MP High Court Rules Arya Samaj Certificate Insufficient Proof of Marriage Without ‘Saptapadi’; Says Marriage Not Mere ‘Song and Dance’

The Madhya Pradesh High Court has delivered a significant judgment regarding the validity of Hindu marriages, ruling that a marriage certificate issued by an Arya Samaj temple is not conclusive proof of marriage if the essential ceremony of ‘Saptapadi’ (seven steps around the sacred fire) has not been performed. The Gwalior Bench, comprising Justice Anand Pathak and Justice Hirdesh, set aside a Family Court order and declared that the respondent woman was not the legally wedded wife of the plaintiff, as the mandatory rituals under the Hindu Marriage Act, 1955, were not established. Case Background The court was hearing a first appeal filed by a man (the plaintiff) who sought a declaration that the respondent was not his legally wedded wife. The plaintiff contended that the respondent had obtained a "fake and forged" marriage certificate from an Arya Samaj Mandir in Gwalior dated March 26, 2012. He further alleged that no traditional marriage rituals, specifically Saptapadi, were performed, and thus, under Hindu Law, the marriage was invalid. The respondent, however, argued that the marriage was solemnized according to Vedic rituals and produced the Arya Samaj certificate and municipal registration as proof. The Court’s Observation In its detailed order, the High Court emphasized that under Section 7 of the Hindu Marriage Act, 1955, a Hindu marriage must be solemnized in accordance with the customary rites and ceremonies of the parties. The court noted that Saptapadi is a sine qua non (essential condition) for a valid Hindu marriage. The Bench observed that while the respondent produced a certificate and witnesses, there was "not even a whisper" in their testimonies regarding the actual performance of Saptapadi. Quoting the recent Supreme Court judgment in Dolly Rani v. Manish Kumar Chanchal, the High Court reiterated that a marriage certificate is merely a proof of the factum of marriage but does not validate a marriage that lacks essential ceremonies. "In Hindu religion, marriage is a sacrament and has a sacred character. Marriage is not an event for mere 'song and dance' or 'wining and dining'. Hindu marriage is conducted as per Vedic procedure... Any Hindu marriage solemnized in accordance with Vedic procedure constitutes a valid marriage if it fulfills requirements of Section 7 of Hindu Marriage Act," the Court remarked. The Verdict The High Court held that the mere issuance of a certificate by the Arya Samaj or the Municipal Corporation cannot confer the status of husband and wife in the absence of proof of rites. Consequently, the Court allowed the appeal, set aside the Family Court's judgment, and granted a decree declaring that the respondent is not the legally wedded wife of the appellant. This judgment serves as a reminder that the legal sanctity of a Hindu marriage lies in its rituals, not just in its registration documents.