The constitutional validity of Section 9 of the Hindu Marriage Act, 1955 for the first time came for…

T. Sareetha (1983) was the early constitutional challenge that held section 9 unconstitutional. Harvinder Kaur subsequently disagreed, and Saroj Rani (1984) upheld section 9 and overruled Sareetha. The question concerns the historical challenge, not the later controlling conclusion in Saroj Rani.

Current law: For persons governed by the Uttarakhand UCC from 27 January 2025, restitution of conjugal rights is separately provided by section 21. The State Code’s enactment does not change which historical case first raised the challenge among the listed decisions.