In a seminal judgment delivered on April 19, 2024, the Supreme Court of India has provided authoritative guidance on the essential requirements for a valid Hindu marriage under the Hindu Marriage Act, 1955. The apex court’s ruling, which came in response to a joint application filed by a couple seeking a declaration that their purported marriage was not valid in the eyes of the law, has far-reaching implications for upholding the sanctity of Hindu marriages across the nation.
The case before the Supreme Court bench, comprising Justices B.V. Nagarathna and Augustine George Masih, involved a couple, Dolly Rani and Manish Kumar Chanchal, who claimed to have solemnized their marriage on July 7, 2021. They obtained a marriage certificate from a registered organization called Vadik Jankalyan Samiti.
However, the couple acknowledged that no actual marriage ceremony was performed as per Hindu rites and customs prescribed by the Act. In its comprehensive judgment, the Supreme Court delved into the intricacies of Section 7 of the Hindu Marriage Act, which governs the ceremonies for a valid Hindu marriage.
The court emphasized that a Hindu marriage must be solemnized in accordance with the customary rites and ceremonies of either party, and where the rites include the Saptapadi (taking of seven steps by the bride and groom before the sacred fire), the marriage becomes complete and binding upon the seventh step.The court categorically stated that a mere issuance of a certificate by an entity, in the absence of the requisite ceremonies being performed, would neither confirm any marital status to the parties nor establish a marriage under Hindu law.
The registration of a marriage under Section 8 of the Act is only to facilitate the proof of a valid Hindu marriage, but it does not confer legitimacy to a marriage that has not taken place in accordance with Section 7.Addressing the specific case before it, the Supreme Court declared that the ‘marriage’ dated July 7, 2021, between Dolly Rani and Manish Kumar Chanchal was not a valid Hindu marriage under the provisions of the Act. Consequently, the certificates issued by the organization and the Registrar of Marriages were declared null and void.
The court further clarified that the couple had never acquired the status of husband and wife. In a strong rebuke, the court deprecated the practice of young couples seeking to acquire the status of husband and wife without undergoing a valid marriage ceremony. It emphasized the sacredness of the institution of marriage in Indian society and urged individuals to deeply contemplate its significance before entering into it.
The court stressed that a Hindu marriage is a sacrament and a samskara, facilitating procreation, consolidating the family unit, and solidifying the spirit of fraternity within communities.The judgment also highlighted the overriding effect of the Hindu Marriage Act, which supersedes any inconsistent customs, usages, or interpretations of Hindu law.
Hindu Marriage Act
It underscored that a union of two persons under the provisions of the Act, through a valid Hindu marriage, grants them the status and character of being a husband and wife in society – a status that cannot be acquired in the absence of a duly solemnized marriage.This landmark ruling by the Supreme Court serves as a guiding light for upholding the sanctity of Hindu marriages in India.
By setting definitive guidelines and reiterating the importance of adhering to the prescribed rituals and ceremonies enshrined in the Hindu Marriage Act, the apex court has ensured that the fundamental tenets of this sacred institution are preserved and upheld across the nation.
