Is Hindu Marriage Valid Without Ceremonies? SC Explains!

Key Judicial Interpretation

The Supreme Court held that a Hindu marriage must be solemnized with the requisite ceremonies as per Section 7 of the Hindu Marriage Act, 1955, for it to be considered valid. Merely obtaining a registration certificate without performing the essential rites does not constitute a valid marriage (paras 6-11).

Court’s View

The Court emphasized that the solemnization of a marriage through the performance of the prescribed rites and ceremonies is crucial under Hindu law. Without these, any registration of marriage is invalid and does not confer marital status (paras 10-14).


The Supreme Court declared the marriage between Dolly Rani and Manish Kumar Chanchal as invalid, nullified the marriage certificates, and quashed all related legal proceedings, including divorce and dowry cases, as there was no valid marriage in the eyes of the law (paras 17-18).

Relevant Acts, Sections, Provisions, and Rules Cited

Sections 7 and 8 of the Hindu Marriage Act, 1955; Article 142 of the Constitution of India; Sections 498A, 420, 506, 509, 34 of the Indian Penal Code, 1860; Sections 3 and 4 of the Dowry Prohibition Act, 1961.

Case of the Appellant

The petitioner, Dolly Rani, sought the transfer of the divorce petition filed by her husband to a different jurisdiction and contended that the marriage was not valid as it was not solemnized with the requisite Hindu rites.

Appellant Relied On

The petitioner relied on the provisions of the Hindu Marriage Act, 1955, emphasizing that the marriage lacked the necessary ceremonial rites, and therefore, could not be considered valid.

Case of the Respondent

The respondent, Manish Kumar Chanchal, acknowledged that the marriage did not fulfill the required ceremonial rites and joined in seeking a declaration that the marriage was invalid.

Respondent Relied On

The respondent relied on the absence of the necessary rites and ceremonies, agreeing that the marriage registration was invalid without a proper Hindu marriage solemnization.

Question & Answer

Question: What constitutes a valid Hindu marriage under the Hindu Marriage Act, 1955?
Answer: A valid Hindu marriage requires the performance of customary rites and ceremonies, including the Saptapadi (seven steps taken by the bride and groom before the sacred fire) if applicable (paras 6-7).

Question: Can a marriage be valid without performing Hindu rites and ceremonies?
Answer: No, the Supreme Court ruled that without performing the requisite Hindu rites and ceremonies, the marriage cannot be considered valid, even if it is registered (paras 10-11).

Question: What was the Supreme Court’s decision regarding the marriage certificates issued in this case?
Answer: The Supreme Court declared the marriage certificates null and void as the marriage did not comply with the necessary Hindu rites and ceremonies (para 17).

Question: What legal proceedings were quashed by the Supreme Court in this case?
Answer: The Supreme Court quashed the divorce petition, maintenance case, and criminal case related to dowry filed by the parties against each other (para 17).

Question: What is the importance of solemnization in Hindu marriages?
Answer: The Supreme Court emphasized that solemnization through prescribed rites and ceremonies is essential for a valid Hindu marriage, reflecting its sacred and sacrosanct nature in Indian society (paras 11-14).

Details of Case

Court: Supreme Court of India
Bench: Justice B.V. Nagarathna, Justice Augustine George Masih
Date of Order: April 19, 2024
Case Name: Dolly Rani vs. Manish Kumar Chanchal
Case No.: Transfer Petition (C) No. 2043/2023