Doly Rani (Dolly Rani) vs. Manish Kumar Chanchal
Background
The petitioner-wife sought to transfer her husband's divorce petition from a Bihar family court to Jharkhand. During the case, the couple, both commercial pilots who had never actually performed a wedding ceremony but had obtained a "marriage certificate" from a private organisation and then registered it as a "Hindu marriage": jointly asked the Supreme Court to declare under Article 142 of the Constitution that no valid marriage had ever taken place between them, and to close all related cases (an FIR under dowry/cruelty laws, a maintenance case, and the divorce petition itself).
Decision Breakdown
The Supreme Court explained that under Section 7 of the Hindu Marriage Act, a marriage is only "solemnised" if actual customary rites and ceremonies (such as the seven steps/saptapadi) are performed: a mere registration certificate, without any ceremony, cannot create a valid Hindu marriage. Since both parties admitted no ceremony was ever performed, the Court declared the "marriage" and both certificates null and void, held the parties were never legally husband and wife, and used its Article 142 power to quash all three connected proceedings (the divorce case, the maintenance case, and the criminal case) in one go. The Court also cautioned strongly against the growing practice of couples registering a "marriage" for convenience (e.g., visas) before actually performing the ceremony.
Lesson Learnt
Registering a marriage on paper is not enough to make it legally valid under Hindu law: the actual customary ceremony must be performed; without it, no marriage (and none of its legal consequences) exists.