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Referring to the documentary evidence placed on record, the Court pointed out that the children’s school records, identity documents and the social recognition they enjoyed all indicated the petitioner as their father. It further held that the children were not the authors of the circumstances surrounding their birth, nor of any events that transpired before or after their birth between the two adults whose relationship brought them into the world.

Justice Sharma warned that if one of the alleged parents later seeks to evade the consequences of his own choices, the law cannot allow the burden to be shifted onto the children. The consequences of such conduct must be borne by the adults themselves. The Court articulated that when two adults choose to enter into a relationship and children are born therefrom, the choices made by those adults cannot defeat or eclipse the rights of those children to know their biological parentage.

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Legal Reasoning and Implications

The High Court clarified that the issue before it was not the validity or morality of the relationship between the adults, but whether the children were biologically fathered by the petitioner. It held that the children’s right to identity and the consequential legal rights flowing therefrom—including claims for maintenance—could not be subordinated to an adult’s fear of social embarrassment.

The Bench further observed that adopting a contrary view would create a scenario wherein a person, after having lived in a relationship outside a legally subsisting marriage or in a live‑in relationship and having brought children into the world, could subsequently deny parentage and leave the children to spend their entire lives in uncertainty regarding their identity and lineage. Such an approach would deprive children of an answer to a fundamental question that goes to the root of their identity: who their biological parents are.

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Linking the right to know parentage with the child’s dignity, the Court stated that this right is intrinsically connected to the child’s identity. Consequently, where a serious and bona fide dispute regarding paternity arises and there exists prima facie material justifying a DNA test, the Court cannot altogether foreclose a scientific examination merely because the relationship between the adults may not constitute a valid marriage in the eyes of law.

Operative Outcome

In light of the foregoing reasoning, the Delhi High Court dismissed the petitioner’s challenge and upheld the Family Court’s order directing DNA testing. The judgment reaffirms that the determination of biological parentage, when genuinely contested, must yield to the child’s paramount interest in knowing their origins, irrespective of any reputational apprehensions harboured by the alleged parent.

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