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Beyond Biology: Analysing The Impact Of The 2026 Supreme Court's Mandate On Adoptive Maternity Leave Under Section 60 Of The Social Security Code, 2020




Yoga Dharshini M, B.B.A.LL.B. (Hons.), School of Excellence in Law (SOEL), The Tamilnadu Dr. Ambedkar Law University (TNDALU), Chennai, Tamilnadu


ABSTRACT:


The landmark decision of Hamsaanandini Nanduri v Union of India 2026 INSC 246, issued by the Supreme Court in 2026, is likely to have a profound effect on the future of Indian maternal rights and motherhood jurisprudence. This analysis will focus on the recent verdict that declared the three-month age requirement for adopted children null and void with respect to maternity provisions in the Code on Social Security 2020, a new law that consolidates nine major labour laws and includes an initial cliff-edge restriction on the eligibility criteria for the grant of maternity benefit. The basis of the Court's decision is Article 14 and 21, which both regard the biological act of giving birth and the overall experience of motherhood, including emotional bonding and nurturing, as relevant issues under the legislation. The evidence presented at the trial showed that approximately 5% of adoptions are legally completed in India within the three-month period, making this requirement "illusory" and "lacking practical effect" under Indian law. In holding that reproductive autonomy is included in the adoption process, the Supreme Court endorsed the idea that the needs of adoptive children, regardless of their ages, are as important, if not more important, than the needs of any new- born infant. The analysis will also include the effects on corporate compliance, and what HR Departments should do to make changes to leave policies to ensure 12 weeks’ leave on pay regardless of the child's age. Moreover, it assesses the wider social change resulting from the judgment, such as the judiciary's urgent appeal for statutory paternity leave to challenge traditional gendered parenting roles and achieve greater equality in the workplace. The aim is to align India with international human rights standards to protect economic security and dignity for all mothers, regardless of their child's biological origin.



Indian Journal of Law and Legal Research

Abbreviation: IJLLR

ISSN: 2582-8878

Website: www.ijllr.com

Accessibility: Open Access

License: Creative Commons 4.0

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All research articles published in The Indian Journal of Law and Legal Research are fully open access. i.e. immediately freely available to read, download and share. Articles are published under the terms of a Creative Commons license which permits use, distribution and reproduction in any medium, provided the original work is properly cited.

 

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The opinions expressed in this publication are those of the authors. They do not purport to reflect the opinions or views of the IJLLR or its members. The designations employed in this publication and the presentation of material therein do not imply the expression of any opinion whatsoever on the part of the IJLLR.

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