New Delhi: The Supreme Court has held that a Hindu marriage cannot be legally recognised if essential ceremonies are not performed, and that a marriage certificate by itself cannot create the status of husband and wife. In a significant ruling, a Bench of Justices B.V. Nagarathna and Augustine George Masih clarified that, under the Hindu Marriage Act, 1955, a marriage is only “solemnised” when it is performed with the required rites and customs.
The judgment came in the case of Dolly Rani v. Manish Kumar Chanchal, where the couple had obtained a marriage certificate from a private organisation and later registered it under Uttar Pradesh rules, but had not actually performed any Hindu wedding rituals. Their Hindu ceremony was scheduled for a later date, which never took place due to serious disputes, including allegations of dowry demands and criminal cases under the IPC and the Dowry Prohibition Act.
The Court observed that Section 7 of the Hindu Marriage Act treats marriage as a sacrament (samskara), with rituals such as Saptapadi—the seven steps around the sacred fire—as central to its completion. It held that “unless and until the marriage is performed with appropriate ceremonies and in due form, it cannot be said to be ‘solemnised’”, and that in the absence of such solemnisation, a man and woman cannot acquire the legal status of husband and wife.
On the role of registration under Section 8, the Bench clarified that registration is only evidentiary, not constitutive: it helps prove a valid marriage but cannot create one. The Court declared that if no ceremony under Section 7 has been performed, registration and any certificate issued would be legally ineffective. It also deprecated the growing practice of young couples getting certificates for “practical purposes” like visas, while deferring or skipping the actual ceremony.
In this case, the Supreme Court declared the 2021 “marriage” between the parties invalid, set aside both the private and government‑issued certificates, and quashed all related proceedings, including the divorce petition, maintenance case, criminal FIR and transfer application. The ruling reinforces that, under Hindu law, rituals are not optional formalities but the very foundation of a legally valid marriage.
