Facts: The petitioner, an adoptive mother of two children, filed a Public Interest Litigation challenging the constitutional validity of Section 5(4) of the Maternity Benefit Act, 1961 (and subsequently the pari materia Section 60(4) of the Code on Social Security, 2020). The impugned provision restricted the entitlement of maternity benefits (12 weeks of leave) only to those adoptive mothers who legally adopt a child "below the age of three months". The petitioner contended that this age cap was arbitrary and discriminatory against mothers adopting older children.
Procedural Posture: The matter reached the Supreme Court of India as a Writ Petition filed under Article 32 of the Constitution of India, seeking a declaration that the specific age-restrictive clause in the maternity benefit law was unconstitutional.
Issue: Whether the three-month age limit for an adopted child to qualify their mother for maternity benefits is violative of Article 14 (Right to Equality) and Article 21 (Right to Life and Dignity) of the Constitution; and whether such a restriction bears a rational nexus with the object of the legislation.
Holding: Yes, the age limit is unconstitutional. The Court struck down the words "below the age of three months" from the provision, holding that all legal adoptive mothers are entitled to the benefit regardless of the child's age.
Reasoning: The Court reasoned that maternity benefits are rooted in "motherhood" and the "best interests of the child", not merely the biological process of childbirth. Adoptive mothers of older children, children with disabilities, or single mothers face equal, if not greater, challenges in bonding and integration, necessitating institutional support. The classification failed the "rational nexus" test under Article 14 because there is no reasonable distinction between mothers adopting children above or below three months regarding their caregiving needs. Furthermore, the Court found the provision "unworkable" and "illusory" because the statutory adoption process under the JJ Act and CARA Regulations typically takes longer than three months, making it practically impossible for most adoptive mothers to claim the benefit. The Court also emphasized that reproductive autonomy under Article 21 includes the right to form a family through adoption.