In 2013, in the Koushal v Naz Foundation case, the Supreme Court overturned a decision by the Delhi High Court which had read down Section 377 of the Indian Penal Code. The Supreme Court’s

decision reinstated Section 377, which criminalises sexual intercourse, saying it was “against the order of nature.” The court held decisional privacy as one of the facets of the right to

privacy, which is “reflected by an ability to make intimate decisions primarily consisting one’s sexual or procreative nature and decisions in respect of intimate relations.” Before this,

most the Supreme Court’s jurisprudence on privacy had been limited to privacy of home (private spaces) or communication.