Supreme Court Declares Marriage Invalid: Hindu Marriage Act and Registration Rules Examined
The case of Dolly Rani vs. Manish Kumar Chanchal involves a crucial ruling by the Supreme Court regarding the validity of marriages under the Hindu Marriage Act, 1955. The Court had to decide whether a marriage that was registered but not solemnized through the required Hindu rituals could be considered legally valid. Ultimately, the Court declared the marriage null and void, emphasizing that Hindu marriages must adhere to the rites and ceremonies prescribed by law.
Background of the Case
The dispute arose when the petitioner, Dolly Rani, sought the transfer of a divorce petition filed by the respondent, Manish Kumar Chanchal, from the Family Court in Muzaffarpur, Bihar, to the Family Court in Ranchi, Jharkhand. However, during the pendency of the case, both parties decided to resolve the matter by filing a joint application under Article 142 of the Constitution of India, requesting the Court to declare their marriage invalid.
The couple had obtained a marriage certificate from Vadik Jankalyan Samiti (Regd.) and a registration under the Uttar Pradesh Marriage Registration Rules, 2017, despite not performing the necessary Hindu marriage rituals. This led to legal complications when differences arose between them.
Key Legal Issues
- Whether a marriage not performed as per Hindu rites and customs can be considered legally valid.
- Whether registration of a marriage under state rules provides legal recognition in the absence of proper solemnization.
- Whether the Court could use its power under Article 142 of the Constitution to declare the marriage null and void.
Arguments by the Petitioner
The petitioner argued that no valid marriage had taken place since it was not solemnized as per Hindu rituals. She contended:
“The respondent could not have sought a divorce decree since no legally valid marriage existed between the parties in the first place.”
She further requested that the marriage certificate issued under the Uttar Pradesh Registration Rules, 2017, and the Vadik Jankalyan Samiti (Regd.) be declared null and void.
Arguments by the Respondent
The respondent admitted that the required Hindu marriage ceremonies were not performed. However, he argued:
“Having no other recourse, I was compelled to file for divorce since the marriage was registered under the Uttar Pradesh Registration Rules, 2017.”
He agreed to the joint application to declare the marriage void.
Supreme Court’s Analysis
1. Importance of Hindu Marriage Ceremonies
The Court reiterated that a Hindu marriage must be solemnized in accordance with the customary rites and ceremonies of either party. The judgment cited Section 7 of the Hindu Marriage Act, which states:
“A Hindu marriage may be solemnized in accordance with the customary rites and ceremonies of either party. Where such rites and ceremonies include saptapadi (the taking of seven steps by the bride and groom before the sacred fire), the marriage becomes complete and binding when the seventh step is taken.”
The Court found that since no such ceremonies were performed, there was no valid marriage under Hindu law.
2. Invalidity of Registration Without Solemnization
The Court observed that the Uttar Pradesh Marriage Registration Rules, 2017, allow for the registration of Hindu marriages but do not confer legal validity if the marriage was not solemnized under Section 7 of the Hindu Marriage Act. The judgment stated:
“Registration of a marriage under state rules does not by itself create a valid marriage in the absence of the required religious ceremonies.”
3. Court’s Power Under Article 142
The Court accepted the joint application filed by the parties under Article 142 of the Constitution, which allows the Supreme Court to pass orders to ensure complete justice. The judgment stated:
“Since no valid Hindu marriage took place, this Court has the authority under Article 142 to declare the marriage null and void and to quash all related proceedings.”
Final Judgment
The Supreme Court allowed the application and issued the following declarations:
- The alleged marriage dated 07.07.2021 is declared null and void.
- The certificates issued by Vadik Jankalyan Samiti (Regd.) and under the Uttar Pradesh Marriage Registration Rules, 2017, are also declared null and void.
- All related cases filed by the parties against each other, including the divorce petition, maintenance case, and criminal FIR, are quashed.
The judgment emphasized:
“In the absence of a legally valid marriage, the parties never acquired the status of husband and wife. Consequently, all legal proceedings arising from their purported marriage stand annulled.”
Key Takeaways from the Judgment
- A Hindu marriage must be solemnized through proper rituals and cannot be considered valid based solely on registration.
- Registration of a marriage without proper solemnization does not confer legal marital status.
- The Supreme Court can invoke Article 142 to declare a marriage null and void if it was never legally valid.
- State marriage registration rules cannot override the requirements of the Hindu Marriage Act.
- This ruling discourages the practice of obtaining marriage certificates without performing proper rituals.
Judgment Date: April 19, 2024
Judges: B.V. Nagarathna, Augustine George Masih
Petitioner Name: Dolly Rani.Respondent Name: Manish Kumar Chanchal.Judgment By: Justice B.V. Nagarathna, Justice Augustine George Masih.Place Of Incident: Ranchi, Jharkhand.Judgment Date: 19-04-2024.
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