S.Vijay Krishnan vs The State Of Tamil Nadu on 5 August, 2026

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    Madras High Court

    S.Vijay Krishnan vs The State Of Tamil Nadu on 5 August, 2026

                                                                           CRL RC No. 1301 of 2026
    
    
                                      IN THE HIGH COURT OF JUDICATURE AT MADRAS
                                               RESERVED ON : 14-07-2026
                                              PRONOUNCED ON : 05.08.2026
                                                       CORAM
                                       THE HON'BLE MR.JUSTICE SHAMIM AHMED
                                                CRL RC No. 1301 of 2026
    
                    1. Mr.Vijay Krishnan. S (48/M)
                       S/o V.K.Selvaraj,
                       R/ at Elroi Apartment F1 No.3,
                       Kundalakesi 2nd Street, Srinivasa Nagar,
                       Perungalathur, Kancheepuram,
                       Tamil Nadu-600063.
    
                    2. Mrs.S.Jayapriya, (47/F)
                       W/o Vijay Krishnan. S,
                       R/at No.5A S2 Flats, Tholkapiyar 1st Street,
                       Srinivasa Nagar, New Perungalathur,
                       Kancheepuram, Tamil Nadu-600063.
    
                    3. Mrs.Kowsalya. G, (28/F)
                       W/o R.Spurgen,
                       R/at Plot No.10, Thayumanaval Flat 2,
                       Sambandar Street, Bharathi Nagar,
                       Near Kannadasan Nagar Main Road,
                       Aadhanur, Madambakkam,
                       Kancheepuram, Tamilnadu-603202.
                                                                                ..Petitioner(s)
                                                           Vs
                    1. The State of Tamil Nadu
                       Represented by its Health Secretary,
                       Secretariat, Fort St.George,
                       Chennai-600009.
    
                    2. The Director of Medical and Rural Health
                       Services
                       359, Anna Salai,
                       Chokkalingam Nagar,
                       Teynampet,
                       Chennai-600006.
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                    3. The Appropriate Authority/ Joint Director of
                       Health Services
                       Chengalpattu District,
                       28, SH58, Mahalakshmi Nagar,
                       Tamil Nadu 603101.
    
                         (R1, R2 and R3 impleaded as per the order of
                         this court dated 02.07.2026 in
                         Crl.MP.No.11409 of 2026 in Crl.RC.No.1301
                         of 2026)
                                                                                   ..Respondent(s)
    
                    Prayer: This Criminal Revision Case has been filed under Section 438 r/w. 442
                    of BNSS, 2023, praying to call for the records relating to Crl.MP.No.1011 of
                    2026 on the file of the learned Judicial Magistrate No.1, Tambaram, Chennai,
                    set aside the order dated 22.04.2026 dismissing the petition as not maintainable.
    
    
                                  For Petitioner(s):      Ms.A.Roshma Banu
    
                                  For Respondent(s):      Mr.M.M.I.Khaleel, Government Advocate
                                                          (Crl.Side)
    
                                                         ORDER
    

    This Criminal Revision Case has been filed under Sections 438 and 442

    of the Bharatiya Nagarik Suraksha Sanhita, 2023, seeking to set aside the order

    SPONSORED

    dated 22.04.2026 passed in Crl.M.P. No.1011 of 2026 by the learned Judicial

    Magistrate No.I, Tambaram, Chennai, dismissing the petition filed under

    Section 4(iii)(a)(ii) of the Surrogacy (Regulation) Act, 2021, as not

    maintainable and has also prayed before this Court to further direct the learned

    Magistrate to issue the parentage and custody of the child to be born through

    surrogacy.

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    2.The facts leading to the filing of the present Criminal Revision Case are

    briefly stated hereunder:

    (a)The marriage between the Petitioners 1 and 2 was solemnized on

    21.08.2006 at P.K. Mahal Thirumana Mandabam, Mylapore, Chennai, in

    accordance with Hindu rites and customs. Despite several years of married life,

    the Petitioners 1 and 2 were unable to conceive a child and therefore they

    decided to obtain a child through surrogacy.

    (b)The Petitioners 1 and 2 approached the competent authorities under the

    Act and, upon scrutiny of their medical records and other relevant documents,

    the Appropriate Authority issued Eligibility Certificate No.11/2706/A2/2024-1

    dated 07.03.2026 certifying their eligibility to undergo surrogacy, valid from

    01.03.2026 to 28.02.2027.

    (c)The 3rd Petitioner, who had voluntarily agreed to act as the surrogate

    mother for the child, also applied before the competent authority and was issued

    Eligibility Certificate No.05/500/A2/2026 dated 07.03.2026 by the District

    Medical Board, Chengalpattu District, certifying her eligibility to act as the

    surrogate mother, valid from 07.03.2026 to 06.03.2027.

    (d)The Petitioners had also obtained health insurance coverage in favour

    of the surrogate mother for a period of thirty-six months commencing from

    10.04.2026 to 09.04.2029, in compliance with the provisions of the Surrogacy
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    (Regulation) Act, 2021.

    (e)After complying with all the statutory requirements prescribed under

    the Act, the Petitioners jointly filed Crl.M.P.No.1011 of 2026 before the learned

    Judicial Magistrate No.I, Tambaram, Chennai, under Section 4(iii)(a)(ii) of the

    Surrogacy (Regulation) Act, 2021 seeking an order concerning the parentage

    and custody of the child to be born through surrogacy to the petitioners 1 and 2

    and for consequential rights and for a direction to the 3 rd petitioner to relinquish

    all her rights over the child to be born through the surrogacy as per the Act

    2021.

    (f)It is the specific case of the Petitioners that the petition was e-filed on

    21.04.2026 together with the petition, supporting affidavit, proof affidavit and

    all the relevant documents was presented before the learned Judicial Magistrate

    on 22.04.2026. However, on the very same day, without issuing notice, without

    affording the Petitioners an opportunity of hearing and without considering the

    materials placed on record, the learned Judicial Magistrate dismissed the

    petition as not maintainable.

    3.The learned Judicial Magistrate, by the impugned order dated

    22.04.2026, dismissed the Petition as not maintainable holding that the Court

    exercising jurisdiction under the Bharatiya Nagarik Suraksha Sanhita, 2023, is

    concerned only with criminal proceedings arising out of commission of offences

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    and that the relief sought by the Petitioners was civil in nature. The learned

    Magistrate further held that no offence under Sections 38 to 41 of the Surrogacy

    (Regulation) Act, 2021 had been alleged and no complaint as contemplated

    under Section 44 of the Surrogacy (Regulation) Act, 2021, had been lodged. On

    the said reasoning, the learned Magistrate concluded that the Petition was not

    maintainable. Aggrieved by the same, the present Revision has been filed.

    4.Heard Mr.D.Vasantha Kumar, learned counsel appearing for the

    Petitioners and Mr.M.M.I.Khaleel, learned Government Advocate (Crl.Side)

    appearing for the respondents and also carefully considered the submissions

    made and perused the entire materials available on record.

    5.The short issue that arises for consideration in this Criminal Revision

    Case is whether the learned Judicial Magistrate was justified in refusing to

    entertain the Petition filed under Section 4(iii)(a)(ii) of the Surrogacy

    (Regulation) Act, 2021 on the ground that the Court lacked jurisdiction.

    6.Learned counsel for the petitioner submits that with regard to the

    legislative intent behind the introduction of the Surrogacy (Regulation) Bill and

    the statements and objectives of the Act, the Indian framework seeks to —

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    (a) Protect surrogate mothers from exploitation,

    (b) Prevent commercialisation of reproduction,

    (c) Ensure ethical reproductive practices,

    (d) Safeguard the welfare of children born through surrogacy,

    (e) Regulate fertility clinics and ART procedures and

    (f) Prevent trafficking and reproductive tourism.

    7. For the sake of convenience, the Petitioners 1 and 2 and the 3 rd

    Petitioner herein after referred to as the Intending Couple and Surrogate Mother,

    respectively.

    8.Before dealing with the correctness of the impugned order, it would be

    necessary to understand the scheme of surrogacy legislation in its totality and

    the intent of the Surrogacy (Regulation) Act, 2021.

    9.Definition of Surrogacy:- The Supreme Court in its judgment

    in Baby Manji Yamada vs Union of India [(2008) (13) SCC (518)], has

    provided the definition of surrogacy:-

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    “9. The word “surrogate”, from Latin “subrogare”,
    means “appointed to act in the place of”. The intended
    parent(s) is the individual or couple who intends to rear
    the child after its birth.”

    10.Statutory Definition:- Under Section 2(1)(zd) of the Surrogacy

    (Regulation) Act, 2021:

    “Surrogacy” means a practice whereby one woman bears
    and gives birth to a child for an intending couple or
    intending woman with the intention of handing over the
    child after birth to such intending couple or intending
    woman.

    Parties Involved

    ▪ Surrogate Mother – the woman carrying the pregnancy.

    ▪ Intending Couple – legally eligible couple seeking a child
    through surrogacy.

    ▪ Intending Woman – an eligible woman permitted under
    law to avail surrogacy.

    ▪ Surrogacy Clinic – medical facility conducting the procedure.

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    11.Origin and Evolution of Surrogacy:-

    The Honourable Supreme Court, in its judgment in Vijaya Kumari vs
    Union of India(2026-2-SCC-96:2025 INSC 1209), had explained the
    development of surrogacy in India, wherein “The first move towards
    prohibition of commercial surrogacy came with the 228 th Report of the
    Law Commission of India in 2009, which flagged the problem of India
    becoming a “reproductive tourism destination” and wombs being “on
    rent”.(Para 22) To prevent these forms of misuse of the procedure,
    the Parliament enacted the Surrogacy (Regulation) Act, 2021 to
    prohibit commercial surrogacy and permit only altruistic surrogacy
    under regulated conditions.

    12.Types of Surrogacy:- The case of Baby Manji Yamada vs Union of

    India [(2008) 13 SCC 518] (Para 10 to 13), also explained the different

    types of surrogacies, which are:

    (i) Traditional Surrogacy

    ● The surrogate mother’s own egg is used.

                          ●    She is genetically related to the child.
                          ●    Conception usually occurs through artificial insemination.
                          ●    Surrogate is the biological mother.
                          ●    Not permitted under India's present legal framework.
    
                              (ii) Gestational Surrogacy
    
                          ●    The embryo is created through IVF and transferred to the surrogate.
                          ●    The surrogate has no genetic connection with the child.
    
    
    
    
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                          ●    Legally recognised under Indian law.
                          ●    Minimizes parental disputes.
                              (iii) Commercial Surrogacy
    
                          ●    Surrogate receives monetary compensation beyond medical
                                      expenses and insurance.
                          ●    Surrogacy performed for profit, often involves contractual payments.
                          ●    Expressly prohibited under the Surrogacy (Regulation) Act, 2021.
    
                              (iv) Altruistic Surrogacy
    
                          ●    No monetary consideration except:
                                 ●     Medical expenses,
                                 ●     Insurance coverage,
                                 ●     Prescribed ancillary expenses.
                          ●    Undertaken out of compassion or familial support.
                          ●    No commercial gain.
                          ●    This is the only form of surrogacy permitted under Indian law.
    
    
    
    
    

    13.Objectives of Surrogacy Regulation:- With regard to the legislative

    intent behind the introduction of the Surrogacy (Regulation) Bill and the

    statements and objectives of the Act, the Indian framework seeks to:

    A) Protect surrogate mothers from exploitation.
    B) Prevent commercialisation of reproduction.
    C) Ensure ethical reproductive practices.
    D) Safeguard the welfare of children born through surrogacy.
    E) Regulate fertility clinics and ART procedures.
    F) Prevent trafficking and reproductive tourism.

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    14.Legal Framework in India:-Primary Legislation

    Surrogacy (Regulation) Act, 2021
    Assisted Reproductive Technology (Regulation) Act, 2021

    Important Rules

    ■ Surrogacy (Regulation) Rules, 2022.

    ■ Assisted Reproductive Technology (Regulation) Rules, 2022.

    Regulatory Authorities

    ■ National Surrogacy Board.

    ■ State Surrogacy Boards.

    ■ Appropriate Authorities.

    ■ District Medical Boards.

    15.STATUTORY SCHEME UNDER THE SURROGACY ACT, 2021:-

    The Surrogacy Act creates a structured statutory mechanism

    involving multiple authorities and the procedure laid down is as follows:-

    Section 4(ii)::- No surrogacy procedure shall be conducted except for

    the following purposes:-

                        ▪     Couple of Indian Origin – S. 4(ii)(a)
                          ▪    Couple shall obtain a certificate of recommendation from the
    

    National Assisted Reproductive Technology and Surrogacy Board

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    S.4(ii)(a)
    ▪ Only for altruistic surrogacy purposes – S. 4(ii)(b)
    ▪ Not for commercial purposes – S. 4(ii)(c)
    ▪ Not for producing children for sale, prostitution or any other
    form of exploitation – S. 4(ii)(d).

    16.SURROGACY PROCEDURE – S. 4(iii):-

    No surrogacy or surrogacy procedure shall be conducted unless the

    Director or in-charge of the surrogacy clinic or person qualified to

    do so are satisfied on the following conditions:-

    a) Certificate of Essentiality – S. 4(iii)(a)

    b) Eligibility certificate of surrogate mother – S. 4(iii)(b)

    c) Eligibility certificate of intending couple – S. 4(iii)(c)

    a)Certificate of essentiality, S. 4(iii)(a) – by appropriate authority (S.

    35 – Appointment by the Central/State Government i.e District

    Medical and Rural Health Services) after fulfilment of the following

    conditions:-

    ● Certificate of Medical Indication by the District Medical Board
    ● Order concerning Parentage and custody of the child from the
    Magistrate
    ● Insurance coverage for the surrogate mother from an Insurance agency

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    i) Certificate of – Considering Pregnancy not possible
    medical indication –
    S.4(iii)(a)(I) Rule 14 of The Surrogacy (Regulation)
    By the District Rules, 2022:

    Medical Board – Absence or missing or abnormal
    uterus or if uterus is surgically
    removed due to medical conditions

    – Intended parent or woman has
    repeatedly failed to conceive after
    multiple In vitro fertilization

    – Multiple pregnancy losses

    – Any illness that makes it impossible
    for woman to carry pregnancy or
    making pregnancy life threatening

    ii) An Order which shall be the birth affidavit of
    concerning the surrogate child born
    Parentage and
    custody of the child

    S. 4(iii)(a)(II)
    By the Magistrate
    of the first class or
    above

    iii) Insurance Rule 5of The Surrogacy (Regulation) Rules,
    Coverage – S. 4(iii) 2022:

                                 (a)(III)                   - Insurance in favour of surrogate
                                                               mother for 36 months for a sufficient
                                 From an Insurance             amount
                                 Company                    - Intending couple/woman shall sign an
                                                               affidavit to be sworn before
                                                               Metropolitan Magistrate or Judicial
                                                               Magistrate of 1st class or Executive
                                                               Magistrate or Notary Public
    
    
    
    
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    a) Essentiality certificate of Surrogate Mother:- S. 4(iii)(b):-

    by appropriate authority after fulfilment of the following

    conditions:-

    Eligibility Certificate of I) Married woman
    Surrogate Mother – S. 4(iii)(b) II) Having child of her own
    III) Between ages of 25 to 35
    years on the day of implantation
    By Appropriate Authority
    IV) Willing woman
    V) Not provide her own gametes
    VI) Not act as surrogate
    mother more than once
    VII) Certificate of medical
    and psychological fitness
    Other conditions as per Form 2:

     Relinquish all rights over
    the child to the intending
    couple

    b) Eligibility Certificate of Intending Couple – S. 4(iii)(c):-by

    Appropriate Authority after fulfilling the following conditions:-

                              Eligibility Certificate of                a) Married
                              Intending Couple – S. 4(iii)(c)           b) Between 23 to 50 years –
                                                                        female
                              By Appropriate Authority               Between 26 to 55 years –
                                                                     male On the date of
                                                                     certification
                                                                     c) Not had any surviving
                                                                     child
                                                                     (biological/adoption/surrogac
                                                                     y earlier)
                                                                  But can have a child – mentally or
                                                                  physically challenged
    
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    17.Prohibition to abandon child, S. 7:- The intending couple or

    intending woman shall not abandon the child, born out of a

    surrogacy procedure, regardless of the circumstances and the

    reasons.

    18.Rights of surrogate child, S.8:- The child born out of

    surrogacy procedure, shall be deemed to be a biological child of the

    intending couple, or intending woman and the said child shall be

    entitled to all the rights and privileges available to a natural child

    under any law.

    19.The main grounds, on which the courts below had

    dismissed the prayer of the Petitioners, seeking an order of parentage

    and custody of the child to be born through surrogacy, are that

    (1) The Petition fled under Section 4(iii) (a) (ii) of the Surrogacy Act 2021

    is not maintainable.

    (2) The Court exercising jurisdiction under the BNSS 2023 is concerned

    only with criminal proceedings out of commission of offence and that

    the relief sought by the petitioner was civil in nature.

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    20. Now the question that arise in this case for consideration of this Court

    are as follows:-

    (1) Whether the learned Magistrate can dismissed the petition filed by the

    petitioner under Section 4(iii)(a)(ii) of the Act as not maintainable?

    (2) Whether the finding recorded by Trial Court that the Court exercising

    Jurisdiction under BNSS 2023 is concerned only with criminal proceedings of

    commission of an offence and the relief sought by petitioner was civil in nature?

    (3) Whether the High Court can pass an order of parentage by itself to avoid

    further delay? Or Whether the High Court can pass an order to remand the matter

    back to the Magistrate for passing fresh orders for issuance of birth affidavit and

    custody of the child to be born through surrogacy?

    21.Having thus outlined the statutory architecture, we shall now proceed to

    consider the facts of the present case and analyze the reasoning of the impugned

    order in light of these legislative provisions and answer the above question as

    framed.

    22.The Surrogacy (Regulation) Act, 2021 has been enacted with the

    avowed object of regulating the practice of surrogacy, prohibiting

    commercial surrogacy, permitting only ethical altruistic surrogacy and

    safeguarding the rights of the intending couple, the surrogate mother and

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    the child born through surrogacy. The Act is a self-contained legislation

    providing a complete statutory mechanism governing every stage of the

    surrogacy process.

    23.The Act creates various statutory authorities and assigns distinct

    responsibilities to each of them. The District Medical Board is entrusted with

    the responsibility of issuing the certificate of medical indication wherever the

    intending couple seeks to avail surrogacy owing to medical necessity. The

    Appropriate Authority constituted under the Act is empowered to verify

    compliance with the statutory requirements and issue the certificate of

    essentiality and eligibility. Apart from these authorities, Parliament has

    consciously vested one further responsibility upon the Court of the

    Magistrate of the First Class or above, namely, to pass an order concerning

    the parentage and custody of the child to be born through surrogacy.

    24.Section 4 of the Surrogacy (Regulation) Act, 2021 lays down the

    conditions subject to which surrogacy can be undertaken. Clause (iii)(a)(ii)

    of the Surrogacy (Regulation) Act, 2021 thereof specifically provides that an

    order concerning the parentage and custody of the child to be born through

    surrogacy shall be passed by the Court of the Magistrate of the First Class

    or above on an application made by the intending couple/intending woman
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    and the surrogate mother. Thus, the parentage order is not an incidental

    requirement. It is one of the statutory preconditions mandated by

    Parliament before the surrogacy process can lawfully proceed.

    25.A careful reading of the statutory scheme leaves no manner of doubt

    that the jurisdiction exercised by the Magistrate under Section 4(iii)(a)(ii) of the

    Surrogacy (Regulation) Act, 2021 does not emanate from the general provisions

    of the Bharatiya Nagarik Suraksha Sanhita, 2023. The source of jurisdiction is the

    Surrogacy (Regulation) Act, 2021 itself. Therefore, while entertaining an

    application under Section 4(iii)(a)(ii) of the Surrogacy (Regulation) Act, 2021,

    the Magistrate is not exercising ordinary criminal jurisdiction relating to

    investigation, inquiry or trial of offences. The Magistrate discharges a special

    statutory function entrusted under a special enactment.

    26.It is a settled principle of statutory interpretation that whenever a special

    enactment confers jurisdiction upon a Judicial Magistrate to perform a specified

    statutory function, the Magistrate is bound to exercise such jurisdiction in

    accordance with the provisions of the special statute. The jurisdiction cannot be

    declined merely because the subject matter may otherwise possess civil

    consequences. The conferment of jurisdiction is a matter of legislative policy, and

    once Parliament has designated the Court of the Magistrate of the First Class or
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    above as the competent authority to pass an order concerning parentage and

    custody, the Magistrate cannot refuse to exercise such jurisdiction by importing

    concepts applicable to ordinary criminal proceedings.

    27.The reasoning adopted by the learned Judicial Magistrate that the

    Petition was not maintainable since the relief sought was civil in nature overlooks

    the legislative scheme of the Surrogacy (Regulation) Act, 2021. It is trite that the

    character of the relief sought cannot determine the jurisdiction of the Court when

    the statute itself expressly designates the forum competent to entertain the

    application. The source of the Magistrate’s jurisdiction is not the Bharatiya

    Nagarik Suraksha Sanhita, 2023, but the special jurisdiction expressly conferred

    under Section 4(iii)(a)(ii) of the Surrogacy (Regulation) Act, 2021.

    28.The Surrogacy (Regulation) Act, 2021 is a complete code governing the

    field of altruistic surrogacy. The Act contemplates a sequential process involving

    different statutory authorities, each entrusted with distinct responsibilities. The

    Appropriate Authority is required to examine the eligibility and essentiality of the

    intending couple and the surrogate mother and issue the necessary certificates

    upon being satisfied that the statutory requirements are fulfilled. Likewise, the

    District Medical Board performs the functions specifically entrusted to it under

    the Act. After completion of these statutory requirements, the intending couple
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    and the surrogate mother are required to approach the Court of the Magistrate of

    the First Class or above for obtaining an order concerning the parentage and

    custody of the child to be born through surrogacy. The Magistrate thus occupies a

    distinct place within the statutory framework and performs a specific function

    assigned by Parliament.

    29.This Court had occasion to examine the scope of the Magistrate’s

    jurisdiction under the Surrogacy (Regulation) Act, 2021 in Nandhini Devi @

    Srinandhini Devi Saravanan and others v. State of Tamil Nadu and others

    (Crl.R.C. No.950 of 2026, dated 25.06.2026). After an elaborate consideration

    of the statutory scheme, this Court held that the Act creates a comprehensive

    mechanism assigning separate duties to the different statutory authorities and that

    the Magistrate has been entrusted with the specific statutory responsibility of

    passing an order concerning the parentage and custody of the child under Section

    4(iii)(a)(ii) of the Surrogacy (Regulation) Act, 2021. The Court further held that

    while exercising such jurisdiction, the Magistrate cannot travel beyond the scope

    of the statute nor refuse to discharge the function specifically entrusted by

    Parliament.

    30.In the said decision, this Court observed that the Magistrate exercises

    only the jurisdiction specifically conferred by the Surrogacy (Regulation) Act,
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    2021, and is not expected to assume any appellate or supervisory role over the

    decisions taken by the Appropriate Authority or the District Medical Board.

    Equally, the Magistrate cannot enlarge or curtail the scope of the enquiry by

    importing conditions not contemplated under the Act. The enquiry before the

    Magistrate is confined to satisfying himself regarding compliance with the

    statutory requirements and thereafter passing an appropriate order concerning the

    parentage and custody of the child.

    31.The above principles squarely apply to the facts of the present case. The

    learned Judicial Magistrate has proceeded on the erroneous premise that unless an

    offence under Sections 38 to 41 of the Surrogacy (Regulation) Act, 2021 is

    alleged or a complaint under Section 44 is filed, the Court lacks jurisdiction to

    entertain the Petition. Such a construction finds no support whatsoever from the

    language employed in Section 4(iii)(a)(ii) of the Surrogacy (Regulation) Act,

    2021.

    32.Section 4(iii)(a)(ii) of the Surrogacy (Regulation) Act, 2021 does not

    stipulate, either expressly or by necessary implication, that the jurisdiction of the

    Magistrate is dependent upon the existence of criminal proceedings. The

    provision merely requires an application by the intending couple or intending

    woman and the surrogate mother seeking an order concerning the parentage and
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    custody of the child to be born through surrogacy. Once such an application is

    presented, the Magistrate is obliged to examine the same in accordance with the

    statutory framework.

    33.The penal provisions contained in Sections 38 to 41 of the Surrogacy

    (Regulation) Act, 2021 deal with offences such as commercial surrogacy,

    exploitation of the surrogate mother and other prohibited acts. Section 44 of the

    Act merely prescribes the manner in which cognizance of those offences may be

    taken. Those provisions belong to an entirely different chapter of the Act dealing

    with penal consequences. They neither control nor qualify the jurisdiction

    conferred upon the Magistrate under Section 4(iii)(a)(ii) of the Surrogacy

    (Regulation) Act, 2021. Reading such a condition into Section 4 of the Act would

    amount to rewriting the statute, which is impermissible in law.

    34.The finding of the learned Magistrate that the Petition was civil in

    nature is equally unsustainable. The legislature, with full knowledge of the nature

    of the relief, has consciously chosen the Court of the Magistrate of the First Class

    or above as the authority competent to pass the order concerning parentage and

    custody. When the statute itself specifies the forum, it is not open to the Court to

    decline jurisdiction by characterising the proceedings as civil in nature. The

    legislative mandate has to be given full effect.

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    35.This Court had earlier, in Crl.O.P. No.29464 of 2025 dated

    14.11.2025, categorically held that the order contemplated under Section 4(iii)(a)

    (ii) of the Surrogacy (Regulation) Act, 2021, has necessarily to be passed by the

    jurisdictional Judicial Magistrate and that the Magistrate cannot refuse to

    entertain such an application on the ground of lack of jurisdiction. The relevant

    observation reads thus:

    “One of the requirements is that the Court of Magistrate of the First
    Class or above has to pass an order concerning the parentage and
    custody of the child to be born through surrogacy on an application
    made by the intending couple or the intending woman and the
    surrogate mother. The Act is very clear that the order has to be passed
    by the Court of Magistrate of the First Class or above…”

    36.The ratio laid down in the above decision has been reaffirmed in the

    case of Nandhini Devi (supra). The legal position is therefore no longer res

    integra. Once Parliament has conferred jurisdiction upon the Court of the

    Magistrate of the First Class or above to pass an order concerning parentage and

    custody under Section 4(iii)(a)(ii) of the Surrogacy (Regulation) Act, 2021, the

    Magistrate cannot refuse to entertain the application on the ground that no

    criminal complaint is pending or that the relief sought has civil consequences.

    Such a course would amount to declining to exercise a jurisdiction expressly

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    vested by the statute.

    37.From the discussion made above, this Court has no hesitation in holding

    that the learned Judicial Magistrate has completely misdirected himself on the

    scope and ambit of Section 4(iii)(a)(ii) of the Surrogacy (Regulation) Act, 2021.

    The impugned order proceeds on the erroneous assumption that unless there

    exists an allegation constituting an offence under the Act, the Court functioning

    as a Criminal Court cannot entertain an application under the Surrogacy

    (Regulation) Act, 2021. Such an approach is contrary to the express language

    employed by Parliament and defeats the very object sought to be achieved under

    the Act.

    38.The Surrogacy (Regulation) Act, 2021 is a special enactment. It not

    only regulates the entire process of altruistic surrogacy but also specifies the

    authorities competent to discharge various statutory functions. The jurisdiction

    conferred upon the Court of the Magistrate of the First Class or above under

    Section 4(iii)(a)(ii) of the Surrogacy (Regulation) Act, 2021, is a special statutory

    jurisdiction, independent of the jurisdiction exercised under the Bharatiya

    Nagarik Suraksha Sanhita, 2023. The Magistrate, while dealing with an

    application under the said provision, does not function as a Criminal Court trying

    an offence but as a statutory authority designated under the Act to pass an order
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    concerning the parentage and custody of the child to be born through surrogacy.

    39.It is a well-settled principle that where a statute expressly confers

    jurisdiction upon a Court, such jurisdiction cannot be declined on grounds dehors

    the statute. Equally well settled is the principle that a Court cannot add conditions

    to a statutory provision which the legislature has consciously omitted. Section

    4(iii)(a)(ii) of the Surrogacy (Regulation) Act, 2021, merely requires an

    application by the intending couple/intending woman and the surrogate mother.

    The provision nowhere stipulates that the existence of criminal proceedings,

    registration of a criminal case or filing of a complaint under Section 44 of the Act

    is a condition precedent for entertaining such an application. The reasoning

    adopted by the learned Magistrate therefore amounts to reading into the statute

    words which are not found therein.

    40.The statutory function entrusted to the Magistrate is also limited in its

    scope. The Magistrate is required to satisfy himself that the statutory

    requirements prescribed under the Surrogacy (Regulation) Act, 2021, have been

    complied with and thereafter pass an order concerning the parentage and custody

    of the child. The Magistrate is not expected to sit in appeal over the satisfaction

    recorded by the Appropriate Authority or the District Medical Board nor can he

    enlarge the scope of enquiry beyond what is contemplated under the Surrogacy
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    (Regulation) Act, 2021. By declining to entertain the Petition itself on an

    erroneous assumption of lack of jurisdiction, the learned Magistrate has failed to

    discharge the statutory obligation cast upon the Court.

    41.This Court is therefore of the considered view that the learned Judicial

    Magistrate has failed to exercise the jurisdiction expressly vested in the Court by

    Section 4(iii)(a)(ii) of the Surrogacy (Regulation) Act, 2021. Such failure to

    exercise jurisdiction constitutes a jurisdictional error warranting interference by

    this Court in exercise of its revisional jurisdiction under Sections 438 and 442 of

    the Bharatiya Nagarik Suraksha Sanhita, 2023, and the impugned order is liable

    to set aside and reversed. The question 1 and 2 are accordingly answered.

    42.Proceedings under Section 4(iii)(a)(ii) of the Surrogacy (Regulation)

    Act, 2021, are beneficial, facilitative and child-centric proceedings and not

    adversarial litigation. The welfare of the child is the paramount consideration

    when determining custody. The jurisdiction exercised by the Magistrate is

    protective in nature and intended to safeguard, (a) the welfare of the child, (b) the

    rights of the intending parents; and (c) the autonomy of the surrogate mother.

    43.The Right to life under Article 21 provides the right and personal liberty

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    to reproduce to live with satisfaction and dignity. The Child so brought to this

    world by surrogacy will provide a better life in all aspects to the parents

    (intending couple) and that will enable the intending couple to live with utmost

    satisfaction. When such facets of Article 21 are involved, the Hon’ble Courts

    have to give a liberal interpretation to the beneficial legislation instead of

    depriving a couple their fundamental right under Article 21 on mere

    technicalities.

    44.In this case, due to the rejection of the application by the impugned

    order, major injury was caused to the Petitioners and the Petitioners herein plead

    to invoke the legal maxim Actus curiae neminem gravabit, which effectively

    lays down that the act of court prejudices nobody and the court may undo the

    wrong done to the party, by even considering the question of time.

    45.This court has, in most of the cases, seen that the Magistrates are

    hyper-technical and are not considering this Act, as a Beneficial Legislation. In

    this regard, it is relevant to refer to the following decisions:-

    46. In 2026-2-SCC-96:Manu/SC/1410/2025 (Vijaya Kumari S Vs. Union of

    India), the Honourable Supreme Court was pleased to observe, as under:-

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    “Concept of surrogacy:-

    20.The first attempt at surrogacy regulation in India was in
    the form of the “National Guidelines for Accreditation,
    Supervision and Regulation of ART Clinics in India”, drafted
    by the Indian Council of Medical Research (“ICMR”), and
    approved by the Ministry of Health and Family Welfare,
    Government of India in the year 2005. It defined “surrogacy”
    as an “arrangement in which a woman agrees to carry a
    pregnancy that is genetically unrelated to her and her husband,
    with the intention to carry it to term and hand over the child to
    the genetic parents for whom she is acting as a surrogate”. It
    also prescribed a list of “general considerations” for surrogacy
    procedures, for instance, HIV tests for prospective surrogate
    mothers, mandatory adoption of the child by the genetic parents
    and limits on how many times a woman can act as a surrogate.

    Importantly however, the aforesaid Guidelines did not forbid
    the practice of “commercial surrogacy”. This was also the case
    in the subsequent draft ART Bill, 2008, which allowed the
    surrogate mother to work out “the financial terms and
    conditions of the surrogacy with the couple”.

    21. “Surrogacy” as a concept was elaborated upon in great detail
    by this Court in Baby Manji Yamada v. Union of India [Baby
    Manji Yamada v. Union of India, (2008) 13 SCC 518] , wherein it
    was observed as follows: (SCC pp. 523-24, paras 8-16)

    “8. Surrogacy is a well-known method of reproduction whereby a
    woman agrees to become pregnant for the purpose of gestating
    and giving birth to a child she will not raise but hand over to a

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    contracted party. She may be the child’s genetic mother (the more
    traditional form for surrogacy) or she may be, as a gestational
    carrier, carry the pregnancy to delivery after having been
    implanted with an embryo. In some cases surrogacy is the only
    available option for parents who wish to have a child that is
    biologically related to them.

    9. The word “surrogate”, from Latin “subrogare”, means
    “appointed to act in the place of”. The intended parent(s) is the
    individual or couple who intends to rear the child after its birth.

    10. In traditional surrogacy (also known as the straight method)
    the surrogate is pregnant with her own biological child, but this
    child was conceived with the intention of relinquishing the child to
    be raised by others; by the biological father and possibly his
    spouse or partner, either male or female. The child may be
    conceived via home artificial insemination using fresh or frozen
    sperm or impregnated via IUI (intrauterine insemination), or ICI
    (intracervical insemination) which is performed at a fertility
    clinic.

    11. In gestational surrogacy (also known as the host method) the
    surrogate becomes pregnant via embryo transfer with a child of
    which she is not the biological mother. She may have made an
    arrangement to relinquish it to the biological mother or father to
    raise, or to a parent who is themselves unrelated to the child (e.g.
    because the child was conceived using egg donation, germ
    donation or is the result of a donated embryo). The surrogate
    mother may be called the gestational carrier.

    12. Altruistic surrogacy is a situation where the surrogate receives
    no financial reward for her pregnancy or the relinquishment of the
    child (although usually all expenses related to the pregnancy and
    birth are paid by the intended parents such as medical expenses,
    maternity clothing, and other related expenses).

    13. Commercial surrogacy is a form of surrogacy in which a
    gestational carrier is paid to carry a child to maturity in her
    womb and is usually resorted to by well-off infertile couples who
    can afford the cost involved or people who save and borrow in
    order to complete their dream of being parents. This medical
    procedure is legal in several countries including in India where

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    due to excellent medical infrastructure, high international demand
    and ready availability of poor surrogates it is reaching industry
    proportions. Commercial surrogacy is sometimes referred to by
    the emotionally charged and potentially offensive terms “wombs
    for rent”, “outsourced pregnancies” or “baby farms”.

    14. Intended parents may arrange a surrogate pregnancy because
    a woman who intends to parent is infertile in such a way that she
    cannot carry a pregnancy to term. Examples include a woman
    who has had a hysterectomy, has a uterine malformation, has had
    recurrent pregnancy loss or has a health condition that makes it
    dangerous for her to be pregnant. A female intending parent may
    also be fertile and healthy, but unwilling to undergo pregnancy.

    15. Alternatively, the intended parent may be a single male or a
    male homosexual couple.

    16. Surrogates may be relatives, friends, or previous strangers.
    Many surrogate arrangements are made through agencies that
    help match up intended parents with women who want to be
    surrogates for a fee. The agencies often help manage the complex
    medical and legal aspects involved. Surrogacy arrangements can
    also be made independently. In compensated surrogacies the
    amount a surrogate receives varies widely from almost nothing
    above expenses to over $30,000. Careful screening is needed to
    assure their health as the gestational carrier incurs potential
    obstetrical risks.

    22. The first move towards the prohibition of commercial
    surrogacy came with the 228th Report [Ed.: Law Commission of
    India, Report No. 228 on Need for Legislation to Regulate
    Assisted Reproductive Technology Clinics as Well as Rights and
    Obligations of Parties to a Surrogacy (August 2009)] of the Law
    Commission of India in 2009, which flagged the problem of India
    becoming a “reproductive tourism destination” (i.e. foreign
    couples come to India for cost-effective surrogacy procedures)
    and wombs being “on rent”. It concluded with the following

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    recommendations, inter alia:

    “1. Surrogacy arrangement will continue to be governed by
    contract amongst parties, which will contain all the terms
    requiring consent of surrogate mother to bear child, agreement of
    her husband and other family members for the same, medical
    procedures of artificial insemination, reimbursement of all
    reasonable expenses for carrying child to full term, willingness to
    hand over the child born to the commissioning parent(s), etc. But
    such an arrangement should not be for commercial purposes.

    2. A surrogacy arrangement should provide for financial support
    for surrogate child in the event of death of the commissioning
    couple or individual before delivery of the child, or divorce
    between the intended parents and subsequent willingness of none
    to take delivery of the child.

    3. A surrogacy contract should necessarily take care of life
    insurance cover for surrogate mother.

    4. One of the intended parents should be a donor as well, because
    the bond of love and affection with a child primarily emanates
    from biological relationship. Also, the chances of various kinds of
    child-abuse, which have been noticed in cases of adoptions, will
    be reduced. In case the intended parent is single, he or she should
    be a donor to be able to have a surrogate child. Otherwise,
    adoption is the way to have a child which is resorted to if
    biological (natural) parents and adoptive parents are different.

    5. Legislation itself should recognise a surrogate child to be the
    legitimate child of the commissioning parent(s) without there
    being any need for adoption or even declaration of guardian.

    6. The birth certificate of the surrogate child should contain the
    name(s) of the commissioning parent(s) only.

    7. Right to privacy of donor as well as surrogate mother should be
    protected.

    8. Sex-selective surrogacy should be prohibited.

    9. Cases of abortions should be governed by the Medical

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    Termination of Pregnancy Act, 1971 only.”

    23. The question of age restrictions on the intending couple did not
    arise in these prior frameworks and recommendations. For instance,
    the ART (Regulation) Bill, 2008 imposed an age bracket of 21-45 years
    within which one could become a surrogate mother. However, there
    were no similar restrictions on the commissioning/intending couple. It
    is only with the advent of the Act in the year 2022 that the age-
    restrictions in Section 4(iii)(c)(I) have been created. Prior to the Act
    therefore, in the absence of a legal bar, or for that matter any binding
    surrogacy regulations, intending couples were free to bear children
    through surrogacy procedures irrespective of their age.

    58. In the result, we hold that Section 4(iii)(c)(I) does not have
    retrospective operation and therefore, would not apply to the Petitioners
    and Applicants who are the intending couples. We reiterate that we
    have not considered the validity of the age restrictions in this but only
    the applicability of the same to the Petitioners and the Applicants
    herein. The Writ Petitions and the applications are allowed in the
    aforesaid terms.”

    47.In 2025-SCC-Online-Mad-9957 (S.Prasanna Vs. M.Jothika), the

    Coordinate Bench of this Court was pleased to observe, as under:-

    “7. Notably, the Act is a beneficial legislation enacted with the
    primary object of regulating surrogacy in India and more
    importantly, addressing the growing problem of infertility among
    young couples. The Act seeks to provide a legally structured,
    ethical and medically safe pathway for childless couples to
    experience parenthood wherein the role of the judiciary assumes
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    great importance. A petition filed under this Act must not be dealt
    with as though it is a routine application and Courts must keep in
    mind that these are matters touching upon one of the deepest
    aspirations of human life, the desire of childless couples to have a
    child.

    8. The judicial officers are therefore expected to approach such
    petitions with sensitivity, responsibility and compassion ensuring
    that the statutory safeguards under the Act are complied with,
    without frustrating the beneficial objective of the legislation. The
    learned Judicial Magistrate, Katpadi, without properly looking
    into the provisions of the Act, has returned the petition
    erroneously by placing reliance on the interim order passed by the
    Apex Court in ARUN MUTHUVEL v. UNION OF INDIA (Writ
    Petition (Civil) No. 756 of 2022 and connected cases on
    05.02.2024 cited supra, in and by which, couples who had
    approached the Supreme Court with regard to exemption in the
    age criteria were directed to approach their respective
    jurisdictional High Courts for mere ease of access of justice,
    which is not at all applicable to the facts of the present case.

    9. Further, it is seen that the learned Magistrate had repeatedly,
    without understanding the sensitivity involved in this case, had
    returned the petition on several occasions thereby, frustrating the
    parties and acting contrary to the intent of the beneficial
    legislation. As discussed supra, the order passed by the Apex
    Court cited supra by the learned Magistrate is not applicable to
    the facts of the present case. Even, in the very same case, the final
    order passed by the Apex Court on 09.10.2025 is to the effect that
    the age restrictions cannot be applied for the couples who started
    surrogacy procedures before the 2021 Act and as stated above is
    also not applicable to the present case of the petitioners. In the
    present case, the intending couples/petitioners sought an order to
    have parentage and custody of the child born through the
    respondent/surrogate mother and an order of approval of
    surrogacy, which is permissible in law.”

    48.In Manu/DE/4285/2026 (Shewta Tuteja Vs. Union of India), the

    High Court of Delhi was pleased to observe, as under:-

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    “ 11. There can be no quarrel with the proposition that the ART
    Act is a beneficial regulatory legislation enacted with the object of
    ensuring safe, ethical and regulated ART practices. Equally, the
    concerns relating to maternal health and child welfare which
    underlie the statutory framework cannot be disregarded. However,
    while interpreting a regulatory statute touching upon reproductive
    rights and decisional autonomy, the Court is also required to
    adopt an interpretation which remains consistent with
    constitutional values embodied under Article 21 of the
    Constitution.

    16. The Supreme Court in the case of Suchita Srivastava (supra)
    recognised reproductive choice as an inseparable facet of
    personal liberty under Article 21 of the Constitution. Similarly, in
    Justice K.S. Puttaswamy (supra), decisional autonomy and
    privacy in matters concerning family, procreation and bodily
    integrity were held to be constitutionally protected interests. These
    constitutional principles necessarily require that statutory
    provisions regulating ART procedures receive a purposive
    interpretation that advances constitutional freedoms while
    preserving the regulatory object sought to be achieved by the
    enactment.

    17. The Punjab Haryana High Court in Sarabjit Kaur (supra)
    while interpreting the provisions of the ART Act observed that the
    primary purpose of the enactment is to regulate and supervise
    ART clinics and banks so as to prevent misuse and unsafe
    practices. The statutory framework ought not to be construed in a
    manner defeating the very object underlying the legislation. The
    restrictions which are not expressly contemplated under the statue
    cannot be imported so as to defeat access to ART procedures. The
    reasoning adopted in Sarabjit Kaur also assumes significance
    inasmuch as the statutory framework imposes age restrictions
    individually upon a woman and a man and not upon
    “commissioning couple” as a composite unit. The legislative
    scheme does not contemplate any joint or collective age restriction
    for a “commissioning couple.”

    27. This Court is also conscious of the fact that reproductive
    rights and access to parenthood in the contemporary
    constitutional jurisprudence cannot be reduced to purely technical
    or pedantic application of statutory conditions divorced from

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    factual context in which such rights are asserted. The ART Act is
    fundamentally regulatory in character. The object of the
    enactment is to ensure ethical and safe ART practices and not to
    create insurmountable barriers defeating legitimate continuation
    of treatment processes already lawfully undertaken.

    28. In view of the peculiar facts of the case, this Court is of the
    considered opinion that denial of permission to utilise the
    remaining five cryopreserved embryos solely on account of the
    Petitioners having marginally crossed age threshold of the ART
    process would not subserve the object of the ART Act.”

    49.In all the above said decisions, the sum and substance is that the

    Surrogacy Act is beneficial legislation enacted with the primary object of

    regulating surrogacy in India and more importantly, addressing the growing

    problem of infertility among young couples. The Act is intended to provide a

    legally structured, ethical and medically safe pathway for childless couples to

    experience parenthood wherein the role of judiciary assume great importance.

    The Courts also stressed on the need to uphold the welfare of intended parents

    and surrogate mothers and mere technical lapses should not hinder the access

    to parenthood.

    50.In regard to answering Question (3) whether the High Court can pass

    the order of parentage by itself to avoid further delay and pass an order for

    issuance of Birth affidavit and custody of the child to be born through surrogacy.

    As per Section 4(iii)(a)(ii) of the Surrogacy (Regulation) Act, 2021, an order

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    concerning the parentage or custody of the child to be born through surrogacy is

    passed by the Court of the Magistrate of the first class or above on an

    application made by the intending couple or the surrogate mother, which shall be

    the birth affidavit after the surrogate child is born. The order of parentage acts

    as a birth affidavit that ensures that the child is treated in law as the biological

    and legitimate child of the intending couple/intending wpoman from birth, with

    all corresponding rights of custody, inheritance and succession.

    51. The Coordinate Bench of this Court, by the orders, dated

    29.07.2025 and 08.08.2025, made in WP.Nos.26975 and 27020 of 2025 (X, Y

    Vs. State), was pleased to observe, as under:-

    “11. During the course of hearing, the format of one of the
    parental order passed by a competent Court was placed before
    this Court. On carefully going through the same, it is seen that the
    concerned Court satisfies itself that intending parents do not have
    any child either born naturally or through adoption or through
    surrogacy and due to the medical condition are incapable of
    having a child naturally and therefore the same necessitates
    surrogacy. The court also satisfies itself that the lady who is going
    to bear the child is willing to become the surrogate mother for that
    couple. Apart from that, the concerned Court satisfies itself that in
    case, the surrogate mother is married, consent of the husband is
    also taken. The surrogate mother must also give a statement to the
    effect that she will not claim the parental custody of the
    child/children so born in future and that the birth certificate can
    be granted in favour of the intending parents. The intending
    parents must also give a statement to the effect that they will not
    abandon the child/children so born, for any reasons whatsoever.
    All the parties must also undertake that there is no commercial
    surrogacy involved in the matter. The court must also be satisfied
    that insurance coverage has been given to the surrogate mother.

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    Apart from that, the court must also be satisfied that the intending
    parents have been granted certificate of medical indication and
    certificate of eligibility by the Medical Board. After satisfying
    itself regarding all these requirements, the parentage order is
    passed and the court declares that the intending parents will be
    declared as a lawful parent of the child/children to be born and
    the order will be treated as the birth affidavit after the child is
    born.

    14.On the one hand, the interest of the intending parents is
    involved and on the other hand, the right and autonomy of the
    surrogate mother is hanging in a balance. Apart from that, the
    surrogate mother is now 17 weeks/19 weeks pregnant with twins.

    Therefore, it also involves the right of the unborn child. Under
    such circumstances, when the same is pitted against the non
    compliance of the mandatory procedure under the Act, this Court
    has to necessarily lean in favour of protecting the interest of the
    petitioners/intending parents, surrogate mother and the unborn
    child. This Court must also exercise its Parens Patriaa
    jurisdiction in a case of this nature.

    16. In the upshot of the above discussion, this Court is inclined to
    pass the parental order after examining the petitioners/intending
    parents and the 5 th respondent/surrogate mother and after
    satisfying itself that all the other procedures are followed. The
    procedure that has been followed in this case has already been
    tabulated and extracted supra. ”

    52.In the above case, in view of the facts and circumstances of the case,

    the Hon’ble High Court has itself passed a parentage order, declaring the

    intending couple as the lawful parents of the child to be born. The parentage

    order was treated as birth certificate of the surrogate child.

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    53.In view of the foregoing discussion and observation and in the light of

    the various decisions referred to above, this Court is of the considered opinion

    that the impugned order dated 22.04.2026 passed in Crl.M.P. No.1011 of 2026 by

    the learned Judicial Magistrate No.I, Tambaram, Chennai, cannot be sustained in

    law and is liable to be set aside and reversed.

    54.Accordingly, the Criminal Revision Case is allowed in favour of

    protecting the interest of the petitioner/intending couple, surrogate mother and the

    unborn child with the following directions:

    (i)The order dated 22.04.2026 passed in Crl.M.P. No.1011 of 2026 by the

    learned Judicial Magistrate No.I, Tambaram, Chennai, is hereby set aside and

    reversed.

    (ii) The Court is satisfied that all the procedures has been followed as per

    the Surrogacy (Regulation) Act, 2021 and the certificate of eligibility issued by

    the Medical Board as per the Act is valid and after satisfying all these

    requirements the parentage order is passed by this Court and the Court further

    orders that the intending couples will be declared as lawful parents of the child to

    be born through surrogate mother and the order will be treated as the birth

    affidavit/certificate after the child is born;

    (iii)The custody of the child born shall vest with the intending

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    couple/parents immediately upon birth of the child. The child born out of

    surrogacy procedure, shall be deemed to be a biological child of the intending

    couple, or intending woman and the said child shall be entitled to all the rights

    and privileges available to a natural child under any law.

    (iv)The intending couple/parents shall not abandon the child, born out of a

    surrogacy procedure, regardless of the circumstances and the reasons.

    (v) The surrogate mother shall not claim the parental custody of the child

    so born in future;

    (vi)There shall be no commercial surrogacy involved in this case at any

    point of time;

    55.Accordingly, in view of the above directions, the question no.3 is

    answered.

    56.There shall be no order as to costs.

    57.Registry of this Court is directed to communicate a copy of this order to

    the learned Magistrate for compliance and information.

    05-08-2026
    Index: Yes/No
    Speaking/Non-speaking order
    Neutral Citation: Yes/No

    SHA

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    To

    1. The Health Secretary, Secretariat, Fort St.George, Chennai-600009.

    2. The Director of Medical and Rural Health Services
    359, Anna Salai,Chokkalingam Nagar,Teynampet,
    Chennai-600006.

    3. The Appropriate Authority/ Joint Director of Health Services
    Chengalpattu District,28, SH58, Mahalakshmi Nagar,
    Tamil Nadu 603101.

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    CRL RC No. 1301 of 2026

    SHAMIM AHMED, J.

    SHA

    Pre-Delivery Order in
    CRL RC No. 1301 of 2026

    05-08-2026

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