Registration of marriage cannot validate a union where essential Hindu rites and ceremonies are not performed.

The appellant, residing in the UK, challenged a registered marriage certificate presented by the defendant, claiming no marriage was ever solemnized nor rites performed

He alleged his signatures were obtained through fraud or inducement

In her written statement, the defendant admitted that no Hindu rites or rituals occurred and that no lawful marriage existed

Despite this admission, the Family Court, Ahmedabad, rejected an application for a decree on admission and dismissed the suit, holding that a registration certificate raises a presumption of validity regardless of the admission, thus requiring a full trial

1. Whether the Family Court was justified in rejecting an application for a decree on admission when the defendant categorically admitted that no lawful marriage was solemnized

2. Whether the mere existence of a marriage certificate under Section 8 of the Hindu Marriage Act, 1955, creates a valid marriage if essential ceremonies under Section 7 are admittedly absent

The court applied Section 7 of the Hindu Marriage Act (HMA), 1955, which mandates that a Hindu marriage must be solemnized via customary rites, specifically stating that a marriage involving Saptapadi is complete only upon the seventh step

It further applied Section 8 of the HMA, 1955, noting that registration is merely for facilitating proof of a marriage already validly solemnized and does not independently confer validity

The court also relied on the principle from Rathnamma & Ors. v. Sujathamma & Ors. (Civil Appeal No. 3050 of 2010), which established that registration alone is insufficient to prove a marriage

The High Court reasoned that under Hindu Law, marriage is a samskara (sacrament) requiring actual solemnization per Section 7

Since the defendant unequivocally admitted in her pleadings that no ceremonies took place and no husband-wife relationship existed, the legal presumption of a valid marriage arising from registration was effectively rebutted

The Court found the Family Court erred by treating the marriage certificate as an irrebuttable proof necessitating a trial; rather, since the "foundational fact" of solemnization was admitted to be absent, no legal status could flow from the certificate

The High Court quashed the Family Court’s order dated 13.11.2025, allowed the appeal, and declared the alleged marriage null and void ab initio

The appellant was granted liberty to approach competent authorities for the cancellation of the marriage registration and certificate