Section 9 of the Hindu Marriage Act, 1955 was held to be 'intra-vires' the constitution by the Supreme…

In "Saroj Rani v. Sudarshan Kumar" (1984) the Supreme Court held section 9 of the Hindu Marriage Act (restitution of conjugal rights) valid and not violative of Articles 14 and 21, explaining that it serves to preserve the marriage and that a decree is enforced only by attachment of property. It does not authorise forcing cohabitation. The other cases listed did not decide this question.