In a detailed ruling delivered on January 19, 2026, the Telangana High Court stepped in to correct what it called a basic legal mistake by a Family Court in Nizamabad. The Division Bench held that the Hindu Marriage Act, 1955 cannot be used to recognise or enforce a marriage when one of the parties belongs to a Scheduled Tribe, unless the Central Government has issued a specific notification extending the law. Setting aside the Family Court’s 2014 order, the High Court declared the alleged marriage void in law.
Background of the Case
The case arose from a family court appeal filed by a woman who was pursuing her dental studies when the dispute began. She told the court that a man from her locality had repeatedly contacted her, followed her, and later forced her to travel with him under threats, including a claim that he would attack her with acid. According to her, she was taken to different places, made to sign papers, photographed at a temple, and was later shown a “marriage certificate” that she never consented to.
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When she finally informed her family, she approached the police and moved the Family Court seeking to dissolve the alleged marriage. Her clear stand was that whatever happened on May 9, 2012 was under threat and fear, not free choice.
The man denied these allegations. He claimed they were in love, that they had married with mutual consent under the Hindu Marriage Act, and that the marriage was even consummated. He relied on photographs and letters to support his version and argued that the woman’s family later opposed the relationship because of caste differences and his job.
The Family Court believed his version and dismissed her petition in July 2014, holding that she failed to prove force or cruelty.
On appeal, the High Court focused on a more basic question: did the Hindu Marriage Act even apply to this couple?
The woman belongs to a Scheduled Tribe, while the man belongs to a Scheduled Caste. The Bench pointed out that Section 2(2) of the Hindu Marriage Act clearly says the law does not apply to members of Scheduled Tribes unless the Central Government issues a notification saying otherwise.
Framing the core issue, the court noted that “the applicability of a personal law statute flows from legislative mandate and not from the choice or conduct of the parties.” In simple terms, even if two people perform a ceremony or register a marriage, that cannot override what the law itself allows or forbids.
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Court’s Observations
The judges were blunt in their assessment. They observed that registering a marriage or performing rituals “cannot validate what the statute expressly excludes.” The court added that if someone from a Scheduled Tribe is to be treated as governed by Hindu personal law, there must be clear pleading and proof that the person has given up tribal customs and is following Hindu customs. No such evidence was produced in this case.
Quoting earlier Supreme Court and High Court rulings, the Bench underlined that customs must be specifically pleaded and strictly proved.
“Mere performance of marriage according to Hindu rites,” the court said, “is legally insufficient.”
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The High Court also found fault with the Family Court for not even deciding this basic issue of whether the Hindu Marriage Act applied before going into the facts.
“When jurisdiction itself depends on statutory applicability, skipping that question makes the entire exercise legally flawed,” the Bench remarked.
Decision
Allowing the appeal, the High Court set aside the 2014 Family Court order. It declared that the alleged marriage, insofar as it was sought to be recognised under the Hindu Marriage Act, is “void and unenforceable in law.” There was no order as to costs, and all pending applications in the appeal were closed.
With this, the court drew a clear line: personal law statutes cannot be stretched by ceremonies or paperwork when the law itself says they do not apply.
Case Title:- X & Y
Case Number:- Family Court Appeal No. 195 of 2014
Bench: Justice K. Lakshman and Justice Vakiti Ramakrishna Reddy
