SHAFIN JAHAN V. K.M. ASHOKAN & OTHERS, (2018) 16 SCC 368:

DATE: 09/04/2018

COURT: Supreme Court of India

BENCH: Chief Justice Dipak Misra, Justice A.M. Khanwilkar, and Justice D.Y. Chandrachud

FACTS:

Hadiya (formerly Akhila Ashokan), a 24-year-old woman from Kerala, converted to Islam while pursuing her studies and later married Shafin Jahan. Her father, K.M. Ashokan, filed a habeas corpus petition in the Kerala High Court, alleging that her conversion and marriage were part of a larger scheme of coercion and radicalization. The High Court, doubting her ability to make independent decisions, annulled the marriage and placed her under her parents’ custody.

Challenging this decision, Shafin Jahan moved the Supreme Court, arguing that the High Court had unlawfully interfered in Hadiya’s right to choose her religion and spouse. The case gained national attention, with concerns raised over personal liberty, religious freedom, and state overreach in individual choices. The Supreme Court decided to examine whether the High Court’s ruling violated Hadiya’s fundamental rights and whether an adult woman’s choice of faith and marriage could be questioned by the judiciary.

ISSUES:

The key issues were whether the Kerala High Court could annul Hadiya’s marriage on grounds of coercion, if this violated her rights under Articles 21 and 25, and whether the state or judiciary could interfere in an adult’s choice of faith and spouse. The case also examined concerns over "love jihad" and individual autonomy in marriage and religion.

JUDGEMENT WITH REASONING:

The Supreme Court set aside the Kerala High Court’s annulment of Hadiya’s marriage, ruling that an adult has the fundamental right to choose their spouse and religion. The Court upheld her autonomy under Articles 21 and 25, emphasizing that neither the judiciary nor the state could interfere in personal choices unless there was evidence of coercion or illegality.

The Supreme Court reasoned that the right to choose a life partner is integral to personal liberty under Article 21 of the Constitution. It held that an adult's decision to marry and convert to another religion falls within their fundamental rights, and any interference by the courts or family members violates their autonomy. The Court emphasized that Hadiya, as an adult, was capable of making independent decisions, and there was no evidence of coercion or force in her conversion or marriage. It reaffirmed that societal norms or parental objections cannot override an individual’s right to make personal choices.

Additionally, the Court criticized the Kerala High Court for overstepping its jurisdiction by annulling the marriage, stating that such an action was legally untenable. It highlighted that habeas corpus petitions should only determine unlawful detention, not adjudicate on marital validity. By reinforcing constitutional protections, the Court asserted that personal freedoms, including marriage and religious conversion, cannot be curtailed based on unverified concerns of radicalization or external influence unless proven by due process.

ANALYSIS:

The Supreme Court’s judgment in Shafin Jahan v. K.M. Ashokan reinforced the primacy of individual autonomy in matters of marriage and religious conversion. By setting aside the Kerala High Court’s annulment of Hadiya’s marriage, the Court upheld her fundamental rights under Articles 21 and 25, affirming that personal liberty includes the right to choose one’s spouse and faith without state or judicial interference. The decision highlighted the importance of constitutional freedoms, making it clear that an adult’s personal choices cannot be negated by parental objections or societal pressures, especially when no evidence of coercion exists. This ruling reaffirmed that the judiciary must act within its constitutional limits and cannot overreach by adjudicating personal relationships under the guise of protective intervention.

Moreover, the Court’s reasoning underscored the limited scope of habeas corpus petitions, clarifying that they should only address unlawful detention and not extend to assessing the validity of a marriage. The judgment also countered broader narratives of "love jihad," stating that suspicions of religious indoctrination cannot override constitutional rights without substantiated proof. By emphasizing due process and the rule of law, the ruling strengthened safeguards against unwarranted state intervention in personal affairs. This case set a crucial precedent in protecting individual freedoms against judicial and parental overreach, reinforcing the foundational values of choice, dignity, and equality in India’s democratic framework.