DOLLY RANI VS. MANISH KUMAR CHANCHAL

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CITATION	2024 SCC ONLINE SC 754
DATE OF JUDGMENT	19^th April 2024
COURT	Supreme Court of India
APPELLANT	Dolly Rani
RESPONDENT	Manish Kumar Chanchal
BENCH	Hon’ble Justice B.V. Nagarathna and Hon’ble Justice Augustine George Masih

INTRODUCTION

The case of Dolly Rani v. Manish Kumar Chanchal presents a complex legal dispute surrounding the validity of a Hindu marriage, the significance of marriage certificates, and the legal status of the parties involved. This case analysis explores the Supreme Court’s evaluation of several critical issues: the validity of the marriage under Hindu law, the legal significance of the marriage certificates and their registration, the marital status of the parties, and the resolution of related legal cases and the joint application. Through these deliberations, the Court aimed to clarify the legal standing of marriages conducted without proper ceremonial observances and the implications of such practices under Hindu law.

FACTS OF THE CASE

Both Dolly Rani and Manish Kumar Chanchal are trained commercial pilots. Dolly Rani and Manish Kumar Chanchal were engaged on March 7, 2021, and claimed to have solemnized their marriage on July 7, 2021.
They obtained a “marriage certificate” from Vadik Jankalyan Samiti (Regd.) and a “Certificate of Registration of Marriage” under the Uttar Pradesh Marriage Registration Rules, 2017. The actual marriage ceremony according to Hindu rites and customs was scheduled for October 25, 2022, but it did not take place.
Differences arose between the parties, and Dolly Rani alleged dowry demands and harassment by Manish Kumar Chanchal’s family. She filed an FIR under Sections 498A, 420, 506, 509, and 34 of the IPC and Sections 3 and 4 of the Dowry Prohibition Act, 1961.
On March 13, 2023, Manish Kumar Chanchal filed for divorce under Section 13(1)(ia) of the Hindu Marriage Act, 1955, in the Family Court, Muzaffarpur, Bihar.
Dolly Rani, residing in Ranchi, Jharkhand, sought to transfer the divorce petition to the Family Court in Ranchi, Jharkhand.
During the pendency of the transfer petition, both parties agreed to file a joint application under Article 142 of the Constitution of India. They sought a declaration that their marriage dated July 7, 2021, was not valid in the eyes of the law and that the marriage certificates issued were null and void. They admitted that no marriage was solemnized as per Hindu customs, rites, and rituals, and the certificates were obtained due to exigencies and pressures.
The Supreme Court emphasized the necessity of performing the requisite ceremonies for a valid Hindu marriage under the Hindu Marriage Act, 1955. The Court declared that a certificate issued without performing these ceremonies does not constitute a valid marriage. Consequently, the Court declared the marriage dated July 7, 2021, between the parties null and void and nullified the certificates issued. The Court observed that a Hindu marriage must be performed with proper and due ceremonies, and in the absence of such ceremonies, no marital status is conferred.

ISSUES RAISED

Whether the marriage between the petitioner and respondent valid?
Do the certificates issued regarding the marriage hold legal significance, and is the registration of the marriage under the Uttar Pradesh Marriage Registration Rules, 2017 valid?
Have the parties acquired the status of husband and wife under the Hindu Marriage Act, 1955?
Whether the registration of the marriage under the Uttar Pradesh Marriage Registration Rules, 2017 is valid?
Should the cases filed by the parties against each other be quashed, and should the joint application filed under Article 142 of the Constitution of India be allowed?

CONTENTIONS OF APPELLANT

The appellant argued that there was no valid marriage between the parties under the Hindu Marriage Act because the necessary ceremonies for a Hindu marriage were not performed.
Additionally, it was alleged that the respondent’s family made dowry demands, which caused differences between the parties. Despite this, the respondent filed a divorce petition under Section 13(1)(ia) of the Hindu Marriage Act, asserting the existence of a valid marriage. However, the appellant maintained that the marriage was not valid, making the grounds for the divorce petition false.
Furthermore, both the appellant and the respondent agreed to submit a joint application under Article 142 of the Constitution of India. This application sought several reliefs, including a declaration that the marriage was invalid and the dismissal of various cases filed by each party against the other.
Thus, the appellant’s main argument was that there was no valid marriage between the parties, and consequently, the divorce petition and other cases filed by the respondent should be dismissed.

CONTENTIONS OF REPONDENT

The respondent’s primary argument was that even though the marriage between the petitioner and respondent did not comply with the required Hindu marriage ceremonies, it was officially registered with the Registrar of Marriages. Consequently, the respondent contended that this registration granted legitimacy to their marital status despite the absence of traditional Hindu rites, thereby justifying the filing of the divorce petition.

JUDGEMENT

In its analysis of the transfer petition filed by the petitioner-wife, seeking to move the divorce proceedings to a different jurisdiction, the Supreme Court noted several key points. The Court observed that, although the parties claimed to be married, they had not fulfilled the necessary requirements for a valid Hindu marriage under Section 7 of the Hindu Marriage Act, 1955. Despite having obtained marriage certificates, the proper marriage ceremonies were not conducted, rendering these certificates null and void.

The Court emphasized the sacred and sacramental nature of Hindu marriage, highlighting the importance of performing the required ceremonies to solemnize the marriage. The Court criticized the trend of couples attempting to register their marriages without completing the essential rituals, warning against trivializing the institution of marriage.

Based on its analysis, the Court declared that the marriage between the parties was not valid under Hindu law. Consequently, the marriage certificates were declared null and void, and the parties were determined to have never attained the status of husband and wife. As a result, the divorce petition, maintenance case, and criminal case filed by the parties were quashed. In its judgment, the Court allowed the application filed under Article 142 of the Constitution, granting the relief sought by the parties. The transfer petition was disposed of, and any pending applications were resolved accordingly.

ANALYSIS

In the case of Dolly Rani v. Manish Kumar Chanchal, the Supreme Court of India addressed the crucial issue of the validity of a Hindu marriage in the absence of traditional ceremonies. The petitioner, Dolly Rani, sought to transfer a divorce petition filed by her husband, Manish Kumar Chanchal, and requested the quashing of several legal proceedings. The couple, both trained commercial pilots, initially obtained a marriage certificate from Vadik Jankalyan Samiti in 2021 and registered their marriage under the Uttar Pradesh Marriage Registration Rules, 2017. However, they did not perform the traditional Hindu marriage ceremonies, such as saptapadi, which led to significant legal and personal disputes, including allegations of dowry harassment by the petitioner.

The Supreme Court scrutinized the legitimacy of the marriage, emphasizing the necessity of performing the requisite rites and ceremonies as stipulated under Section 7 of the Hindu Marriage Act, 1955. The Court clarified that a marriage must be solemnized with proper ceremonies to be valid under Hindu law, and merely obtaining a marriage certificate without these ceremonies does not confer marital status. The Court criticized the practice of couples registering marriages without performing the essential rituals, stating that such actions trivialize the sacred institution of marriage. Consequently, the Court declared the marriage certificates issued to the parties null and void, as they were not supported by the necessary ceremonies.

Ultimately, the Supreme Court held that the marriage between Dolly Rani and Manish Kumar Chanchal was not valid under Hindu law, and thus, the parties had never acquired the status of husband and wife. The Court quashed the divorce petition, maintenance case, and criminal case filed by the parties against each other. This judgment underscores the importance of adhering to traditional marriage ceremonies in Hindu law and serves as a caution against bypassing essential rituals to obtain marital status. It reinforces the sacred nature of Hindu marriages, emphasizing that they are not merely legal formalities but solemn institutions requiring due ceremonies and rites.

CONCLUSION

The Supreme Court concluded that the marriage between the parties was not valid under Hindu law due to the lack of proper solemnization ceremonies. Consequently, the marriage certificates issued were declared null and void, and the parties were deemed never to have acquired the status of husband and wife. The Court quashed the divorce petition, maintenance case, and criminal case filed by the parties against each other. The application filed under Article 142 of the Constitution was allowed, granting the relief sought by the parties. The transfer petition and any pending applications were disposed of accordingly.

This judgment underscores the importance of performing the requisite ceremonies for a valid Hindu marriage and serves as a caution against the practice of bypassing essential rituals to obtain marital status.

REFERENCES

This Article is written by Poorna.R student of School of excellence in law, Chennai; Intern at Legal Vidhiya.

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