From the development of the law on the point, over the years, culminating in the aforesaid enactment, it appears,

that the right of a woman to live in the shared household, originally conceived as a part of her right to maintenance, has enlarged with the advent of the Act. (Para 29) Section 18 postulates the passing of protective and ameliorative orders of civil Courts, calculated to preserve the status quo for the benefit of women. This is, in fact, one of the most significant features of the statute. A woman who is facing the brunt of harassment in a domestic relationship is more concerned with being rendered destitute rather than punishment being handed down to the perpetrator of the harassment. In this connection, the preceding Section 17 is legally path-breaking since it introduces the right of every woman in a domestic relationship to reside in the shared household, whether or not she has any right, title or beneficial interest in the same. (Para 6) Vandana vs. Mrs. Jayanti Krishnamachari & Others (2007) 6 MLJ 205 (Mad)

Domestic relationship9 - means a relationship between two persons who live or have lived together in a shared household. Such persons may be related by a) consanguinity / blood; b) marriage; c) through a relationship in the nature of marriage, d) adoption or e) members of a joint family. Consanguinity means being related to another person through a common ancestor. Under the PWDVA, the domestic relationship is the basis for a woman to take action. The concept of domestic relationship has broadened the scope of who may seek remedies under this law. Previously only a woman who was able to prove her relationship with the other party by blood or marriage (such as wives and mothers) were entitled to remedies related to domestic violence, such as right to residence and maintenance. As per the expression have at any point lived together, immediate residence of the two parties is not required. Prior acts of violence will be taken into account for filing an application under the Act. Azimuddin & Others vs. State of Uttar Pradesh & Another, judgment of Allahabad High Court on 12 February 2008 (i) Riaz Fatima and Anr v. Mohd Sharif : 135 (2006) DLT 205; (ii) Dagdu Chotu Pathan v. Rahimbi Dagdu Pathan: 2002 (3) Mh.L.J. 602 (FB); (iii) Dilshad Begum Ahmadkhan Pathan v. Ahmadkhan Hanifkhan Pathan and anr: Criminal Revision Applications 313 and 314/1997 decided on 17.1.2007 (Bombay High Court); (iv) Shamim Ara v. State of U.P.: AIR 2002 SC 355. Shamim Ara v. State of U.P.: AIR 2002 SC 3551