction to maintain such relations and women
were starved of the love and affection of their husbands, women were treated as the victims and not the authors
of the crime. When Section 497 was enacted there were no codified personal and matrimonial laws like today
but they were unequal and inoperative. 9
Apart from IPC, there is one other penal legislation in India that regulate ‘Adultery’ in India. Ranbir Penal
Code, 1932 especially applicable to the State of Jammu and Kashmir is one such legislation. It provides under
S. 497 for the punishment for the offence of adultery, it reads.
“Adultery : 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 a case the wife shall be punishable as an abettor.”
It is important to note that a bill in 1972 as the Indian Penal Code (Amendment) Bill, 1972 suggested that
special privileges granted to woman under S. 497 of the Code be done away with. However, the amendment of
the section could not be carried out and law remains as it was when enacted in 1860. It is pertinent to mention
here the recommendation of the Law Commission of India in its 42nd report regarding the provision of
adultery in I.P.C. The recommendation 10 was as follows :—
“20.18. After much discussion and careful consideration, we are of the opinion that the
exemption of the wife from punishment under S. 497 should be removed, that the maximum
punishment of five years imprisonment prescribed in the section is unreal and not called for in
any circumstances and should be reduced to two years, and that with these modifications, the
offence of adultery should remain in the Penal Code. It is accordingly recommended that the
section may be revised, as follows :
‘497. Adultery.— If a man has sexual intercourse with a woman 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,
the man and woman are guilty of the offence of adultery, and shall be punished with

8
Gaur (Dr.) K.D., A Text Book on the Indian Penal Code (2004, Ed.). pg 734
9
See Varad Deore, A Provision Redundant in Penal Law in Changed Legal and Social Context, available at
http://www.legalserviceindia.com/article/l291-Adultery.html visited on 23.01.2011
10
Legal and Constitutional History of India, 2001 Reprint, page 379
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imprisonment of either description of a term which may extend to two years, or with fine,
or with both.’ 11
Thus the proposal of Law Commission is to bring the section of the line of gender neutrality without
discriminating the two different sexes and making them criminally liable in equal degree. However, the Law
Commission had proposed the lesser degree of punishment.

D. SECTION 497 : CONSTITUTIONAL CHALLENGES:

The first important discussion regarding the constitutional validity of the section was held in the case of Yusuf
Abdul Aziz v The State of Bombay and Husseinbhoy Laljee. 12 In this case, Section 497 of the Indian Penal
Code was challenged to be ultra vires the Article 14 and 15 of the Constitution of India. The Supreme Court
held that Article 14 is general provision and should be read keeping in mind the other provisions which sets
out exceptions to fundamental rights. Sex is a sound classification and Article 15 (3) provides for the
exceptions to the women and children. The petitioners argued that this clause is made only for the beneficial of
the women and not for giving license for committing or abetting crime. However, the Court held that they
cannot see any restrictions as such; nor they agree that the section tantamount to a licence to commit the
offence of which punishment has been prohibited. The Court finally held that Article 14 and 15 when “read
together validate the impugned clause in section 497 of the Indian Penal Code”.
In the case of Sowmithri Vishnu v Union of India13 the Supreme Court held that the Section 497 is not violative
of the Article 14 or Article 15 of the Indian Constitution on the grounds that:
(1) Section 497 confers upon the husband the right to prosecute the adulterer but, it does not confer any right
upon the wife to prosecute the woman with whom her husband has committed adultery. The Supreme Court
considered this to be a policy of law, and while defining the offence of adultery if the offence is restricted to
men is not violative of any constitutional provision.
(2) Section 497 does not confer any right on the wife to prosecute the husband who has committed adultery
with another woman. The Court said that the law is that the wife who is involved in an extra-marital sexual
relationship is not a author of a crime but is a victim and the legislature considers it to be offence against the
sanctity of a matrimonial home, and the offence is generally considered to be committed by a man. The
procedure of law and the definition itself speaks for who have the right to prosecute whom.
(3) Section 497 does not take in cases where the husband has sexual relations with an unmarried woman, with
the result that husbands have, as it were, a free licence under the law to have extra-marital relationship with
unmarried women. The Court said that the law does not give freedom to men to have illicit relations with
unmarried women, it only made a specific kind of extra-marital relation as an offence which it considered to
be most seen and common. The husband can be booked under civil procedure by wife for separation. It is for
the law makers to reform the penal law as per modern times and it doesn’t offend Article 14 or 15 of the
Constitution of India.

11
See, Recommendation of V.S. Committee Chaired by Justice V.S. Mallimath; “The Report of the Committee on
Criminal Justice Reforms”; 2002; Para 117
12
AIR 1954 SC 321
13
AIR 1985 SC 1618.
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In the case of V. Revathi v Union of India 14 the constitutional validity of S. 198(1) read with S. 198(2) of
Criminal Procedure Code, 1973 that it only allows the husband of the adulteress to prosecute the adulterer but
does not permit the wife of the adulterer to do so. The court said that the law does not allow either of the
spouses to prosecute each other under criminal law; a husband is not permitted because the wife is not treated
an offender in the eye of law. The wife is not permitted as Section 198(1) read with Section 198(2) does not
permit her to do so. Moreover there is “reverse discrimination” in favour of women and there is no
discrimination against women so far as she is not allowed to prosecute her own husband.
E. SECTION 497 A CRITIQUE

1. Section 497: A violation of Right to Equality

The Section 497 of the Indian Penal Code which deals with adultery is gender biased mainly on the grounds
that it does not allow the wife to prosecute the woman with whom her husband has adultered though it allows
the husband to prosecute the man who has adultery with his wife.
The law has considered woman to be a victim not as author of the crime. This very notion of victimhood lies
on “the psychological belief of considering oneself helpless, lacking power to overcome the situation and in a
need of some external agency to take them out of the situation.”15 The State enhances the state of
powerlessness and impotence which is central to the ideology of victimhood through this kind of legislation.
The contention of the Honourable Court is that the community punishes the “the 'outsider' who breaks into the
matrimonial home and occasions the violation of sanctity of the matrimonial tie by developing an illicit
relationship with one of the spouses subject to the rider that the erring 'man' alone can be punished and not the
erring woman. It does not arm the two spouses to hit each other with the weapon of criminal law.” However,
the Court misses out the point that the wife has no relief in Criminal law though the same provision is given to
the husband, and in a case where the woman is unmarried the woman cannot be prosecuted altogether. This
can be seen as a violation of natural justice which is fundamental to our Constitution. Article 14 read with
16(1) accords right to equality or an equal treatment consistent with the principles of natural justice.

2. Section 497 : A misuse of Article 15(3)

The framers of the Constitution believed that in the middle of the twentieth century no one would discriminate
on the ground of sex. However, it is clearly seen that the legislature is clearly making discrimination on the
grounds of sex on the pretext of giving “protective discrimination” to the women. The special treatment given
to the women under cl. 3 of Article 15 should be restricted to such cases which must be related to some
features or disability which are so peculiar that it differentiate women from men as a class. 16
The equality clauses in the Indian Constitution were framed on the basis of the American Constitution, so to
ignore the background is like not only violating the basic norms of comparative constitutional law but
violating the basic principles of interpretation of the constitution.17 The American Supreme Court has stated

14
AIR 1988 SC 835
15
See, Amartya Bag, Psychology and Politics of Victimhood: A Case Study of Dalits in India 4 (Term Paper, KIIT
University, 2009)
16
Durga Das Basu, Commentary on the Constitution of India at 1796 (Wadhwa 8th ed 2007); See also, Srinivasan v.
Padmasini, AIR 1957 Mad 622
17
State of U.P. v Deoman, AIR 1960 SC 1125
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that where both the sexes are on equal footing and discriminations to a particular sex as a class would be like
denying the equal protection clause as enshrined in the constitution; - “the very kind of arbitrary legislative
choice [is] forbidden by the Constitution.” 18 Even any kind favour may it be positive or negative to the women
for “administration convenience” would be repealed or struck down as discriminatory and unconstitutional.19
The Court held that they cannot see any restrictions that the clause should be used to measures which are
strictly beneficial in nature. 31 However, if we take a note of what was the intention of our Constitution framer
behind keeping such clause as Article 15(3), the scenario becomes clear. Prof. K.T. Shah believed that:

… this discriminations is in favour of particular classes of our society which, owing to an unfortunate legacy
of the past, suffer from disabilities or handicaps. Those, I think may require special treatment; and if they do
require it, they should be permitted special facilities for some time so that real equality of citizens may be
established. […] It is only intended to safeguard, protect or lead to their betterment in general; so that long-
range interests of the country may not suffer. (emphasis added) 20

The intention of the Constitution Drafters are clear that they included this clause to safeguard, protect or lead
to the betterment of women in general; they have not intended to keep it to give a licence for abetting or
committing an offence. Even the Supreme Court did not agree that the section tantamount to a licence to
commit the offence of which punishment has been prohibited.

The Court said that an argument like making both man and woman held liable for adultery is not permissible
as this is a policy of law. An example put forward by the Honorable Court that “why the offence of robbery
should be punishable with imprisonment for ten years under Section 392 of the penal Code but the offence of
adultery should be punishable with a sentence of five years only : 'Breaking a matrimonial home is not less
serious a crime than breaking open a house'.” However, if we put the example in this way and check if it make
discrimination that “Why the offence of robbery by a woman be not punished and the robbery by a man is
punished for 10 years”. Can this be called a gender equal law as such, if breaking the matrimonial home is
considered to be a more heinous crime than robbery, why a woman cannot be prosecuted for the offence? The
question of policy of law does not apply here as the law is discriminatory on the face without any valid,
satisfactory reason for such laws.

The underlying law at the present situation, considers only men as offender, as a class; the women are not
physically or socially such situated that they are incapable of committing the offence of adultery. Further, both
the sexes are on an equal footing in committing the offence of adultery, this kind of legislation are
discriminatory and arbitrarily protecting the women. The Section 497 of the Indian Penal Code is nothing but
violative of the equality clause under Indian Constitution.

18
Reed v Reed, (1971) 404 US 76, 77
19
Frontiero v Richardson, (1973) 411 US 677, 690
20
Constituent Assembly Debates. Vol VII at 655.

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F. CONCLUSION

In most of the foreign jurisdictions, adultery, apart from being a ground for divorce, has been perceived as a
criminal wrong against marriage. Similarly, in these jurisdictions, both the spouses are generally held
criminally responsible for their extramarital sexual intimacy.

However, the penal law of adultery in India is premised on the one-and-a-half century old caste-based
stratified "social setting" in the context of the traditional conservative property-oriented familial ideology and
sexual mores. It is also premised on a few outdated and moot assumptions of sexuality, sexual agency and
unequal mutual marital rights and obligations of the spouses. It, in ultimate analysis, unmistakably intends to
protect the rights of the husband and not of the wife 21. It is also bridled with deep-rooted obsolete assumptions
predominantly premised on gender discrimination and the wife's sexuality. Such a law in the 21st century
undoubtedly seems to be inconsistent with the modern notions of the status of women and the constitutional
spirit of gender equality. During the post-IPC period, a number of Acts have been enacted to relieve women
from the hitherto traditional system of seclusion and subordination and to assure them a status equal to men in
every walk of life.

The existing gender discriminatory penal law of adultery, against this backdrop, deserves a serious relook and
revision to the effect that a person, male or female, who, being married, has sexual intercourse with a female
or a male (as the case may be) not his or her spouses without the consent or connivance of such spouses be
made criminally responsible. Similarly, the spouse of the errant spouse be allowed not only to seek divorce
from the other life partner but also to initiate legal proceedings with a view to fixing criminal liability of the
"outsider" for wrecking the marriage. The latest proposals for reform of the Fifth and the Fourteenth Law
Commissions of India deserve serious and immediate attention of the legislature 22. Such changes are required
to translate the contemporary "social transformation" assuring equality to women and the constitutional spirit
of gender equality into a reality.

REFERENCES:-

1. Gangoli Geetanjali, Indian Feminisms : Law patriarchies and violence in India, Ashgate
Publishing Company USA, 1st Ed.2007. pg. 61.
2. Comment on the draft of first Law Commission Report. Gaur K.D., Indian Penal Code.
Eastern Law Publication, 2nd Ed. Pg. 388.

21
See generally, Ratna Kapur & Branda Cossman,Subversive Sites:Feminist Engagements with Law in India (Sage,
1996); Ursula Vagel: "Whose Property? The Double Standards of Adultery in the Nineteenth Century Law", in Carol
Smart (ed.): Regulating Womanhood:Historical Essays in Marriage, Motherhood and Sexuality (Routledge, London,
1992); and S.P. Sathe, Towards Gender Justice (RCWS, SNDT Women's University, Bombay, 1996). Also see
Alamgirv. State of Bihar, AIR 1959 SC 436 (439)
22
See K.I. Vibhute, " 'Rape' and the Indian Penal Code at the Crossroads of the New Millennium: Between Patriarchist
and Gender Neutralist Approach", Journal of the Indian Law Institute (January-March 2001
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3. Ratanlal & Dhirajlal, 2 Law of Crimes at 2710 (Bharat Law House 26th ed 2007) (C.K.
Thakker and M.C. Thakker, eds).
4. RatanLal and Dhiraj Lal’s Indian Penal Code (Enlarged Edition) 29th Edition, 2002, page
2305.
5. Varad Deore, A Provision Redundant in Penal Law in Changed Legal and Social Context,
available at http://www.legalserviceindia.com/article/l291-Adultery.html visited on
23.01.2011.
6. Legal and Constitutional History of India, 2001 Reprint, page 379.
7. See, Recommendation of V.S. Committee Chaired by Justice V.S. Mallimath; “The Report of
the Committee on Criminal Justice Reforms”; 2002; Para 117.
8. Amartya Bag, Psychology and Politics of Victimhood: A Case Study of Dalits in India 4
(Term Paper, KIIT University, 2009). th
9. Durga Das Basu, Commentary on the Constitution of India at 1796 (Wadhwa 8 ed 2007); See also,
Srinivasan v. Padmasini, AIR 1957 Mad 622.
10. Constituent Assembly Debates. Vol VII at 655.
11. Ratna Kapur & Branda Cossman,Subversive Sites:Feminist Engagements with Law in
India (Sage, 1996); Ursula Vagel: "Whose Property? The Double Standards of Adultery in the
Nineteenth Century Law", in Carol Smart (ed.): Regulating Womanhood:Historical Essays in
Marriage, Motherhood and Sexuality (Routledge, London, 1992); and S.P. Sathe, Towards
Gender Justice (RCWS, SNDT Women's University, Bombay, 1996).
12. K.I. Vibhute, " 'Rape' and the Indian Penal Code at the Crossroads of the New Millennium:
Between Patriarchist and Gender Neutralist Approach", Journal of the Indian Law
Institute (January-March 2001).
13. www.wikipedia.com

14. www.ssrn.com
15. www.legalserviceindia.com
16. www.manupatra.com
17. www.ebc.com

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