The literal meaning of adultery is indulging in sexual relations with any person other than a spouse which can be done by men as well as women. Most countries have decriminalized it for being violative of the Right to Equality and some the nations like Malaysia and Saudi Arabia are yet to decriminalize it. India has the provision for adultery under Section 497 of the Indian Penal Code, 1860. It defines adultery in a narrow sense. It describes adultery as an act of men while indulging in a sexual relationship with a married woman without the consent of her husband and the man who is the third party was liable under the provision. Supreme Court of India declared this provision unconstitutional because of being violative of Articles 14 and 21 of the constitution in 2018 in the case of Joseph Shine v. Union of India. After this judgment, nobody is punished under this provision and adultery remains a ground of divorce only under the civil law and not a criminal offence anymore. Apart from the sexual relationship with a person other than a spouse, various other forms of activity indicate immoral behaviour on the part of a married partner indulging in such activities. In today’s world of social media, there are various platforms where people can talk and share their life virtually. These new form of interactions and relationships forming due to increased use of media has affected the personal relationships of a married couple. This issue is not prominently visible in society but it is gradually hampering the institution of marriage as well as family structure in our country. This paper will evaluate the impact of media and social media on the relationships in India and all over the world and how adultery is perceived in a wider sense.
Introduction
In
India Section 497 deals with adultery. It was made in 1860 when the position of
women was not very good in terms of social and educational background. Women
were suffering a lot of violence and discrimination already. Thus to proto from
any form of prosecution for the act of adultery, this law was made in such a
way that women don’t get prosecuted for adultery. The reasoning given for this
was that women are victims in the act of adultery and men are the ones who
always seduce women, so men shall be punished instead of women in all the cases
of adultery. The women were not given the power to complain against the husband
under the criminal procedure code because polygamy was prevalent at that time
and men were allowed to have more than one relationship. But the situation is
changed now. Polygamy is not allowed under marriage laws. There was a
requirement for change in the provision so that both men and women are
prevented from indulging in the act of adultery. But the Court has completely
decriminalized the provision of adultery in IPC instead of making it
gender-neutral. Marital infidelity means cheating, being unfaithful and
dishonest to the husband, and having an affair outside marriage which is
against the institution of marriage which is based on the principle of sexual
exclusivity. Sexual autonomy cannot prevail over public morality, decency, and
the institution of marriage which is very much required to maintain peace and
harmony in the society. Allowing such acts of infidelity will lead to chaos in
society. There are various factors involved that lead to such infidelity
activities and most of them are somehow connected to social media nowadays.
Marital infidelity is not limited to sexual intercourse only. In this paper,
marital infidelity will include emotional infidelity, sexual infidelity as well
as cyber infidelity which will cover most of the activities connected to social
media.
Adultery and social media
There
are different forms of adultery in the present times which have been defined
and explained by Schneider and Weiss which are as follows:
Emotional
infidelity- there can be instances where people may develop emotional feelings
toward each other. They may spend quality time with each other. They may start
telling lies to their partners due to lustful thoughts developed among them.
This does not involve any sexual relationship but still, it is an attack on the
institution of marriage.
Sexual
infidelity- this includes a sexual relationship with another person other than
the spouse. This is the only form that has been mentioned in the Indian Penal
Code and Civil Procedure Code.
Cyber
infidelity- in the present times of the internet and social media, infidelity,
and cheating happen with people are attracted physically and emotionally to
other people online. Many people are having extramarital affairs on online
platforms.
Some people consider some activities as infidelity behaviour and some people don’t consider it wrong at all.[1]
Social
Media is a platform where people can develop their social networking which
includes blogs, business networks like LinkedIn, social gaming like PubG, and
many others.[2]
Some data have shown the impact of the use of social media on divorced couples
and how they are linked directly or indirectly.[3] There are several factors
pointed out by various authors and experts responsible for the people seeking
out extramarital relationships. Some of the factors can be financial pressure,
lack of communication between the couple, lesser compatibility, lack of respect,
etc. a feeling of dissatisfaction and conflict in the marriage is the prime
cause of such relationships.[4] Due to this mental and
physical satisfaction, people lead to seeking sexual intimacy with the use of
social media. They want a level of excitement and affection from a partner
which they fail to achieve from their legitimate partner. With the ease of
access to several social media platforms, people have become addicted to such
activities and they feel it’s normal to do so to fulfill their desires.[5]
The activities like adultery and other forms of adultery are also a result of what the media portray and how it destroys the traditional values of a society.[6] Nowadays, there is a promotion of such adulterous relationships which can be seen in movies and advertisements. In the pop, culture marriage is portrayed in such a way that in a progressive society, it is right to have own choice for a partner. Some series depict such extramarital relationships as normal behaviour of an individual even after marriage.[7] These are leading to a belief among people that there is no importance in marriage and lifelong commitments. Sex has become a commodity and no more has remained a matter of committed intimacy. All such things are shown on television for entertainment and ratings but we the people forget that part and forget the line between entertainment and reality. Adultery is hurtful in any sense and it shall be prevented to take place even if it required interference of the legislature and judiciary as it is important to maintain the structure of society.
Social media has made infidelity very complex and easily accessible. A study by Russel has shown how social media plays a significant role in damaging the real-life relationships of people around the globe.[8] A study has shown that there are 13000 married couples found that more the time spent by their husbands on social media platforms like Facebook, the more their wives felt bad about their marriage and relationship with their husbands.[9] It has been agreed by various academicians and experts that there is a big threat going around contemporary marriages because of digital media access.[10] There is a survey conducted by the U.S. named Adultery in the Digital Age in the U.S. in which a survey of 1000 adults was done which d=showed that majority of them have been involved in physical contact like nightstands or cheating. It was also observed in the survey that 19% of the time, following an ex on social media platforms leads to cheating.[11]
If we are talking about the portrayal of adultery as a normal behaviour among people living in a society, we must take into account the instance of France which happened as a great shock to the world. France is a country that accepts infidelity as being a normal human choice and a normal relationship based on the choice of an individual. The President of France was in limelight for indulging in an adulterous extramarital affair with someone other than his wife.[12] In a survey held in 2013, it was found that only 47% of the population considers infidelity morally unacceptable and the rest of them consider it the right thing to do.[13] Even they have made a statement on media platforms that adultery is required to keep the marriage alive, and people should have the freedom to choose a partner, chose their life choices, reproduce children as many as possible, and enjoy life as they want.[14] They even have made a statement that there shall be National Adultery Act where people who have not been involved in adulterous relationships shall be subjected to punishment under their law.[15] Such an anti-social and immoral statement has been made by a French leader which depicts the society thinking and how much their thought process has been corrupted due to modern days’ lives and choices.
Another
survey conducted by National Opinion Research Centre reported that 20% of
American men and 10% of American women are not faithful in their marriages.[16] In the modern days,
Facebook has made it very much accessible to everyone to get indulged in any
form of immoral and infidelity relationships.[17] Facebook and other social
media platforms distract an individual from their intimate relationships and
make it harder for an individual to be completely present in the place where
they are supposed to be.[18]
Social
media is a platform that provides a place where people can harm their
relationships such as talking to alternative partners which creates conflict,
breakups, and divorce.[19] Many implications might
have resulted from such interaction on online platforms.[20] Studies have shown that
people are so busy scrolling up their Instagram feeds that they don’t get time
for talking to their partners.[21]
A
relationship between access to Facebook and divorce rates has been established
by a study which has shown that there is a 20% annual increase in the people
enrolling on Facebook and it has resulted in 2.18 to 4.32% increase in divorce
rates.[22] Social media apps and
dating apps like tinder have made it very easy for the dissatisfied couple to
look out for other partners and studies have shown that a whopping 30% of
Tinder users are married which depicts the damage to the Institution of
marriage.[23]
The
definition of cheating is different from the traditional definition of adultery
which has been adopted by the various legislature of several countries across
the globe. Cheating has been defined as an act that is dishonest or unfair to
gain an advantage, especially in a game or examination such as deceiving,
tricking, or sexually being unfaithful.[24]
Infidelity
appears to be appealing to people nowadays because of several reasons such as
it distorts the mind of people that everything is only digital which is just an
illusion and there is no existence of the real world.[25] There are also instances
when people give personal justification such as they are not satisfied with
their relationships.[26]
There
is also an extension of adultery known as micro-cheating which means a set of
behaviors that flirts with the line between faithfulness and unfaithfulness
defined by Maryland-based couple therapist Lindsey Hoskins.
In
India, Adultery provisions had some issues which were required to be dealt with
and some modifications were needed to go along with the growth and development
of the society but decriminalizing the whole provision is not a good idea
considering the trend which has been analyzed in this paper.[27] The term “with the
consent of husband’ denotes the patriarchy and women being the property of men
at that time.[28]
Time has changed and women are as equal as men in terms of education, finances,
and social development. Adultery was initially inserted in the law of torts as
“criminal conversion” at the time of British rule in the 19th
century.[29]
That law got abolished in 1857 when a whole new draft was made and an adultery
provision was added to protect the sanctity of marriage as an institution. It
was added on the ground that if it is not dealt with legislature and judiciary,
then people will take such matters into their own hands which might lead to
violence against women if they commit any similar acts. To protect women, this
provision was added. But in reality, it is not serving the objective as women
are the ones who are suffering under the provision.[30]
The
2nd Law Commission Report also recommended that certain amendments
are required in the provision to make it gender-neutral.[31] There is no requirement
of decriminalizing the whole provision as society is not ready for the same.
Conclusion and Suggestions
the
data and its findings show that the absence of any form of regulation for the
act of adultery, cheating, or infidelity is leading to chaos in society. People
are opting for choices that are wrong and immoral only because the state is
grating them absolute freedom of choice and privacy. Any liberty comes with a
certain duty not to harm any other individual while exercising their right. As
a result of such adulterous activities, the rate of divorce is increasing and
people are suffering from mental harassment. Other than the couple themselves,
there are other parties also which are suffering such as the parents of the
couple, their children, and family. It has a very dangerous and alarming impact
on children especially It affects their morality as well as their future
finances and dependency. Thus we cannot call marriage a private space that need
not be interfered with by the state but it shall interfere if something wrong
happens because it affects parties other than the couple themselves.
No
doubt that the provision shall treat both men and women at an equal pedestal
because both plays equal role in the marriage and both are equally responsible
for maintaining the sanctity of marriage. Exclusivity of sexual relationships
is one of the main factors in marriage and it should be respected by both the
parties.
Apart
from making the provision for adultery gender-neutral, the law shall also
evolve keeping in mind the technological development that has happened
enormously in the last few decades. With the rise in access to the internet,
people have very easy access to social media platforms and they are easily
indulging in talking and chatting with other people. They have various forms of
excuses and one of them is that it is not an adulterous act as they are not indulging
in sexual activity. The question is whether only sexual intercourse determines
if a person is respecting the sanctity of marriage or not. Even talking
intimately with people other than the spouse is an immoral act which shall also
be included within the definition of adultery. Thus the paper also suggests
that the definition of adultery shall be expanded.
Also, the movie and serials which are telecasted and depicts such infidelity and extramarital affairs positively must go through stricter censorship. TV and Movies have a very long-term psychological impact on the people and what is shown to them must be regulated to create a better society.
*The Author is a student of LL.M at KIIT School of Law, Bhubaneswar
Disclaimer: The views, thoughts, and opinions expressed in the text belong solely to the author and not to the Jurisedge Academy.
Readers may submit his/her blog for publication. Click Here or Scan the QR Code to submit your Manuscript
[1] Hertlein, K & Piercy, F.P.
Internet infidelity: A critical review of the literature. The Family
Journal, 14(4), 366-371 (2006)
[2] Obar, J.A., & Wildman, S.
Social media definition and the governance challenge: An introduction to the
special issue. Telecommunications policy, 39(9), 745-750 (2015)
[3] Winda Putri Diah Restya, Social
Media and Marital Infidelity, Psychology Faculty, University of
Muhammadiyah Aceh, Indonesia.
[19] Brandon T. McDaniel, do you have
anything to hide? Infidelity- related behaviours on social media sites and
marital satisfaction, Computers in Human Behaviour, 88-95 (2017).
[27]
Strasser and Mark, Sodomy,
Adultery, and Same-Sex Marriage: On Legal Analysis and Fundamental Interests,
1998 UCLA WOMEN’S LAW JOURNAL 8(2), 20, 29.
Saurabh Kumar
Share post:
Author- Akanksha Ranjan*
Abstract
The literal meaning of adultery is indulging in sexual relations with any person other than a spouse which can be done by men as well as women. Most countries have decriminalized it for being violative of the Right to Equality and some the nations like Malaysia and Saudi Arabia are yet to decriminalize it. India has the provision for adultery under Section 497 of the Indian Penal Code, 1860. It defines adultery in a narrow sense. It describes adultery as an act of men while indulging in a sexual relationship with a married woman without the consent of her husband and the man who is the third party was liable under the provision. Supreme Court of India declared this provision unconstitutional because of being violative of Articles 14 and 21 of the constitution in 2018 in the case of Joseph Shine v. Union of India. After this judgment, nobody is punished under this provision and adultery remains a ground of divorce only under the civil law and not a criminal offence anymore. Apart from the sexual relationship with a person other than a spouse, various other forms of activity indicate immoral behaviour on the part of a married partner indulging in such activities. In today’s world of social media, there are various platforms where people can talk and share their life virtually. These new form of interactions and relationships forming due to increased use of media has affected the personal relationships of a married couple. This issue is not prominently visible in society but it is gradually hampering the institution of marriage as well as family structure in our country. This paper will evaluate the impact of media and social media on the relationships in India and all over the world and how adultery is perceived in a wider sense.
Introduction
In India Section 497 deals with adultery. It was made in 1860 when the position of women was not very good in terms of social and educational background. Women were suffering a lot of violence and discrimination already. Thus to proto from any form of prosecution for the act of adultery, this law was made in such a way that women don’t get prosecuted for adultery. The reasoning given for this was that women are victims in the act of adultery and men are the ones who always seduce women, so men shall be punished instead of women in all the cases of adultery. The women were not given the power to complain against the husband under the criminal procedure code because polygamy was prevalent at that time and men were allowed to have more than one relationship. But the situation is changed now. Polygamy is not allowed under marriage laws. There was a requirement for change in the provision so that both men and women are prevented from indulging in the act of adultery. But the Court has completely decriminalized the provision of adultery in IPC instead of making it gender-neutral. Marital infidelity means cheating, being unfaithful and dishonest to the husband, and having an affair outside marriage which is against the institution of marriage which is based on the principle of sexual exclusivity. Sexual autonomy cannot prevail over public morality, decency, and the institution of marriage which is very much required to maintain peace and harmony in the society. Allowing such acts of infidelity will lead to chaos in society. There are various factors involved that lead to such infidelity activities and most of them are somehow connected to social media nowadays. Marital infidelity is not limited to sexual intercourse only. In this paper, marital infidelity will include emotional infidelity, sexual infidelity as well as cyber infidelity which will cover most of the activities connected to social media.
Adultery and social media
There are different forms of adultery in the present times which have been defined and explained by Schneider and Weiss which are as follows:
Emotional infidelity- there can be instances where people may develop emotional feelings toward each other. They may spend quality time with each other. They may start telling lies to their partners due to lustful thoughts developed among them. This does not involve any sexual relationship but still, it is an attack on the institution of marriage.
Sexual infidelity- this includes a sexual relationship with another person other than the spouse. This is the only form that has been mentioned in the Indian Penal Code and Civil Procedure Code.
Cyber infidelity- in the present times of the internet and social media, infidelity, and cheating happen with people are attracted physically and emotionally to other people online. Many people are having extramarital affairs on online platforms.
Some people consider some activities as infidelity behaviour and some people don’t consider it wrong at all.[1]
Social Media is a platform where people can develop their social networking which includes blogs, business networks like LinkedIn, social gaming like PubG, and many others.[2] Some data have shown the impact of the use of social media on divorced couples and how they are linked directly or indirectly.[3] There are several factors pointed out by various authors and experts responsible for the people seeking out extramarital relationships. Some of the factors can be financial pressure, lack of communication between the couple, lesser compatibility, lack of respect, etc. a feeling of dissatisfaction and conflict in the marriage is the prime cause of such relationships.[4] Due to this mental and physical satisfaction, people lead to seeking sexual intimacy with the use of social media. They want a level of excitement and affection from a partner which they fail to achieve from their legitimate partner. With the ease of access to several social media platforms, people have become addicted to such activities and they feel it’s normal to do so to fulfill their desires.[5]
The activities like adultery and other forms of adultery are also a result of what the media portray and how it destroys the traditional values of a society.[6] Nowadays, there is a promotion of such adulterous relationships which can be seen in movies and advertisements. In the pop, culture marriage is portrayed in such a way that in a progressive society, it is right to have own choice for a partner. Some series depict such extramarital relationships as normal behaviour of an individual even after marriage.[7] These are leading to a belief among people that there is no importance in marriage and lifelong commitments. Sex has become a commodity and no more has remained a matter of committed intimacy. All such things are shown on television for entertainment and ratings but we the people forget that part and forget the line between entertainment and reality. Adultery is hurtful in any sense and it shall be prevented to take place even if it required interference of the legislature and judiciary as it is important to maintain the structure of society.
Social media has made infidelity very complex and easily accessible. A study by Russel has shown how social media plays a significant role in damaging the real-life relationships of people around the globe.[8] A study has shown that there are 13000 married couples found that more the time spent by their husbands on social media platforms like Facebook, the more their wives felt bad about their marriage and relationship with their husbands.[9] It has been agreed by various academicians and experts that there is a big threat going around contemporary marriages because of digital media access.[10] There is a survey conducted by the U.S. named Adultery in the Digital Age in the U.S. in which a survey of 1000 adults was done which d=showed that majority of them have been involved in physical contact like nightstands or cheating. It was also observed in the survey that 19% of the time, following an ex on social media platforms leads to cheating.[11]
If we are talking about the portrayal of adultery as a normal behaviour among people living in a society, we must take into account the instance of France which happened as a great shock to the world. France is a country that accepts infidelity as being a normal human choice and a normal relationship based on the choice of an individual. The President of France was in limelight for indulging in an adulterous extramarital affair with someone other than his wife.[12] In a survey held in 2013, it was found that only 47% of the population considers infidelity morally unacceptable and the rest of them consider it the right thing to do.[13] Even they have made a statement on media platforms that adultery is required to keep the marriage alive, and people should have the freedom to choose a partner, chose their life choices, reproduce children as many as possible, and enjoy life as they want.[14] They even have made a statement that there shall be National Adultery Act where people who have not been involved in adulterous relationships shall be subjected to punishment under their law.[15] Such an anti-social and immoral statement has been made by a French leader which depicts the society thinking and how much their thought process has been corrupted due to modern days’ lives and choices.
Another survey conducted by National Opinion Research Centre reported that 20% of American men and 10% of American women are not faithful in their marriages.[16] In the modern days, Facebook has made it very much accessible to everyone to get indulged in any form of immoral and infidelity relationships.[17] Facebook and other social media platforms distract an individual from their intimate relationships and make it harder for an individual to be completely present in the place where they are supposed to be.[18]
Social media is a platform that provides a place where people can harm their relationships such as talking to alternative partners which creates conflict, breakups, and divorce.[19] Many implications might have resulted from such interaction on online platforms.[20] Studies have shown that people are so busy scrolling up their Instagram feeds that they don’t get time for talking to their partners.[21]
A relationship between access to Facebook and divorce rates has been established by a study which has shown that there is a 20% annual increase in the people enrolling on Facebook and it has resulted in 2.18 to 4.32% increase in divorce rates.[22] Social media apps and dating apps like tinder have made it very easy for the dissatisfied couple to look out for other partners and studies have shown that a whopping 30% of Tinder users are married which depicts the damage to the Institution of marriage.[23]
The definition of cheating is different from the traditional definition of adultery which has been adopted by the various legislature of several countries across the globe. Cheating has been defined as an act that is dishonest or unfair to gain an advantage, especially in a game or examination such as deceiving, tricking, or sexually being unfaithful.[24]
Infidelity appears to be appealing to people nowadays because of several reasons such as it distorts the mind of people that everything is only digital which is just an illusion and there is no existence of the real world.[25] There are also instances when people give personal justification such as they are not satisfied with their relationships.[26]
There is also an extension of adultery known as micro-cheating which means a set of behaviors that flirts with the line between faithfulness and unfaithfulness defined by Maryland-based couple therapist Lindsey Hoskins.
In India, Adultery provisions had some issues which were required to be dealt with and some modifications were needed to go along with the growth and development of the society but decriminalizing the whole provision is not a good idea considering the trend which has been analyzed in this paper.[27] The term “with the consent of husband’ denotes the patriarchy and women being the property of men at that time.[28] Time has changed and women are as equal as men in terms of education, finances, and social development. Adultery was initially inserted in the law of torts as “criminal conversion” at the time of British rule in the 19th century.[29] That law got abolished in 1857 when a whole new draft was made and an adultery provision was added to protect the sanctity of marriage as an institution. It was added on the ground that if it is not dealt with legislature and judiciary, then people will take such matters into their own hands which might lead to violence against women if they commit any similar acts. To protect women, this provision was added. But in reality, it is not serving the objective as women are the ones who are suffering under the provision.[30]
The 2nd Law Commission Report also recommended that certain amendments are required in the provision to make it gender-neutral.[31] There is no requirement of decriminalizing the whole provision as society is not ready for the same.
Conclusion and Suggestions
the data and its findings show that the absence of any form of regulation for the act of adultery, cheating, or infidelity is leading to chaos in society. People are opting for choices that are wrong and immoral only because the state is grating them absolute freedom of choice and privacy. Any liberty comes with a certain duty not to harm any other individual while exercising their right. As a result of such adulterous activities, the rate of divorce is increasing and people are suffering from mental harassment. Other than the couple themselves, there are other parties also which are suffering such as the parents of the couple, their children, and family. It has a very dangerous and alarming impact on children especially It affects their morality as well as their future finances and dependency. Thus we cannot call marriage a private space that need not be interfered with by the state but it shall interfere if something wrong happens because it affects parties other than the couple themselves.
No doubt that the provision shall treat both men and women at an equal pedestal because both plays equal role in the marriage and both are equally responsible for maintaining the sanctity of marriage. Exclusivity of sexual relationships is one of the main factors in marriage and it should be respected by both the parties.
Apart from making the provision for adultery gender-neutral, the law shall also evolve keeping in mind the technological development that has happened enormously in the last few decades. With the rise in access to the internet, people have very easy access to social media platforms and they are easily indulging in talking and chatting with other people. They have various forms of excuses and one of them is that it is not an adulterous act as they are not indulging in sexual activity. The question is whether only sexual intercourse determines if a person is respecting the sanctity of marriage or not. Even talking intimately with people other than the spouse is an immoral act which shall also be included within the definition of adultery. Thus the paper also suggests that the definition of adultery shall be expanded.
Also, the movie and serials which are telecasted and depicts such infidelity and extramarital affairs positively must go through stricter censorship. TV and Movies have a very long-term psychological impact on the people and what is shown to them must be regulated to create a better society.
*The Author is a student of LL.M at KIIT School of Law, Bhubaneswar
Disclaimer: The views, thoughts, and opinions expressed in the text belong solely to the author and not to the Jurisedge Academy.
Readers may submit his/her blog for publication. Click Here or Scan the QR Code to submit your Manuscript
[1] Hertlein, K & Piercy, F.P. Internet infidelity: A critical review of the literature. The Family Journal, 14(4), 366-371 (2006)
[2] Obar, J.A., & Wildman, S. Social media definition and the governance challenge: An introduction to the special issue. Telecommunications policy, 39(9), 745-750 (2015)
[3] Winda Putri Diah Restya, Social Media and Marital Infidelity, Psychology Faculty, University of Muhammadiyah Aceh, Indonesia.
[4] Ibid.
[5] Sairun, Medos Cetus Perceraian Ratusan Pasangan di Bengkulu Selatan, (2018)
[6] Angela Kays Burden, Media portrayal of adultery challenges traditional values, The Desert News (2009).
[7] Ibid.
[8] Bisma Parvez, Social media has normalized infidelity and it’s not okay, The Tempest, (2019)
[9] Jeffrey Dew, Does Media use Matter for Marital Quality? Institute for Family Studies, (2015).
[10] Alysse EIHage, Is Digital Media Complicating How We Define Infidelity? Institute for Family Studies, (2017).
[11] Ibid.
[12] Richard Wike, French more accepting of infidelity than people in other countries, Pew Research Center, (2014).
[13] Ibid.
[14] Mark Miller, France Makes Adultery Mandatory, Huffpost, (2017).
[15] Ibid.
[16] Ibid.
[17] Adam Bulger, Social Media Infidelity is a very modern problem, Fatherly. (2021)
[18] Ibid.
[19] Brandon T. McDaniel, do you have anything to hide? Infidelity- related behaviours on social media sites and marital satisfaction, Computers in Human Behaviour, 88-95 (2017).
[20] Ibid.
[21] Negative effects of social media on marriage and relationships, ETIMES, (2021)
[22] Laura Sell, Digital Divorce: A Guide for Social Media & Digital Communications, McKinley Irvin.
[23] Ibid.
[24] Laken Holte, Social media and online infidelity in the 21st century, Medium.com, (2019)
[25] Ibid.
[26] Ibid.
[27] Strasser and Mark, Sodomy, Adultery, and Same-Sex Marriage: On Legal Analysis and Fundamental Interests, 1998 UCLA WOMEN’S LAW JOURNAL 8(2), 20, 29.
[28] Sec. 497, Indian Penal Code, 1860.
[29] Married Women’s Property Act 1882, 45 & 46 Vict., c. 30
[30] K.I. Vibute, Adultery in IPC- need for a gender equality perspective, 6SCC J-16 (2001)
[31] Second Report on IPC, 1847 p. 134-135.
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