In a significant ruling, the Allahabad High Court has held that a Hindu marriage performed in an Arya Samaj Mandir, if solemnized in accordance with Hindu rites and customs, constitutes a valid marriage under the Hindu Marriage Act, 1955.

The Court emphasized that the location of the ceremony is irrelevant under Section 7 of the Act—it is the performance of customary rites, such as Saptapadi and Panigrahan, that determines the legality of the marriage. While registration enhances evidentiary value, its absence does not invalidate a properly solemnized Hindu marriage.

The observations came from Justice Arun Kumar Singh Deshwal, who dismissed a plea by one Maharaj Singh seeking to quash criminal proceedings initiated by his wife in a dowry harassment case. Singh contended that their marriage, conducted in an Arya Samaj temple, was not legally valid and that the certificate issued by Arya Samaj held no statutory weight.

Rejecting these arguments, the Court clarified that **a marriage performed in Arya Samaj Mandir as per the Vedic procedure—**including Kanyadan, Panigrahan, Saptapadi, and Vedic chants—is a valid Hindu marriage under Section 7 of the Act. The Court acknowledged that while Arya Samaj marriage certificates are not statutory, they are not without evidentiary value, especially when verified by the priest who performed the ceremony under the Bharatiya Sakshya Adhiniyam, 2023.

The High Court also referred to the Supreme Court's decision in Dolly Rani v. Manish Kumar Chanchal (2025), reiterating that registration under Section 8 only aids in proving marriage but does not grant legitimacy to a marriage not otherwise valid under Section 7.

In this case, the wife had filed an FIR under Sections 498A and 506 of the IPC, alleging cruelty by the husband post-marriage. While the husband claimed the Arya Samaj certificate was forged, the Court noted that both the complainant and the priest confirmed that Vedic rituals were indeed performed.

Addressing the allegation of cruelty, the Court referred to the Supreme Court’s recent ruling in Aluri Venkata Ramana v. Aluri Thirupathi Rao, which clarified that the absence of a dowry demand does not negate a 498A offence if other forms of cruelty are established.

As a result, the Court declined to quash the criminal proceedings under its inherent powers under Section 482 CrPC and dismissed the husband’s application on April 8, 2025.

Case Title: Maharaj Singh v. State of U.P. and Another