Same-Sex Marriage: A Far Fetched Dream or Reality?

I. Introduction

If patients are to be accepted as they are, regardless of their condition, they must be treated with respect and without prejudice or personal agendas. Many nations, including the United States, have a long and wicked history of discrimination against homosexuals, who are a legitimate expression of human sexuality. Abuse has taken many forms, including contempt, disdain, ostracism, and annihilation. Homo-sexuality was formerly thought to be abnormal, prompting a plethora of ideas from the medical and psychiatric disciplines to explain it. Despite strong evidence to the contrary, it was classified (though in a less prominent area) in the Diagnostic and Statistical Manual of Mental Disorders before 1987. Many medical experts still believe it to be a problem and advocate "cure" therapies. In the past, people have used deceit and false marriages to hide their true sexuality. Doctors have seen the consequences of mankind’s rejection of homosexuality on their patients far too often. Stigma and shame may manifest themselves in our lives in a variety of ways, including high levels of stress and anxiety, as well as dysfunctional behaviours, despair, and even suicide. Our sexuality plays an important role in identifying who we are as an individual. LGBT people confront an uphill battle to live a normal life in a culture that refuses to accept and love them.

Things have been moving in our country, as well as in many other parts of the world. People who are transgender or non-binary are becoming increasingly accepted in society. However, there have been attempts to avoid acceptance. Indiana Governor Mike Pence recently signed a bill into law that allows anybody to discriminate against homosexuals provided their religious views justify it. Later on, public pressure made them back down on their proposed legislation. The law was recently changed to make it clear that sexual orientation is protected.

Marriage between people of the same sex should be encouraged as a matter of social fairness and health.

Long-term relationships are linked to improved health, a reduced chance of certain diseases, and a better environment for healthy children. Patients with chronic and severe diseases typically have family members engaged in their care, as all medical experts are aware. “When the stakes are severe, such as making life-or-death decisions, talking to a patient's partner is not the same as working with the patient's spouse legally. Families with children who are being raised by their parents must ensure that both parents have equal legal and financial rights as a married pair.”² In today's world, health insurance for both couples and their children is usually linked to marriage. Married couples are eligible for over a thousand government benefits, including family medical leave, Medicaid, and Department of Veterans Affairs programs. Some of these benefits, however, are at risk for same-sex couples in countries where marriage is not recognized. Currently, same-sex marriage is legal in certain states but not in others, despite the well-documented health risks associated with such unions.

LGBT people have fought long and hard for their rights to be recognized, as well as for cultural prejudices to be abandoned and overturned. Most countries have decriminalized consensual acts of sex between members of one same-sex group via law or the courts as a first step. Despite this, laws limiting freedom of expression exist in 76 countries throughout West Asia and Africa. In the case of Suresh Koushal, the Supreme Court upheld the validity of Sec.377 of the Indian Penal Code.

The Delhi High Court affirmed the decriminaliz-ation of adult consenting sexual activity in Naz Foundation v. NCT of Delhi (hereafter referred to as Naz Foundation). According to the findings, decriminalizing homosexual behaviour is insufficient to provide gays entire respect and freedom; they must also be provided with the legal protections they demand. It also gives you a variety of ways to be recognized.³

It is not just about a legal issue but instead a subject of basic rights that affects the lives of many people in countries like India, which is rapidly modernizing and revitalizing the old traditional attitude of the masses. The myriad customs, rituals, beliefs, and traditions stifle opposition to liberal legislation. Delhi High Court first dismissed the NAZ FOUNDATION's appeal because the Court recognized an intellectual rather than a legal problem. It was then appealed to the Supreme Court in a special leave petition, and the case was remanded there for a fresh decision.

II. History of same-sex marriages

In India, homosexuality has a long history. Sexual practises between women are depicted as revelations of a feminine universe where sexuality was based on pleasure and fertility in ancient texts like the Rig-Veda, which dates back to 1500 BC, as well as sculptures and relics. Some historical evidence of same-sex relationships include descriptions of homosexual activities in the Kamasutra, Harems of young boys held by Muslim Nawabs and Hindu Aristocrats, male homosexuality in Medieval Muslim history, and evidence of sodomy in Tantric rites.

With the arrival of Vedic Brahmanism and, subsequently, British Colonialism, these experiences began to lose their relevance. According to Giti, the Aryan invasion, which began around 1500 BC, began to suppress homosexuality by establishing patriarchy's control. There are references in the Manusmriti to punishments such as caste loss, severe monetary fines, and whipping for gay and lesbian activity. In the case of married ladies, 'luring of maids' is punishable by shaving the woman's head, cutting off two fingers, and then parading her on a donkey. Manu's more harsh sanctions for married women could indicate either a high incidence of such partnerships among married women or higher acceptability of these activities among unmarried women.

In either case, these expressions allude to difficulties in the Brahmanical patriarchy enforced heterosexuality rules. Both sexual systems coexisted until British Colonialism, when the destruction of representations of homosexual expression and sexual expression, in general, became more systematic and apparent, notwithstanding oscillations in relative repression and freedom.

The presentation of explicit sexual imagery was considered 'pornographic and wicked' by homophobic and Victorian puritanical ideals. Since the time of colonial expansion, the Western concept of sexuality has been heavily affected by reproductive assumptions. Puritanical beliefs and attitudes were imprinted onto colonial people's view of sexual activity, as seen by their reactions to all types of 'unnatural' sexual behaviours.

The way people think about homosexuality has changed dramatically during the last century. Since 1974, homosexuality has no longer been classified as an aberrant behaviour and is no longer classified as a mental disease. In other nations, it has also been decriminalized. Since then, anti-discrimination or equal opportunity laws and policies have been adopted in numerous states around the world to safeguard homosexual and lesbian rights. In 1994, South Africa became the first country in the world to enshrine lesbian and homosexual rights in its constitution. Similar regulations exist in Canada, France, Luxembourg, Holland, Slovenia, Spain, Norway, Denmark, Sweden, and New Zealand. The Supreme Court of the United States ruled in 1996 that no state could pass legislation discriminating against gays. In India, so far, no such progressive changes have taken place, and homosexuals remain victims of violence in different forms
They are supported by the state and society.

III. Expectations for marriage and sexuality in both the religious and secular worlds

“The historical and traditional cultures recognized by Bachofen and Morgan gradually succumbed to colonialism uniformity. Although a diversity of marriage patterns existed in the past, conquering nations sometimes forced indigenous cultures to conform to colonial religion and administrative structures.”⁴ Empires have traditionally promoted (or, in some cases, coerced) the widespread adoption of a restricted number of theological and legal systems, whether Egyptian, Vijayanagaran, Roman, Ottoman, Mongol, Chinese, European or any other.⁵ “During national debates about same-sex marriage in the late twentieth and early twenty-first centuries, the opinions of one or more of the global religions—Buddhism, Hinduism, Judaism, Islam, and Christianity—and its associated civic ceremonies were often referenced.”⁶ Countries that had reached an agreement on this topic by the early 2000s tended to have a single primary religious affiliation among their citizens, and some of these localities had a single, state-sponsored religion.

“This was true in both Iran, where a strong Muslim theocracy made same-sex intimacy illegal, and Denmark, where the findings of an Evangelical Lutheran bishops' conference (representing the state religion) paved the way for the first national recognition of same-sex relationships through registered partnerships.”⁷ In some cases, cultural homogeneity within the dominant religion did not result in the application of the doctrine to the civic arena, but it may have encouraged a more fluid sequence of debates among citizens: despite official opposition from their main religious organization, the Roman Catholic Church, Belgium, and Spain have legalized same-sex marriage.⁸

Religion has less of an influence on the outcome of domestic debates on same-sex marriage. Unanimity on this issue was difficult to come by in some of these countries, including the United States. The Netherlands, on the other hand, had a varied religious population, as did Canada, which in 2001 became the first country to allow same-sex couples to marry. Most world religions have at one time or another opposed same-sex marriage for one or more of the following reasons: homosexual acts are immoral because they violate natural law or divine intentions; sacred texts condemn homosexual acts, and religious tradition recognizes only one man and one woman as a valid marriage. “In the early twenty-first century, religions as different as Judaism, Christianity, Hinduism, and Buddhism all issued statements on the subject. Same-sex marriage was forbidden in Orthodox Judaism, but it was permitted in Reform, Reconstructionist, and Conservative Judaism.”⁹ “The United Church of Christ, the United Church of Canada, and the Religious Society of Friends (Quakers) were among the Christian denominations that opposed it, while the United Church of Christ, the United Church of Canada, and the Religious Society of Friends (Quakers) were more lenient or allowed individual churches autonomy in the matter.”¹⁰ The Unitarian Universalist churches and the gay-friendly Universal Fellowship of Metropolitan Community Congregations both officially supported same-sex marriage.¹¹

“Due to Hinduism's absence of a single leader or hierarchy, some Hindus welcomed the practice while others vehemently opposed it. The three major Buddhist schools—Theravada, Mahayana, and Vajrayana—emphasized enlightenment as a central problem, and as a consequence, most Buddhist literature saw all marriages as a mutual choice.”¹² One of the places where religion and government power collide is marriage definitions; sexuality is another. The goal of marriage, according to one understanding, is to promote a successful pregnancy and childrearing. “In another, marriage is a necessary component of a stable civilization, with reproduction occurring as an unintended consequence of that stability. Marriage is considered a weapon of social domination by a third group, and as a consequence, it is viewed as undesirable. A fourth argument is that the government should not interfere in the relationships of consenting adults.”¹³

Although most religions subscribe to just one of these beliefs, it is not uncommon for two or more to coexist in the same community. The essential goal of marriage, according to proponents of the first approach, is to provide a sufficiently stable social environment within which to produce and raise children. They argue that since both males and females are essential for reproduction, marriage rights should be limited to opposite-sex couples. Another way to put it is that sexually intimate relationships should be capable of producing offspring. According to this viewpoint, the movement to legalize same-sex marriage is a misguided attempt to ignore the social, moral, and biological distinctions that ensure mankind’s existence and should be rejected. Because biological reproduction is seen as a kind of social duty, proponents argue that seeing people's legal and moral responsibilities to one another in terms of genetic relatedness is better. They frequently defined the parents' legal obligations to their biological children differently from those of their stepchildren in the circumstances like inheritance or custody.

There is a tendency for spouses, parents, and children’s legal ties to converge among those who believe same-sex marriage is undesirable. “Automatic property succession between spouses, parents, and children is common in these cultures, as is the ability for close relatives to co-own property without the need for joint ownership contracts.”¹⁴ To make things even more confusing, although these cultures may allow close family members exceptional powers such as sponsoring immigration applications or making medical decisions on behalf of the ill, these privileges are seldom provided automatically. Same-sex couples generally have a harder time getting around the law and, in other cases, are openly prohibited from doing so. Same-sex marriage proponents claim that committed relationships, including physical intimacy, are important because they bind people together in new and different ways than the conventional procreative form of marriage. Such connections are fundamentally important in this context while yet being distinct from (though not incompatible with) childbearing and childrearing tasks—people from stable family groupings for a variety of reasons, including sexual interactions.¹⁵

The emancipation of the vulnerable, such as children, the elderly, and others, are the foundation of a thriving community. Devaluing same-sex partnerships, in this opinion, is incorrect since it contains arbitrary and unjustifiable discrimination that damages the community as a whole. According to the majority of proponents of same-sex marriage, international human rights legislation provides equality of treatment for all persons. As a consequence, they deny a particular group the ability to marry as its whole was discriminatory.¹⁶ Any committed couple should be able to gain all of the legal advantages associated with heterosexual marriage, according to proponents of the community-benefit approach. “Self-identified "queer" theorists and activists, in contrast to these positions, sought to deconstruct the paired oppositional categories commonly used in discussions of biology, gender, and sexuality (e.g., male-female, man-woman, gay-straight) and replace them with categories or continua that they believed more accurately reflected actual human practices.”¹⁷ Marriage, according to advocates for the LGBT community, is a "hetero-normality" institution that places individuals in cultural categories they don't fit in and stigmatizes those who refuse to accept it. They argue that adult consensual intercourse should not be prohibited and that marriage as a cultural institution should be abolished for these reasons. Libertarianism, a fourth viewpoint, differed from queer theory in its underpinnings but shared some of its outcomes; it claimed that government powers should be strictly limited, with the primary goal of maintaining civil order, infrastructure, and defence. Marriage legislation of any kind, whether legalizing or prohibiting same-sex marriage, was objectionable to libertarians since it went beyond the jurisdiction of the government. Marriage should be "privatized," according to libertarians, so that people are free to form partnerships with whoever they choose, even if the government doesn't regulate it.¹⁸

IV. The effect on the health of sexual minorities

Using a variety of approaches and nations where same-sex marriage has been proposed or implemented, a growing body of research is shedding light on the effect of equal marriage laws on the health and well-being of sexual minorities. According to research, legalizing same-sex marriage has a favourable influence on the health of persons from sexual and gender minorities. When comparing sexual minorities living in states with equal marriage rights to those living in states without equal marriage rights, there has been evidence of lower psychological distress and improved self-reported health. According to one state-specific research, when same-sex marriage was legalized, homosexual and lesbian men’s health increased. Furthermore, residents of states that have or are contemplating limiting marriage recognition to couples of different sexes are more likely to suffer from alcoholism and mental illness than residents of jurisdictions that do not have such limitations. According to an Australian study on marriage limitation voting, sexual minorities in jurisdictions where same-sex marriage rights were approved by voters had superior overall health, mental health, and life happiness. In contrast, sexual minorities residing in countries where such rights are not backed by voters have fewer opportunities.¹⁹

Despite previous literature reviews demonstrating beneficial outcomes for sexual minorities, we are unaware of any studies that have looked into the effects of legalized same-sex marriage on the health of individuals, couples, and communities. We can now investigate the psychological ramifications of equal marriage laws thanks to a slew of new research, both quantitative and qualitative. Understanding the ramifications will considerably improve the design and interpretation of future research into the possible health benefits of same-sex marriage.²⁰

V. India's stance on same-sex marriage

The Central Government claimed strongly before the Delhi High Court in October 2020, through Tushar Mehta, that the legalization of Section 377 of the IPC does not immediately translate into the fundamental right to marry for same-sex couples. Earlier this week, the Solicitor General of the United States reiterated his position, arguing that the 2018 ruling in Navtej Singh Johar v. Union of India does not address same-sex marriage but rather argues that private conduct between same-sex couples is no longer illegal under Indian penal laws. In response to the government's arguments, Saurabh Kirpal, a Senior Advocate representing one of the Petitioners, said that while the judge did not specifically legalize same-sex marriages, the logical conclusion backed such a view.

Because it lacks rationale, the central government's conservative and narrow-minded approach bothers me the most. Rather than granting its inhabitants the freedom to marry whoever they want, the Indian government seems to be more interested in maintaining the country's supposedly ancient customs and traditions. The Supreme Court has stressed the significance of an individual's right to marry the person of their choice on multiple occasions. "Individual liberty and self-determination are preserved by our Constitution; the Supreme Court declared in Shafin Jahan v. Asokan KM (2018).”²¹ This refers to one's ability to make judgments affecting numerous facets of one's identity and personality. The decision to marry or not is totally up to the individual.²²

According to a superficial assessment of the Court's decisions, a person has the legal and exclusive right to marry the partner of their choice. Why would the federal government suddenly stand in the way of the courts and the interests of the people? The government reaction is pitifully insufficient. A prior legal argument made by the government was that "living together as partners and having sexual interactions with same-sex persons is not comparable with the Indian family unit notion of a husband and wife, as well as children born out of the marriage between the two.”²³

The federal government would rather violate persons’ constitutionally established marital rights than take the risk of allowing them to enjoy their fundamental right to privacy and freedom of choice. The Delhi High Court will hear the cases one more time on November 30, after which the matter will be disposed of. “However, notwithstanding how much effort the federal government has put into ensuring equal rights for heterosexual and same-sex couples, the Supreme Court may be able to nail it by intervening to safeguard individuals who have been denied basic rights."²⁴

I believe that extending the legal term of "family" in India is crucial. Gender and the roles that people play no longer dictate how people live their lives. Gender politics in traditional heteronormative marriage need to be reformed, as do social and political systems that prevent LGBTQ+ people from participating fully in society. “If the LGBTQ+ community's rights are to be acknowledged, the government must take active measures to officially establish marriage unions as an exclusive domain of the pair, on par with heterosexual married couples.”²⁵

VI. Why should same-sex marria-ge be legalized?

The threat of divorce, not homosexuality, poses the greatest threat to marriage's integrity. According to a recent New York Times article, in areas where homosexual marriage is not prohibited by law, the divorce rate has decreased. “The divorce rate in Massachusetts has decreased by 21% since homosexual marriage became legal in 2004. Despite being the first state to implement a constitutional amendment prohibiting homosexual marriage in 1998, Alaska has the highest divorce rate in the US, at over 17%.”²⁶ Statistics reveal that divorce rates are unaffected by race, religion, or age and that divorce rates have continuously increased despite many countries' rejection of gay marriage. In reality, sixty percent of heterosexual marriages terminate after ten years, and eighty percent after twenty.

Legalizing gay marriage will improve family values while also preventing risky behaviour. Promiscuity is characterized by problems such as sexually transmitted infections, which are often associated with sexuality. Marriage promotes the characteristics of monogamy and fidelity. "All of those changes for today's generation of LGBT adolescents," Andrew Sullivan writes in his Timepiece. They will be able to predict their future as a family member from the beginning. As long as they date throughout their childhood and early adulthood, there is a final framework that will give them a feeling of stability and social support... It never occurred to them heterosexuals to consider if they could be able to marry the person they love in the future."

Finally, when evaluating the establishment of a law, it is necessary to remember not to infringe on the rights of others. Is it possible that permitting homosexual marriage might affect the legal rights of others? As previously stated, a marriage is a legally binding agreement between two people who freely choose each other. A wedding involves the two people being married, the person performing the ceremony (such as a magistrate, preacher, or clerk), and any witnesses who choose to participate. Everyone in attendance at a wedding or civil ceremony is doing so on purpose. After the marriage license is signed, one or both of the person's last names may be changed; they will have a new tax filing status, they will be allowed to possess joint property, make medical choices, acquire employee health benefits, and so on. Except for the two consenting adults, no one else has rights that change at that instant. The rights of others are unaffected in any way.²⁷

The views of the affected minority should be taken into account when determining whether or not this action is lawful. If you're one of those who want to love the sinner and hate the sin, Emerson Collins has some wise words for you. That which you want, you must give up. “You can't love me and loathe who I am at the same time. No one can say they love me when we have personal control over the government, which is why saying you'd construct a society in a way that diminishes who I am is illogical.”²⁸

Throughout the world, there has been an increasing acceptance of the right of gay and lesbian couples to marry. Back in 2001, The Netherlands became the first country in the world to legally recognize same-sex marriage. Post that, several countries such as Belgium, Spain, Canada, Sweden, South Africa, and Norway followed in the footsteps of the progressive Dutch legislation to recognize same-sex marriages. To date, around a dozen countries legally support same-sex marriage. Denmark, in a recent happening, supported a gender-neutral bill allowing gay marriages through church weddings or civil registry; although, Denmark was the first nation to legalize same-sex unions in 1989.

In terms of international law too, several attempts have been made by reputed international human rights courts such as the Human Rights Committee of the United Nations, European Court of Human Rights, Inter-American Human Rights Courts, etc. both through strategic legislations and progressive, broad judgments to recognize the concept of same-sex marriages often as a matter of basic human right.

One of the foremost cases in this regard was delivered by The Human Rights Committee case in 1999, with two same-sex couples as the plaintiffs/petitioners and the government of New Zealand as the defender/respondent. Schalk and Kopf v Austria, an ECHR case from 2010, had a same-sex couple as plaintiffs/petitioners and the Austrian government as respondents. Even though both New Zealand and Austria initially responded negatively to the petitions, both countries now officially recognize same-sex marriage.

The Inter-American Court of Human Rights (IACHR) declared on January 8, 2018, that the American Convention on Human Rights necessitates and compels same-sex marriage to be legalized. Costa Rica was fully bound by the momentous decision, which set a precedent for the other signatory countries. Governments should issue provisional orders legalizing same-sex marriage until a new law is enacted, according to the Court. Barbados, Bolivia, Chile, Costa Rica, the Dominican Republic, Ecuador, El Salvador, Guatemala, Haiti, Honduras, Mexico, Nicaragua, Panama, Paraguay, Peru, and Suriname are all affected by the judgment. Following that, the Costa Rican government said that it would implement the judgment "in its entirety," and the Panamanian government indicated that it would accept it as well.

The European Court of Justice declared on June 5, 2018, that member states of the European Union must recognize the freedom of movement and residency rights of same-sex marriages if one partner is an EU citizen. The Court concluded that while EU member states can decide whether or not to legalize same-sex marriage, they cannot restrict an EU citizen's and their spouse's freedom of movement. Furthermore, the Court determined that the term "spouse" is gender-neutral and does not always imply a partner of the opposite gender.

In the case of M. v. H., the Supreme Court of Canada found that cohabiting same-sex couples in a common-law marriage have the same rights as unmarried cohabiting opposite-sex spouses.

The European Court of Human Rights declared that same-sex couples should be treated equally to opposite-sex couples when it comes to common-law status.

The Supreme Court of Brazil has declared that two women can legally marry. It is Brazil's top Court that has upheld gay marriage. It overturned two lower court decisions that had been made against the ladies.

VII. Conclusion

Diverse civilizations have varied conceptions of marriage. Intimate connections, such as those between a person and his or her spouse or partner, are the primary focus of this organization. It is undeniable that homosexuals face discrimination and intolerance, in addition to being marginalized within society as a whole. The reasons could be personal or social. Same-sex marriages are currently legal in 29 of the world's 195 countries.

In India, however, they are still regarded as filthy and unnatural and hence outlawed. The anti-discriminatory verdicts in Naz Foundation and NALSA must be enhanced to overturn Koushal and obtain legal and societal acceptance of same-sex weddings. The best course of action would be to make homosexual marriage a part of personal law. Making personal laws recognize the validity of gay and lesbian relationships is a difficult task since doing so might be perceived as an infringement of religious freedom. There's also the possibility of amending the Special Marriage Act, which is technically unconstitutional since it discriminates against homosexuals by refusing to recognize the community's "right to marriage".²⁹

If the Koushal decision is overturned, there is a good chance that the Naz Foundation notion, which outlaws discrimination based on sexual orientation, would be applied to discrimination under Article 15. Several judgments, notably Navtej Singh Johar v. Union of India, Naz Foundation, and NALSA, have made preliminary but substantial steps to reduce the stigma associated with the LGBT population. It is now up to the citizens of the nation to challenge and enforce the principles set out in these rulings.³⁰ If we wish to appropriately recognize the harmed group's human dignity, we must set laws that are clear and unambiguous, and we must forcibly enforce them.

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Footnotes

1. Author is a student at Law Centre-1, Faculty of Law (Delhi University), India.

2. Same-sex marriage around the world, Pew Research Center (2019). ↩

3. Ibid. ↩

4. Hatzenbuehler ML, Link B., Introduction to the special issues on structural stigma and health, Social Science and Medicine (2014). ↩

5. Ibid. ↩

6. Lannutti PJ., Experiencing same-sex marriage: Individual, couples, and social networks (New York: Peter Lang; 2014). ↩

7. Kealy-Bateman W, Pryor L., Marriage equality is a mental health issue, Australasian Psychiatry (2015). ↩

8. Raifman J, Moscoe E, Austin B, McConnell M., Difference-in-differences analysis of the association between state same-sex marriage policies and adolescent suicide attempts, JAMA Pediatrics (2017). ↩

9. Voyles CH, Sell RL., Continued disparities in lesbian, gay, and bisexual research funding at NIH, American Journal of Public Health (2015). ↩

10. Elwood WN, Irvin VL, Sun Q, Breen N., Measuring the influence of legally recognized partnerships on the health and well-being of same-sex couples: Utility of the California Health Interview Survey, LGBT Health (2017). ↩

11. Ibid. ↩

12. Arksey H, O’Malley L., Scoping studies: Towards a methodological framework, International Journal of Social Research Methodology (2005). ↩

13. Lannutti PJ., The influence of same-sex marriage on the understanding of same-sex relationships, Journal of Homosexuality (2007). Ibid. ↩

14. Bernstein, Mary. 1997. Celebration and Suppression: The Strategic Uses of Identity by the Lesbian and Gay Movement, American Journal of Sociology 103: 531–565. ↩

15. Ibid. ↩

16. Bayer R., Homosexuality and American psychiatry: the politics of diagnosis, (Princeton, NJ: Princeton University Press, 1987). ↩

17. Philpot SP, Ellard J, Duncan D, Dowsett GW, Bavinton BR, Down I, et al. Gay and bisexual men’s interest in marriage: An Australian perspective, Culture, Health & Sexuality (2016). ↩

18. Ibid. ↩

19. Monette P. Becoming a man: half a life story (New York: HarperCollins, 1992). ↩

20. Ibid. ↩

21. Gonzales G, Same-sex marriage -- a prescription for better health, N Engl J Med (2014). ↩

22. Ibid. ↩

23. Adam Barry, The Rise of a Gay and Lesbian Movement (Twayne Publishers 1987) ↩

24. Ibid. ↩

25. Ettelbrick, Paula L., Wedlock Alert: A Comment on Lesbian and Gay Family Recognition, Journal of Law and Policy (1996) 5: 107–166. ↩

26. LeBlanc AJ, Frost DM, Bowen K., Legal marriage, unequal recognition, and mental health among same-sex couples, Journal of Marriage and Family (2018). ↩

27. Ibid. ↩

28. Thomas M., Atrocity stories and triumph stories: Using couple narratives to evaluate same-sex marriage and civil partnership, Narrative Inquiry (2014). ↩

29. Flores AR, Barclay S., Backlash, consensus, legitimacy, or polarization: The effect of same-sex marriage policy on mass attitudes, Political Research Quarterly (2016). ↩

30. Ibid. ↩