Rathnamma v. Sujathamma
“Registration of Marriage Agreement Alone Does Not Prove Valid Marriage”
TL;DR
The Supreme Court held that mere registration of an agreement of marriage is not sufficient to prove a valid marriage. Under Section 7 of the Hindu Marriage Act, marriage must be solemnized according to customary rites and ceremonies.
The Bottom Line
Registering a marriage agreement is not the same as a valid marriage. You must actually perform marriage ceremonies as per your customs to have inheritance rights as a spouse.
Case Timeline
The journey from FIR to Supreme Court verdict
Alleged Marriage
Sujathamma claims to have married Hanumanthappa
Alleged Marriage
Sujathamma claims to have married Hanumanthappa
Death of Hanumanthappa
Hanumanthappa died, triggering inheritance dispute
Death of Hanumanthappa
Hanumanthappa died, triggering inheritance dispute
Partition Suit Filed
Sujathamma claimed share in deceased husband's estate
Partition Suit Filed
Sujathamma claimed share in deceased husband's estate
Trial Court Decision
Trial court found no valid marriage proved
Trial Court Decision
Trial court found no valid marriage proved
First Appellate Court
Reversed trial court and held marriage valid
First Appellate Court
Reversed trial court and held marriage valid
High Court Decision
Reversed appellate court, upheld trial court
High Court Decision
Reversed appellate court, upheld trial court
Supreme Court Judgment
Upheld that no valid marriage was proved
Supreme Court Judgment
Upheld that no valid marriage was proved
The Story
Sonnappa was the propositus (ancestor) who owned the properties in dispute. He had two sons, one of whom was Hanumanthappa. Sujathamma (the respondent) claimed to have married Hanumanthappa on 7th March 1986. Hanumanthappa died on 15th October 1986.
Sujathamma claimed she was entitled to inherit her deceased husband's share in Sonnappa's estate. However, the marriage was challenged by the other family members (Rathnamma and others).
The trial court found that at the time of the alleged marriage, Hanumanthappa was only 19 years 9 months old, and Sujathamma was 15 years old. Neither had attained the legal age for marriage. More importantly, the only evidence of marriage was a registered "agreement of marriage" - there was no evidence of any marriage ceremony being performed.
The registered agreement merely stated that both parties were of the same caste and had agreed to marry with their fathers' consent. The question was whether this constituted a valid marriage under Hindu law.
Legal Issues
Click each question to reveal the Supreme Court's answer
Arguments
The battle of arguments before the Supreme Court
Petitioner
Vihaan Kumar
No valid marriage ceremony performed
The appellants argued that there was no evidence of any marriage ceremony being performed. Only an "agreement" was registered, not a marriage.
Underage parties
Both Hanumanthappa and Sujathamma were below the legal age for marriage at the relevant time.
No customary rites proved
No evidence of Vokkaliga community custom allowing marriage without ceremonies was presented.
Respondent
State of Haryana
Marriage was registered
Sujathamma argued that the registration of the marriage agreement proved the marriage.
Community custom
Claimed that in the Vokkaliga community, such agreements constitute valid marriage.
Court's Analysis
How the Court reasoned its decision
The Supreme Court examined Section 7 of the Hindu Marriage Act, 1955, which requires that a Hindu marriage be solemnized in accordance with customary rites and ceremonies. The Court found no evidence of any ceremony being performed - only an agreement to marry was registered.
In the agreement of marriage, it was only stated that both parties are of the same caste and with the permission and consent of both of their fathers, they entered into the agreement.
Para Para 12
The document was merely an agreement, not evidence of marriage ceremony.
This type of marriage is not recognized in law as Section 7 of the Act contemplates that marriage can be solemnized in accordance with customary rites and ceremonies.
Para Para 15
Section 7 requires actual performance of customary rites.
In the absence of any precedent or custom of such marriage, no judicial notice could be taken of a custom. The argument that in the Vokkaliga community such marriage can be performed was not accepted as no judicial precedent was brought to the Court's notice.
Para Para 18
Custom must be proved, not merely asserted.
The Verdict
Relief Granted
Sujathamma's claim to inherit from Sonnappa's estate as widow of Hanumanthappa rejected.
Directions Issued
- Registration of marriage agreement does not prove valid marriage
- Section 7 HMA requires solemnization according to customary rites
- Custom claimed must be proved with evidence
- Respondent not entitled to inherit as she failed to prove valid marriage
Key Legal Principles Established
Registration of marriage agreement is not proof of valid marriage
Hindu marriage must be solemnized with customary rites and ceremonies (Section 7 HMA)
The essential ceremony for most Hindu marriages is Saptapadi (seven steps before sacred fire)
Custom must be proved, not merely asserted without evidence
Inheritance rights as spouse depend on proof of valid marriage
Key Takeaways
What different people should know from this case
- Simply registering a marriage agreement is not enough - you need to actually perform marriage ceremonies
- For a Hindu marriage, ceremonies like Saptapadi (seven steps around fire) are required
- If you claim a custom allows different ceremonies, you must prove that custom exists
- Without a valid marriage, you cannot claim inheritance rights as a spouse
Legal Framework
Applicable laws and provisions
Statutory Provisions
Section 7
Hindu Marriage Act, 1955
“(1) A Hindu marriage may be solemnized in accordance with the customary rites and ceremonies of either party thereto. (2) Where such rites and ceremonies include the Saptapadi (that is, the taking of seven steps by the bridegroom and the bride jointly before the sacred fire), the marriage becomes complete and binding when the seventh step is taken.”
Relevance: Mandates solemnization with customary rites for valid Hindu marriage.
Section 13
Indian Evidence Act, 1872
“When the question is whether any person had a special right, custom, or usage, evidence of particular instances is relevant.”
Relevance: Governs how customs must be proved in court.
Related Cases & Precedents
Bhaurao v. State of Maharashtra
cited(1965) 2 SCR 837
On essential ceremonies for valid Hindu marriage.
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