By Abstract
Marital sexual abuse is understood as non-consensual sexual intercourse within marriage by a husband with his wife. It remains a deeply contested issue in India due to its complex legal and social inferences. The existing literature indicates significant variability in reporting the instances of non-consensual sexual relations within marriage, ranging from approximately 2% to 56% across studies, largely due to underreporting, definitional inconsistencies, and sociocultural stigma. Keeping in view the gravity of this sensitive issue, this paper argues that the challenges surrounding marital sexual abuse in India are better addressed within the broader legal and policy framework of domestic violence and sexual abuse, rather than through the creation of a distinct criminal offence as marital rape. This paper focuses on strengthening implementation of existing laws, improving reporting mechanisms and enhancing awareness through education in urban and village areas may offer more effective and culturally responsive solutions as needed rather criminalising the marital rape. This paper offers a balanced, evidence-based approach that protects women’s dignity and mental well-being while considering the socio-legal realities of Indian society.
Introduction
Marriage in India as per all practised religions has traditionally been regarded as a sacrosanct social institution which is associated with mutual rights, duties and various expectations. It is considered a holy relationship of not only a couple but for families. It is beginning of a new life for both a wife and husband. Marriage institution gets break down when issues relating to consent and autonomy for consumption of marriage come across. In other words, Marital rape, is also defined as non-consensual sexual intercourse by a spouse, occupies a contentious space in Indian legal discourse. Under Exception 2 to section 63 of Bhartiya Nayaya Sanhita 2023 corresponding section section 375 of the Indian Penal Code (IPC), sexual intercourse by a man with his wife (if she is above the age of 18 years) is not classified as rape, reflecting longstanding legal and societal assumptions about implied consent within marriage.
Despite this legal position, empirical research and national surveys indicate that non-consensual sexual experiences within marriage do occur. Data from NFHS-5 (2019–21) says that approximately 6.9% of ever-married women aged 18–49 have experienced sexual violence by their husbands[1]. In addition, social stigma, economic dependence, fear of familial disruption, and lack of awareness often prevent women from disclosing such experiences, leading to a substantial gap between reported and actual cases[2]. It is also not denied that the mental health consequences of spousal sexual abuse are increasingly being reported in many cases including depression, anxiety disorders, post-traumatic stress disorder (PTSD), sexual transmission disease, unnecessary pregnancies, and suicidal ideation. Marital sexual abuse rarely occurs in isolation, it is frequently accompanied by other forms of intimate partner violence, including physical and emotional abuse, thereby intensifying its psychological impact[3].
Consequently, the question of criminalizing marital rape as a distinct offence has generated significant debate. Critics argue that such criminalization may face practical challenges in evidentiary standards, potential misuse, and unintended consequences for the institution of marriage. An alternative perspective suggests that the harms arising from non-consensual sexual acts within marriage can be effectively addressed under existing legal frameworks with few amendments, such as the Protection of Women from Domestic Violence Act, 2005, which recognizes sexual abuse as a form of domestic violence[4]. But now it should address marital sexual abuse from husband. In this context, the present paper seeks to examine few questions like why marital sexual abuse by husband is required to be acknowledged in India emphasizing the amendments to Domestic Violence Act 2005. Secondly keeping marital sexual abuse term instead of Marital rape recognised globally, is somehow balancing the institution like marriage and it’s sanctity which is needed for a country like India.
Judiciary and Marital Rape
The Justice J.S. Verma Committee Report (2013) is one of the most significant documents in this context. The Committee clearly recommended that the marital rape exception under Section 375 IPC should be removed, stating that marriage should not be used as a defence to sexual violence and that consent remains central even within marriage. It emphasized that sexual autonomy and bodily integrity are fundamental constitutional values, and thus, non-consensual sexual acts within marriage should be treated as rape. However, despite this strong recommendation, the legislature did not fully adopt this reform. Similarly, the Law Commission of India in its 172nd Report (2000) had earlier examined sexual offences law and suggested a broader understanding of sexual violence, though it did not explicitly recommend full criminalization of marital rape at that stage. Later discussions in legal policy circles, including recommendations in various Parliamentary Standing Committee deliberations, have acknowledged the need to improve protection against sexual and domestic violence within marriage, even if through indirect legal mechanisms. Having these reports, the Indian judiciary has played a significant yet important role in addressing the issue of marital rape, reflecting a continuing tension between statutory provisions and constitutional values. A landmark intervention came in Independent Thought v. Union of India[5], where the Supreme Court read down Exception 2 to Section 375 of the Indian Penal Code and held that sexual intercourse with a wife below 18 years of age (earlier 15 years) would amount to rape, thereby partially limiting the scope of the marital rape exception.
In RIT Foundation v. Union of India, W.P.(C) 284/2015 & connected matters (Delhi High Court, Judgment dated 11 May 2022), the Union Government, through its affidavit, opposed the criminalization of marital rape by emphasizing that marriage in India is a distinct and socially significant institution that requires a different legal treatment from other relationships. It was argued that Exception 2 to Section 375 of the Indian Penal Code (now sec. 63 Exception 2 of BNS 2023) reflects a conscious legislative decision to balance the protection of women with the preservation of marital stability. Therefore, any change in this position must be undertaken by the legislature rather than the judiciary. While acknowledging that sexual abuse within marriage may occur, the Government contended that it should not be categorized as “rape” in the criminal law framework. Such classification could have far-reaching social consequences on the society. The affidavit further highlighted that adequate remedies already exist under laws such as the Protection of Women from Domestic Violence Act, 2005, which recognizes sexual abuse, along with provisions like section 498A IPC and other matrimonial remedies. Concerns were also raised regarding the potential misuse of criminal law, particularly the possibility of false allegations in matrimonial disputes, as well as serious evidentiary challenges in proving absence of consent within the private sphere of marriage.
Additionally, the Government pointed to the diverse socio-cultural context of India could be disturbed with this criminalization. Instead, it advocated for a more harmonised approach focusing on awareness, social reform, counselling, and strengthening existing civil and protective mechanisms. But this affidavit was not accepted and the court[6] delivered a split verdict. Justice Rajiv Shakdher held the exception unconstitutional for violating women’s rights to dignity and equality, while Justice C. Hari Shankar upheld its validity, emphasizing legislative intent and the institution of marriage. The split verdict has led to the matter being considered by the Supreme Court. The matter is pending before the Supreme Court. No final judgment has been delivered yet.
In furtherance, the criminalisation of marital rape raises complex evidentiary and privacy concerns. Particularly such offences occur within the intimate and private sphere of marriage where independent evidence is often scarce. Non-consensual sex and its establishment in court through evidence raises many questions as, the courts may have to examine deeply personal communications, past patterns of intimacy, Non-consensual relationship and the conduct of both spouses, thereby potentially intruding into the private domain or privacy of marital life. Now it touches the core principal laid down in K.S. Puttaswamy v. Union of India[7], where the Supreme Court recognized the fundamental right to privacy, including bodily autonomy and decisional freedom is a part of Art. 21 of the constitution. On the other hand, as discussed above, consent to reproductivity is also significant. In Nimeshbhai Bharatbhai Desai v. State of Gujarat[8], the Gujarat High Court observed (obiter) that the marital rape exception[9] is unconstitutional, as it is inconsistent with the principles of equality and dignity. Further in Hrishikesh Sahoo v. State of Karnataka[10], the Karnataka High Court permitted prosecution of a husband for rape, observing that a man is a man first and a husband later, and that the absence of consent cannot be ignored within marriage. However, the Supreme Court subsequently stayed the operation of this judgment. In contrast, in Gorakhnath Sharma v. State of Chhattisgarh[11], the court held that, due to the statutory exception, a husband cannot be prosecuted for raping his wife. Keeping in view of above points, while marital rape is not recognized as an offence, such acts may still constitute cruelty or sexual abuse under other legal provisions. In addition, the tension between marital privacy and individual autonomy is not new. In T. Sareetha v. T. Venkata Subbaiah[12], the Andhra Pradesh High Court struck down the remedy of restitution of conjugal rights as unconstitutional, emphasizing bodily autonomy. However, in Smt. Saroj Rani v. Sudarshan Kumar Chadha, (1984) 4 SCC 90, the Supreme Court upheld the provision, reflecting a contrasting judicial perspective.
Recent developments, including the ongoing challenge to the marital rape exception before the Supreme Court (as tracked by the Supreme Court Observer), indicate that the issue remains unsettled. While the judiciary has increasingly recognized the importance of consent, dignity, and autonomy within marriage, it has thus far stopped short of fully criminalizing marital rape, instead leaving the matter to legislative determination while expanding protection under existing legal frameworks.
Available Remedies for Marital Sexual Abuse by husband in India
Even though marital rape is not criminalized for adult wives, the Indian law provides various civil and criminal remedies to address sexual abuse within marriage. These remedies focus on protection, relief, and accountability, though they do not treat such acts as rape.
- Relevant Provisions under Bharatiya Nyaya Sanhita, 2023 (BNS)
Under the Bharatiya Nyaya Sanhita, 2023, the law adopts a balanced approach by addressing harm within marriage without categorizing it as rape and not leaving women without remedies.
- As per Section 63 – Rape (with Exception 2), sexual intercourse by a man with his own wife (if she is above the age of 18 years) is not considered rape. However, where the offence of rape is otherwise made out, it is punishable with rigorous imprisonment for a term not less than ten years[13], which may extend to life imprisonment, along with fine. This reflects a conscious legislative policy to treat marriage as a distinct social institution and to avoid criminalizing marital relations under the same framework as non-marital offences.
- Section 85 – Cruelty by Husband or Relatives imposes criminal liability where a woman is subjected to cruelty, which has been interpreted broadly to include physical, mental, and even sexual abuse or coercive conduct, and is punishable with imprisonment up to three years along with fine. Thus, if a husband engages in forced, degrading, or harmful sexual behaviour that causes injury or severe mental trauma, it can be addressed under cruelty provisions, ensuring accountability without labeling it as rape.
- Section 67 – Sexual Offences provides for punishment in cases involving non-consensual or aggravated sexual acts, with imprisonment ranging from two years to seven years along with fine, depending on the nature and gravity of the offence. Although its scope within marriage is limited, it still provides an additional layer of legal protection in appropriate cases.
The above-mentioned framework indicates that Indian criminal law already provides mechanisms to deal with abuse within marriage, focusing on protection, punishment for cruelty, and maintaining social balance. Rather than introducing a separate offence of marital rape, strengthening these existing provisions, along with effective implementation and awareness, may offer a more practical and socially sensitive solution to address marital sexual abuse.
Divorce Laws
Under the Hindu Marriage Act, 1956 – Section 13(1), cruelty is a well-established ground for divorce. Judicial interpretation has significantly expanded its scope to include sexual abuse within marriage. In Samar Ghosh v. Jaya Ghosh[14], the Supreme Court laid down illustrative guidelines for determining mental cruelty, emphasizing that any conduct causing deep mental pain, agony, or humiliation so as to make marital life insupportable would amount to cruelty. This interpretation is wide enough to include non-consensual and degrading sexual conduct. Similarly, in K. Srinivas Rao v. D.A. Deepa[15], the Court reiterated that cruelty includes behaviour that makes it unsafe or unreasonable for a spouse to continue cohabitation. Indian courts, in several matrimonial disputes, have recognized that forced sexual intercourse, perverse or unnatural acts, and conduct that violates a woman’s dignity can constitute both physical and mental cruelty, thereby justifying divorce. In V. Bhagat v. D. Bhagat[16], , the Court further clarified that mental cruelty must be assessed in light of the social status, background, and circumstances of the parties, thereby allowing a contextual understanding of abusive marital conduct, including sexual mistreatment.
Similarly, under Muslim law, marriage (nikah) is regarded as a contract, implying mutual rights and obligations. A Muslim woman can seek dissolution under the Dissolution of Muslim Marriages Act, 1939, particularly Section 2(viii), on the ground of cruelty[17]. In Shayara Bano v. Union of India[18], while dealing with triple talaq, the Supreme Court emphasized that practices causing harm and injustice to women are not protected, reinforcing the importance of dignity within marriage. Additionally, in Itwari v. Asghari[19], the court recognized that cruelty under Muslim law includes conduct that makes the wife’s life miserable, which can extend to inhumane and coercive marital behaviour, including sexual mistreatment.
Domestic Violence Act, 2005 (DV Act)
The Protection of Women from Domestic Violence Act, 2005 (DV Act) provides the most comprehensive legal remedy for marital sexual abuse in India, even though such acts are not criminalized as rape. The Act adopts a broad and victim-centric approach by recognizing, under Section 3, that domestic violence includes not only physical and emotional abuse but also sexual abuse, defined as any conduct of a sexual nature that abuses, humiliates, degrades, or violates the dignity of a woman. This explicitly brings forced sexual relations and coercive acts within marriage under legal scrutiny. Further, Section 17 guarantees a woman’s right to reside in the shared household, ensuring that she cannot be evicted or forced to leave due to abuse. The Act empowers Magistrates under Section 18 to issue protection orders, restraining the husband from committing further acts of violence or contacting the aggrieved woman. Under Section 19, residence orders may be granted, including directions to the husband to remove himself from the shared household or to provide alternative accommodation. Additionally, Section 20 provides for monetary relief, covering medical expenses, loss of earnings, and maintenance, thereby ensuring financial support to the victim. The Act also recognizes the psychological impact of abuse, allowing courts under Section 22 to grant compensation and damages for mental torture and emotional distress. In cases involving children, Section 21 enables the grant of temporary custody orders to protect their welfare. The procedural framework under Section 12 allows the aggrieved woman to directly approach the Magistrate, while Protection Officers (Section 8) and Service Providers (Section 10) assist in accessing legal, medical, and shelter support. Thus, the DV Act provides a wide range of immediate and practical remedies, focusing on protection, residence, financial security, and dignity of the victim, though its nature remains largely civil and protective rather than punitive. On the one hand, arguments in favour of criminalization emphasize the importance of dignity, consent, and equality within marriage. It is argued that recognizing marital rape as an offence would affirm that a woman’s bodily autonomy continues even after marriage, and that consent remains essential in all circumstances. Criminalization would also provide legal recognition to the physical and psychological harm caused by non-consensual acts and may act as a deterrent against such behaviour. It is further argued that such a step would align Indian law with evolving international standards on gender justice and women’s rights.
However, concerns raised against criminalization also reflected in government positions highlight several practical and social challenges. Marriage is a unique social institution in India, and treating marital relations under the same criminal framework as non-marital rape may have serious social consequences. It has also been pointed out that adequate remedies already exist under laws such as domestic violence and cruelty provisions, making separate criminalization debatable. Another major concern is the possibility of misuse of criminal law in matrimonial disputes, which could lead to false allegations. Additionally, evidentiary difficulties arise because such acts occur in private spaces, making it challenging to prove absence of consent beyond reasonable doubt.
A very major argument is raised against criminalizing marital rape is the possibility of false or exaggerated allegations, particularly in the context of matrimonial disputes like misuse of dowry and divorce cases. In Arnesh Kumar v. State of Bihar[20], the Supreme Court observed that provisions relating to matrimonial offences, especially those dealing with cruelty, had sometimes been used as a tool for harassment, leading the Court to issue guidelines against automatic arrests. Similarly, in Rajesh Sharma v. State of Uttar Pradesh[21], the Court noted instances of misuse of dowry-related laws and attempted to introduce safeguards, though later modified. These judicial observations are often cited to argue that introducing marital rape as a criminal offence may lead to similar challenges, particularly given the private nature of marital relationships and difficulty in verifying allegations. The evidentiary burden in such cases would be complex, and there is a concern that the law could be invoked in situations of marital discord, separation, or ongoing litigation. Thus, criminalising marital rape may have broader social consequences on marital stability in India. It is suggested that bringing intimate marital relations under criminal law could increase marital conflict, distrust between spouses, and consequently lead to a rise in divorce or separation cases. Further, the legal intervention may alter relationship dynamics and contribute to greater marital breakdown, particularly in economically and socially dependent households. However, claims that it would directly lead to an increase in prostitution or extra-marital affairs are speculative and not supported by empirical evidence, and therefore remain theoretical concerns rather than established outcomes.
Impact of criminalisation on Same Sex marriages
Marital rape has been criminalized in around 77 countries globally, reflecting a growing international recognition of consent within marriage as per the studies of UN Women[22]. These include countries such as the United States, United Kingdom, Scotland, Canada, Australia, South Africa, Germany, France, Sweden, Norway, Spain, Brazil, Nepal, Bhutan, Philippines, New Zealand, and Ireland, among others, indicating a gradual shift toward recognizing that marriage does not negate the requirement of consent.
In jurisdictions such as the United States, United Kingdom, and Scotland, rape laws have evolved into consent-based and largely gender-neutral frameworks. In the United States, marital rape is criminalized across all states. and statutory provisions such as California Penal Code §261 define rape primarily on the basis of lack of consent, without providing any marital exception. Similarly, in the United Kingdom, the Sexual Offences Act 2003 establishes a comprehensive framework where Section 1 defines rape based on absence of consent, while Sections 2–4 extend to other forms of sexual offences in a gender-neutral manner; the marital rape exception was abolished. In Scotland, the Sexual Offences (Scotland) Act 2009 goes further by providing a fully gender-neutral definition of rape under Section 1 and defining consent as “free agreement” under Section 12, thereby covering marital, non-marital, and same-sex relationships comprehensively. These legal systems also recognize male rape and same-sex sexual violence, ensuring broader and more inclusive protection.
In India, the landmark decision in Navtej Singh Johar v. Union of India[23], is particularly significant. The Supreme Court decriminalised consensual same-sex relations by reading down Section 377 IPC, holding that criminalisation of such relations violated fundamental rights under Articles 14, 15, 19, and 21 of the Constitution. The Court emphasized that sexual orientation is an essential attribute of privacy, dignity, and individual autonomy, and that consensual relations between adults cannot be criminalized. This judgment marked a shift towards recognizing consent as central in intimate relationships, irrespective of gender.
However, despite this progressive recognition of autonomy and consent, Indian criminal law under the Bharatiya Nyaya Sanhita, 2023 still remains gender-specific and does not extend similar protection within marriage or to same-sex contexts. Thus, while Navtej Johar opened the door for discussions on same-sex relationships and individual choice, the absence of gender-neutral rape laws continues to create legal gaps, especially in the context of marital relationships and potential recognition of same-sex marriage. In contrast, India’s Bharatiya Nyaya Sanhita (BNS), 2023 adopts a restricted and gender-specific framework. Under Section 63, rape is defined with a male perpetrator and female victim, and Exception 2 to Section 63 excludes marital rape in cases involving adult wives. This results in significant legal limitations, particularly in the context of evolving discussions around same-sex relationships. The current framework does not recognize male rape under rape provisions, and same-sex partners are not fully covered within the definition of rape. Consequently, if same-sex marriage is recognized in India in the future, notable legal gaps may arise in addressing sexual violence within such relationships.
Thus, while a substantial number of countries have moved towards criminalization of marital rape and adoption of gender-neutral, consent-based frameworks, India continues to follow a more limited and relationship-specific approach. This contrast highlights potential challenges in extending legal protection to all individuals equally, particularly in the context of changing social and legal realities.
Conclusion and suggestions
Marriage, apart from other responsibilities, is often presumed to include sexual relations between husband and wife. However, the term “rape” can be perceived as harsh when used in the context of marriage, particularly in a country like India. It is understood that, at times, sexual relations may occur without explicit consent. Yet, an important question arises: if such acts occur repeatedly and consent is consistently absent, does this not amount to a violation of a partner’s legal rights, particularly their bodily autonomy and dignity, even within the framework of marriage?
At the same time, issues of maturity and capacity must also be considered. In some cases, one partner may not be psychologically or emotionally mature despite being of legal age, while the other may be more developed. This raises concerns regarding the capacity of individuals to fully understand and engage in marital obligations, including sexual relations, which are closely linked to personal, psychological, and physical readiness and may evolve over time. Furthermore, in India, rape laws are not gender-neutral. Criminalizing marital rape solely in relation to husbands may raise complex concerns, including those related to misuse and the mental health impact on the accused male partner. Therefore, any legal reform in this area requires a nuanced and balanced approach that takes into account rights, protections, and practical challenges. In light of the concerns surrounding the criminalization of marital rape—particularly the potential for misuse, evidentiary difficulties, and its impact on the institution of marriage—a balanced and practical approach may be adopted by strengthening existing legal mechanisms rather than introducing it as a separate offence.
- Firstly, there should be a strengthening of existing legal provisions, such as Section 85 of the Bharatiya Nyaya Sanhita (cruelty) and the Protection of Women from Domestic Violence Act, 2005, by explicitly clarifying that marital sexual abuse by husband falls within their ambit. The punishment may also be enhanced beyond the existing term of three years to ensure greater deterrence and accountability. There is a rationale for locating such protection within these existing provisions, as it allows the law to address the harm without disturbing the core structure of criminal law. This approach would ensure accountability while maintaining legal consistency and practical enforceability.
- Secondly, there is a need to develop clear judicial guidelines for dealing with allegations of marital sexual abuse by husband. Drawing from cases like Arnesh Kumar v. State of Bihar, safeguards such as preliminary inquiry, mediation in appropriate cases, and protection against arbitrary arrest can help prevent misuse while still addressing genuine grievances.
- Thirdly, emphasis should be placed on civil remedies and victim support mechanisms. Strengthening the proper implementation of the DV Act, providing counselling services, legal aid, and shelter homes, and ensuring speedy disposal of cases can offer immediate and practical relief to affected women. It is suggested that sexual abuse as already provided in DV Act, it can be amended to marital sexual abuse by husband where punishment should also be included.
- Fourthly, awareness and sensitization programs should be promoted to educate individuals about consent, capacity to consent, dignity, and respectful marital relations from both the partners thereby addressing the issue at a societal level rather than only through criminal law and one sided.
- Fifthly, referring the title of this paper to beyond criminalisation, and considering concerns related to reproductive health, unplanned pregnancies, and sexually transmitted diseases (STDs), policies should also incorporate clear and accessible hospital treatment guidelines in marriage related sexual abuse in DV Act. These should ensure timely medical care, including emergency treatment, access to contraception, safe abortion services in accordance with law, testing and treatment for STDs, and proper documentation of injuries in a sensitive and confidential manner. Alongside this, there should be a strong focus on the financial empowerment of women, including access to maintenance, employment opportunities, and social security schemes, so that victims are not compelled to remain in abusive marriages.
- Lastly, a gradual and consultative approach to law reform may be adopted, involving stakeholders such as legal experts, women’s groups, and community leaders, to ensure that any future changes are socially workable and legally balanced.
Thus, instead of immediate criminalization, a combination of legal strengthening, procedural safeguards, and social reform may be provides for a more effective and sustainable solution to address marital sexual abuse by husband in India.
* Associate Professor, Department of Law, Maharaja Agrasen Institute of Management Studies, GGSIPU
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[2] Ministry of Women and Child Development, Government of India. (2005).
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Available at: https://link.springer.com/article/10.1007/s00737-009-0065-6 (visited on 2/03/2026)
[4] Ministry of Women and Child Development, Government of India. (2005).
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Available at: https://wcd.nic.in/sites/default/files/ProtectionofWomenfromDomesticViolenceAct2005.pdf
[5] (2017) 10 SCC 800
[6] 2022 SCC OnLine Del 1404
[7] (2017) 10 SCC 1
[8] 2018 SCC OnLine Guj 732
[9] Sec 375 Exception No. 2
[10] 2022 SCC OnLine Kar 1242
[11] 2021 SCC OnLine Chh 493
[12] AIR 1983 AP 356
[13] Sec. 64 of BNS 2023
[14] (2007) 4 SCC 511
[15] (2013) 5 SCC 226
[16] (1994) 1 SCC 337
[17] 2(viii) of the Dissolution of Muslim Marriages Act, 1939, a Muslim woman can seek divorce on grounds of cruelty, which includes habitual assault, making life miserable, forced immorality, disposal of property, or preventing her from practicing her religion
[18](2017) 9 SCC 1
[19] AIR 1960 All 684
[20] (2014) 8 SCC 273
[21] (2017) 8 SCC 746,
[22] Facts and Figures: Ending Violence against Women and Girls. Available at Facts and Figures | UN Women – Asia-Pacific. Visited on 10/04/2026.
[23] (2018) 10 SCC 1
Written by *Dr. Nisha Dhanraj Dewani
