Sitabai vs Ramchandra
● Court: Supreme Court of India
● Citation: AIR 1986 SC 1807
● Facts:
Sitabai was married to Ramchandra according to the customs followed by their community, which did not involve formal statutory procedures prescribed under Hindu law, such as the Saptapadi (the seven steps during the marriage). Despite the marriage being recognized by their community, the lack of statutory rituals made it legally ambiguous. Ramchandra later denied the existence of a valid marriage, contending that since no formal rituals were performed, Sitabai had no claim to any rights that a legally married woman would have.
Sitabai, however, argued that the marriage was valid based on community customs and that she should be entitled to maintenance as a wife under Section 125 of the Criminal Procedure Code (CrPC), which provides for maintenance to wives, children, and parents who are unable to maintain themselves. She maintained that regardless of whether the marriage followed formal procedures or not, the essence of their union, recognized by the community, entitled her to maintenance.
Ramchandra's defense was based on the argument that a marriage without formalities under the Hindu Marriage Act could not be considered legally valid and that since the marriage wasn’t legally valid, Sitabai had no right to maintenance. This raised important questions about whether a marriage recognized by a community but not by statute could still have legal implications.
● Issues:
1. Whether a marriage conducted according to community customs, but without statutory formalities, can be considered legally valid.
2. Whether a woman in such a marriage can claim maintenance under Section 125 of the CrPC.
● Relevant Articles:
Article 14: Equality before the law.
Article 21: Protection of life and personal liberty.
● Judgment:
The Supreme Court held that a marriage performed under customary rites, even without following statutory formalities, was valid if the community recognized it. The Court ruled in favor of Sitabai, stating that a wife could not be denied maintenance under Section 125 of the CrPC merely because the marriage did not follow the formal statutory procedures. The Court emphasized that the primary objective of the maintenance provision was to protect women and prevent their exploitation, particularly when they were unable to maintain themselves.
Harinya
Commentaires