The Author, Kumar Satyam is a Second-year B.A.LL.B. (Hons.) student at the Maharashtra National Law University, Nagpur.
INTRODUCTION
Marriages in India has been a sacred union of two people irrespective of the the religious faith you believe in. Recent cases have been recorded where new type of marriages have emerged in India where the groom abandon the bride in lieu of NRI marriages, commonly known as the Abandoned Brides: Neither a widow nor a wife. NRI brides’ cases often come with dowry issues and many problems. Though cases get registered, it gets quite difficult to seek justice due to a lack of legal support. Honour Killing, a prevalent culture in India, presents such cases where it is quite challenging to prove the subjectivity regarding the identity of the bride and groom after the murder, as usually, families disown such cases, and a lack of literacy regarding registration can lead to a lack of evidence.
A properly structured law on the registration of marriage can solve many other problems where the victims are unable to seek justice. Legal hurdles like same-sex marriage, honour killing and fraud. Paper would include the extensive study of the marriage fraud which later becomes hurdles for the individual in the marriage to prove. “Burden of Proof” makes it difficult for one partner to avail for justice and a remedy.
Country can have a national database for the whole country to compulsory register their marriages to significantly make it effective for the judiciary to fast track the matrimonial cases.
REGISTRATION OF MARRIAGE
Registration of the marriage simply denotes the registration of a couple as a legal couple, but it is a social contract per say where both consenting parties come together to validate the union between themselves in front of law. Though registration of a marriage is the thing which some or the other way violates the privacy of a personal bond, but in the modern times where complexity between relationship is changing specially in India where booming population is now getting aware about their legal rights and legal duties. Registration of anything is omnipotent, data is the new gold. One of the biggest things which is absent from the public forum are the registration of marriages between two parties[1]. One of the crucial things which India celebrate but fail to record on a piece of paper. Evidence is the fuel of the court which runs the everyday proceeding, same happened in the case of D. Velusamy vs. D. Patchaiammal (2010)[2] where D. Patchaiammal (the woman) claimed maintenance from D. Velusamy, stating they were married. Velusamy denied it, claiming he was already married to another woman named Lakshmi. Patchaiammal had no marriage certificate to prove her own marriage. The case went all the way to the Supreme Court. The court had to decide if Patchaiammal was a "wife" or a "mistress," as a "mistress" is not entitled to maintenance. Because there was no certificate, the court had to delve into complex factual questions:
- Did they live together for a significant time?
- Did they present themselves to society as husband and wife?
- Were they of legal age to marry?
The Supreme Court set a high standard, ruling that not all live-in relationships are "relationships in the nature of marriage." It sent the case back to the lower court for a fresh trial to determine if the relationship met these strict criteria. This meant that years after her initial plea, the woman was still at square one, trying to prove she was a wife instead of just getting the maintenance she needed[3]. A certificate would have settled this issue on day one.
But it would have been avoided if she was already aware of the marital status of her partner or if their earlier intervention of the authorities to curb this fraudulent act. One of the best examples to prevent these types of instances have been shown by France, a classic example. By law, a couple must be married in a civil ceremony at the town hall (Marie) before they can have any religious ceremony. A priest or religious leader who performs a wedding for a couple before their civil registration can face legal penalties.
Function and Historical Context
Function of the marriages are seen to provide stability in the life of a person as per the popular belief in the society. Though post marriages problem is still a matter a taboo in India, due to the cultural belief of the wedlock decided in heaven before birth. Though it is not clear when the human started a wedlock within small groups but a certainty lies in the time when humans started forming clans and settled for farming[4]. One of the primary reasons for the wedding was the procreation. Marriage was made to prolong a dynasty or a family legacy but later it changed into something more of an emotional connection, where it became a social need to commit your life to single person[5].
Hinduism: A religion being the one of the oldest religions, introduced wedding more of a spiritual connection to God. In Hinduism, marriage is a sacred institution that forms a lifelong spiritual bond between two individuals, going beyond a union of just the couple to encompass their families and society. It's governed by the Hindu Marriage Act of 1955, which outlines the rules and rituals for a valid marriage. The ceremony itself is steeped in tradition, with rituals like the Saptapadi symbolizing the couple's journey together[6].
In India, marriage registration is mandatory, providing legal recognition and serving as crucial proof of marriage. This registration helps prevent social issues like child marriages and bigamy. The process involves submitting an application along with required documents, after which a marriage certificate is issued, offering protection and rights to the couple under the law. Registration under the Special Marriage Act also allows for interfaith marriages, providing a legal framework for unions beyond religious boundaries[7].
Islam: It has the system of validating a marriage as a social contract but it stays within the religion ambit where only a Maulana deems a wedlock as a contract without any formal paper work, though have been instances of the Nakahama during the wedding but it is not validating marriage record but a personal contract for the parties, more of a promissory contract in eyes of the God[8]. Though the function of marriages in Islam in the early phases was to procreation and a solemn duty to work for the growth of the religion. Though popular perception of the marriages under Islam is still a matter of controversies whether it is 4 wives (formal marriages), Talaq system (now illegal in India) and marital remedies. Though here also wedlock has been decided by God[9].
Christian Wedding: It has the same system like all the recognised religion in India, here a father would validate a marriage. Though Christian wedding is one of the first wedding where traces of the registration can be found through the validation of a clergy or a registrar. In India one of the leading examples would the Christian wedding in colonial era where it was properly registered by a clergy or the registrar[10].
Parsi: Marriages in the Parsi community in India are rich in tradition and are governed by a specific secular law, the Parsi Marriage and Divorce Act, 1936[11]. The ceremony itself, known as the 'Ashirvad', is a central and essential component. It is a religious ceremony performed by a Parsi priest (or mobbed) and must take place in the presence of at least two Parsi witnesses. During the Ashirvad, the couple sits facing each other, often separated by a cloth, and the priest recites prayers and blessings in Avesta and Pazand, showering the couple with rice and rose petals to symbolize prosperity and happiness. The ceremony, which is deeply symbolic, includes rituals like Ara Antar (separation of the couple by a cloth) and Chero Bandhvanu (tying a sacred string around the couple seven times)[12].
Regarding the legality of registration, the Parsi Marriage and Divorce Act, 1936 is very clear and strict. Registration is not just an option; it is a mandatory legal requirement that is integrated into the ceremony itself. According to Section 6 of the Act, immediately after the solemnization of the marriage, the officiating priest is legally required to certify the marriage in a specific form (Schedule II of the Act). This certificate must be signed by the priest, the contracting parties (the couple), and the two Parsi witnesses[13].
Other religion like Jews and many more also celebrate the selective autonomy of the registration of their respective wedlock according to their will. But here lies the problem that while making the laws, nation’s forefather wanted to keep the new laws balanced on either side. Making registration compulsory was not a good idea at that time due to its nature, where state is indirectly involved in marriage which was still a matter of taboo[14].
Importance In Today’s World
Registration is a powerful tool for dismantling deep-seated gender inequalities. Registration creates an official, searchable record of a man's marital status. This makes it significantly harder for a husband to abandon his wife and children and later deny the marriage or illegally marry another person (bigamy)[15]. In a patriarchal society, an unregistered marriage allows a husband to simply "disown" his wife, leaving her with no social or legal recourse[16]. A marriage certificate instantly validates her status as a "wife," shifting the legal power dynamic. She is no longer just a woman he lived with; she is his legal spouse with enforceable rights. The registration process requires official verification of age (21 for males, 18 for females)[17]. This acts as a direct legal barrier against child marriage, as a registrar would be legally bound to reject an application involving minors[18].
Is it a social contract?
A marriage certificate is the primary document required to claim a vast array of legal and financial rights that are often denied to women. In the event of a separation or divorce, a wife's claim for maintenance for herself and her children rests on her ability to prove she is legally married. The certificate is conclusive proof, eliminating the long, expensive, and emotionally draining court battle of having to prove the marriage even happened[19].
Upon a husband's death, the marriage certificate is the key document for the widow to claim her share in his property, assets, pension, and insurance benefits. Without it, relatives can easily challenge her claim, attempting to disinherit her and her children[20]. The certificate legally establishes the paternity of children born from the marriage. This is crucial for securing their rights to inheritance, maintenance, and custody, ensuring they are not unfairly deemed "illegitimate.[21]" While the Domestic Violence Act protects women in live-in relationships as well, a marriage certificate strengthens a woman's case significantly. It establishes her undeniable right to reside in the "matrimonial home," preventing her from being illegally thrown out by her husband or in-laws.
The act of registration is, in itself, an act of awareness and a formal declaration to the state. It elevates the marriage from a private, family affair to a public, legal contract recognized by the state. This creates social and legal awareness that the two individuals now have legally binding responsibilities toward each other.
- Deters Fraudulent Marriages: It acts as a major deterrent, especially in cases of fraudulent marriages with NRIs (Non-Resident Indians) where a spouse is abandoned after moving abroad. Registration provides a verifiable legal address and identity, which is crucial for initiating any legal action[22].
- Educates on Legal Age: The process itself educates the public about the legal minimum age for marriage, reinforcing that child marriage is a crime.
A marriage certificate is the single most important document that transforms a woman's status from a position of social dependency to one of a legally-recognized individual with a full suite of enforceable rights. It is the first and strongest line of defence against abandonment, disinheritance, and the denial of her and her children's dignity[23].
INHERENT FLAWS AND SHORTCOMING OF THE CURRENT LAWS
When a news takes an international flavor then it takes a wide turn and internally questions the sanity of the law of the land, this happened when subsequent articles were published one after the another by The New York Times, Times magazine and The Guardian about a mammoth number of around 50 thousands (still a figure of dispute between different publication), news covered the condition of the abandoned bride by their NRI husbands just after marriage, some even having a totally different wife and children in the country they work[24]. Laws are weak to figure the real numbers but it can increase more in near future as the phenomenon was discovered in last year[25]. Passport and immigration paper usually ask about the marital status of the person who is travelling abroad but the airline requires registered paper of a legal marriage but these husbands usually flee the country right after the wedding day to escape any paper work and wedding problem[26]. The Government of India can’t take legal action as many of these weddings are just done to save reputation or to transfer the girl as a burden from one place to another. Birde usually don’t claim any compensation as divorce are near to impossible and social bond won’t allow this because the cases are usually found in the villages and tier-3 towns of the North Indian State like Punjab, Haryana[27]. Lack of registration left this bride stranded in wait of their spouse for years, some even waiting for 20-30 years. These women can’t legally divorce or remarry as for divorce, we need 2 parties to sign on the divorce paper and to remarry they need a divorce as the religious custom and law don’t allow them to do so.
THE BETTER INDIA, a solution-based media platform, which did a detail interaction with these brides evidently prove the point a Unified marriage registration[28]. Where many brides used to only receive stories and remuneration of their husband from the abroad. Authority in practicality can’t do anything due to limitation of the international borders. Problems and confessions like this explain the gravity of the issue which have been already solved by many of the nation’s smaller than India, example of The German Civil Code (Bürgerliches Gesetzbuch or BGB), specifically Sections 1303-1320, and the Civil Status Act (Personenstandsgesetz or PStG) where[29], the law states that a marriage is only concluded when the parties declare their intent before a civil registrar (Standesbeamte). Religious ceremonies are legally considered private celebrations[30].
One of the other problems which many of us think has vanished is the child marriages in rural and tier-3 towns which is very prevalent for till now, while the practice is banned and illegal to perform, the resulting marriage itself is typically voidable to protect the rights and choices of the minor involved[31]. Kriti Bharti, activist from a NGO called Saarthi, says Rural Rajasthan have succussed in evading the law[32]. For example, “marriage ceremonies for underage persons will be held at night, with small groups of people attending”[33]. This reduces the chance of alerting authorities. Once the marriage has taken place, the bride will stay with the parents till she attains puberty to avoid any suspicion. Even if the authorities have been tipped off, the families can deny any of the charges of child marriages. Bharti states in addition to this, “in some parts of India, authorities are not always interested and child marriage may be accepted as a part of the culture[34].”
Hurdle of the new policy implementation
Implementing a new policy for compulsory marriage registration in India faces significant hurdles, especially when viewed through the lenses of the Uniform Civil Code (UCC), population size, tribal customs, and religion.
1. Uniform Civil Code (UCC) Perspective
- Association and Resistance: Compulsory marriage registration is often seen as a foundational step towards, or a component of, a potential Uniform Civil Code. This association itself is a major hurdle. Groups opposed to the UCC, fearing it will override their religion-based personal laws on marriage, divorce, and inheritance, may strongly resist mandatory registration, viewing it as an infringement on their religious freedom and the first step towards imposing uniformity they oppose[35]. Marriage under the Uniform Civil Code (UCC) in places like Uttarakhand requires mandatory registration for all couples, sets a minimum marriage age of 21 for men and 18 for women, and bans polygamy, child marriage, and practices like triple talaq and iddat[36]. It also gives women equal rights in matters of property and inheritance. Couples who fail to register their marriage will not receive government benefits[37].
- Defining 'Marriage' Uniformly: Before a full UCC, a compulsory registration policy would have to grapple with the diverse definitions and validity criteria for marriage under existing personal laws (Hindu, Muslim, Christian, Parsi, etc.) and the Special Marriage Act. Deciding what constitutes a "marriage" eligible for registration that respects all traditions while being legally sound under a compulsory framework is complex.[38]
2. Population Perspective
- Scale and Logistics: India's sheer population size (over 1.4 billion) makes nationwide implementation a monumental logistical challenge. Establishing accessible registration offices, training personnel, creating digital infrastructure, and ensuring compliance across vast rural and remote areas require immense resources and efficient administration, which may be lacking.
- Awareness and Literacy: A significant portion of the population, particularly in rural or marginalized communities, may lack awareness about the need for registration or the procedures involved. Illiteracy and limited access to information can make compliance difficult, potentially leading to unintentional non-registration and subsequent legal issues for citizens.
- Migration: High rates of internal migration mean people often marry away from their place of birth or permanent residence. A rigid registration system tied to specific jurisdictions could create difficulties for migrant couples in accessing registration services or producing required local documentation.
3. Tribal Custom Perspective
- Diversity and Non-Codification: India has numerous tribal communities (Adivasis) with unique and diverse customary marriage practices, many of which are uncodified and differ vastly from mainstream religious or civil laws. Forcing these marriages into a standardized registration format might fail to recognize their validity or could conflict directly with established customs.
- Autonomy and Fear of Assimilation: Many tribal communities value their autonomy and distinct cultural identity, often protected under constitutional provisions (like Schedule 5 and 6). Mandatory registration might be perceived as an imposition by the state, potentially eroding their unique traditions and pushing them towards mainstream norms they do not follow.
- Accessibility and Documentation: Tribal areas are often remote with limited access to government offices. Furthermore, customary tribal marriages might not involve the kind of documentation (like specific identity proofs, formal invitations, or priest certificates) typically required for registration, creating practical barriers.
4. Religion Perspective
- Interference in Personal Laws: Religious communities, particularly minorities, often view marriage as a sacred institution governed primarily by their religious laws and traditions (e.g., Nikah in Islam, rites under Christian or Parsi law). Compulsory registration by the state can be seen as an intrusion into these personal laws, potentially undermining the religious solemnization as the primary validation of the marriage.
- Validity Concerns: Some may fear that the state registration, rather than the religious ceremony, could become the sole determinant of marital validity, thereby diminishing the role of religious institutions and officiants. Questions might arise about the status of marriages valid under religious law but not registered.
- Practical Implementation: Different religions have varying procedures and officiants. Designing a registration system that respects the role of diverse religious authorities (priests, imams, ministers) while ensuring legal compliance can be challenging. There might be resistance from religious bodies if they are burdened with administrative registration duties.
Case Study: Abandoned Bride
"Amanpreet," a 22-year-old from a village in Punjab, was excited when a proposal came from "Raj," a 27-year-old living and working in the UK. Raj's family, residing locally, presented him as well-settled. Due to a lack of awareness about the potential risks associated with NRI marriages and the critical importance of legal documentation, Amanpreet's family focused on the social status the match would bring. They didn't thoroughly vet Raj's background or insist on immediate civil registration of the marriage. The wedding was a grand affair, performed according to religious customs, financed heavily by Amanpreet's family's savings and loans.
Raj stayed in India for only four weeks after the wedding. He returned to the UK, promising to start Amanpreet's visa process immediately. Initial communication was regular, but soon became infrequent and then stopped altogether. When Amanpreet's family contacted Raj's parents, they feigned ignorance and eventually became hostile.
Amanpreet's family discovered through distant contacts that Raj might have been previously married or in a relationship in the UK. Crucially, Raj had travelled back on his passport which still listed him as 'single'. The religiously conducted marriage in India had no immediate bearing on his official status recorded in his travel documents or likely, in the UK. This discrepancy made his deception easier to maintain abroad.
Without a civil marriage certificate, establishing the marriage legally became her first hurdle. She had photos and witnesses, but no single, state-recognized document. She was married in the eyes of her community, but effectively abandoned. Seeking a divorce proved almost impossible. Raj was in the UK, unreachable, and unwilling to participate in any legal proceedings. Serving him legal notice internationally was complex and costly. Without the participation (or even traceable location) of the other party, Indian courts struggled to proceed with a contested divorce. Filing for an ex-parte divorce (where one party is absent) was also fraught with procedural difficulties, especially given the lack of a registration certificate and the international element. Amanpreet couldn't legally remarry without a divorce decree. She wasn't single, nor a widow, nor legally divorced. She was trapped in an "invisible marriage," facing social stigma and unable to move forward with her life, highlighting how the lack of one party effectively paralyzes the standard legal remedy of divorce.
Amanpreet's situation exemplifies how a lack of awareness regarding legal safeguards like registration, coupled with practical issues like inaccurate passport details and the near impossibility of pursuing legal remedies like divorce when one spouse abandons the other internationally, creates a perfect storm for abandoning brides. The marriage exists socially but dissolves legally and practically, leaving the woman stranded without rights, recognition, or a clear path forward.
SPECIAL MARRIAGE ACT: A WAY AROUND
The SMA provides a working framework where registration is not just an add-on but an integral part of the marriage solemnization itself. Couples marrying under the SMA must follow a civil process involving notice, potential objections, and finally, solemnization before a Marriage Officer, culminating in the issuance of a legally binding marriage certificate. This demonstrates that a secular, state-regulated marriage process with inherent compulsory registration has existed and functioned within India's legal system for decades. It's a proven blueprint[39].
The SMA offered the first truly secular pathway to marriage, bypassing religious rituals and personal laws. Initially used primarily for inter-religious or inter-caste couples who faced societal hurdles, its very existence provided a legal sanctuary for unions based on individual choice rather than community dictates. As more couples (especially in urban areas and those challenging traditional norms) opt for the SMA, the idea of a state-registered marriage gains visibility and gradual acceptance[40]. While not yet the norm nationwide, its increasing use signifies a slow shift towards recognizing marriage as a legal contract requiring state validation, alongside its social and religious dimensions. The SMA normalizes the presence of the state in the formalization of marriage[41].
In essence, the Special Marriage Act acts as a ray of hope because it's not just a theoretical idea but a living piece of legislation that has successfully integrated compulsory registration into the marriage process for a growing number of Indians. Its alignment with individual choice, secularism, and rights protection resonates with evolving liberal values, suggesting that a similar, universal requirement for registration[42], while facing hurdles, has a precedent rooted in India's own legal history and its gradual journey towards modernity. Alongside the online system, registration should be possible at multiple local government offices (like Panchayat offices, municipal corporation offices, sub-registrar offices, or even designated post offices) to cater to those without internet access or who prefer in-person services. This ensures reach even in remote areas[43].
Uniform Marriage Registration
A uniform marriage registration system in India could work smoothly by adopting a multi-pronged approach focused on accessibility, simplicity, integration, and awareness. A national or state-level online portal could allow couples to initiate the registration process, upload documents, and schedule appointments, making it accessible from anywhere. Legally require all officiants (religious priests, civil marriage officers, etc.) who solemnize a marriage to provide the couple with a formal proof-of-solemnization document and inform them of the mandatory registration requirement and process. They could even be empowered to initiate the registration online on behalf of the couple. Conduct widespread public awareness campaigns using various media (TV, radio, social media, community meetings) to educate citizens about the benefits and necessity of registration, as well as the process. Implement the mandatory system in phases, perhaps starting with urban areas or specific states, allowing the system to be tested and refined before nationwide application. Include provisions for registering older, existing marriages with simplified procedures for a limited period. Consider sensitive handling or temporary exemptions for tribal communities with unique customs, focusing initially on integration rather than rigid uniformity.
Problem of the bureaucracy
Potential problems with bureaucracy in a compulsory marriage registration system in India are manifold. Fraud could manifest through the submission of fake documents (age, identity, divorce decrees) or even impersonation, leading to the registration of illegal marriages (like child marriages or bigamous ones) or obstructing legitimate ones. Corrupt officials might exploit the mandatory nature of registration by demanding bribes to expedite the process, overlook discrepancies, issue certificates without proper verification, or even deliberately delay applications to solicit payments.
A significant hurdle could be bureaucratic rigidity. Inflexible rules regarding specific documentation, residency proofs, or procedural steps could disproportionately affect marginalized, illiterate, or migrant populations who may struggle to meet stringent requirements, effectively denying them access to registration despite having valid marriages. Officials might rigidly adhere to protocols without considering genuine difficulties faced by applicants, turning the process into an obstacle rather than a service.
CONCLUSION: CONTEMPORARY DEBATES
The main debate lies in the importance of the registration which have been ignored or pardoned time to time after the independence. Where in many countries, it has been deemed compulsory. India still leaving it, gives sustenance to the ever-rising social issue. Debate on the other side contradict the issue as disrespecting the functioning of the relationship and privacy, Law in the personal affair always have been matter of controversy and dilemma, as where constitution gives its citizen to profess their religion is whatsoever capacity they want.
BIBLIOGRAPHY AND SOURCES
- The Indian Christian Marriage Act 1872.
- ‘Neither a widow nor a wife’: India’s abandoned brides,” The Fuller Project, https://fullerproject.org/story/abandoned-brides-india-nri-dowry-2/ (Visited on July 15, 2025).
- Muskan Kumari, "Whether Hindu Marriage is a Contract or a Sacrament", JOURNAL OF LEGAL RESEARCH AND JURIDICAL SCIENCES, Vol. 2 No. 3 2023, p. 312.
- AIR 2011 SC 479
- Rupa Hazarika, "Transformation of Hindu Marriage from Sacrament to Agreement", JOURNAL FOR RE ATTACH THERAPY AND DEVELOPMENTAL DIVERSITIES, Vol. 6 No. 1s 2023, p. 179.
- CHAPTER XIV MARRIAGE, MAINTENANCE OF WIVES AND RESTITUTION OF CONJUGAL RIGHTS Mulla: Principles of Mahomedan Law, Updated 20th Edition Mulla
- Tamanna Singh, "Navigating the Hindu Marriage Act of 1955: A Journey of Law, Society and Changing Times", INDIAN JOURNAL OF INTEGRATED RESEARCH IN LAW, Vol. 5 No. 1 2024, p. 241.
- Aisha Ahmed, "The Controversial Recognition of a Woman’s Right to Divorce", SZABIST LAW JOURNAL, Vol. 2 No. 1 2021, p. 40
- Dinshah Fardunji Mulla, PRINCIPLES OF MAHOMEDAN LAW, $24^{th}$ ed. 2025
- The Indian Christian Marriage Act of 1872
- THE PARSI MARRIAGE AND DIVORCE ACT, 1936
- RITUALS IN PARSI CULTURE S.A.M.Tayaru (Asst.Prof of English, Dept. of Basic science,Shri Vishnu Engineering college of Women, Bhimavaram, A.P, India.)
- THE PARSI MARRIAGE AND DIVORCE ACT, 1936
- S. Manjula, "Marriage Under Various Personal Laws of India: An Analysis", INTERNATIONAL JOURNAL OF LAW MANAGEMENT & HUMANITIES, Vol. 6 No. 6 2023, p. 3230.
- Joydeep Chowdhury, "The Hindu Marriage Registration Act, 2012: Legal Recognition, Challenges, and the Path toward Gender Equality in Bangladesh", SCHOLARS INTERNATIONAL JOURNAL OF LAW, CRIME AND JUSTICE, Vol. 8 No. 2 2025
- K Syamalamma, CHILD MARRIAGE, https://www.nls.ac.in/wp-content/uploads/2021/03/faculty-seminar-child-marriage.pdf, (Visited on October 01, 2025).
- (2011) 1 SCC 141
- 1978 AIR 1557
- Badri Prasad vs. Dy. Director of Consolidation (1978) 1978 AIR 1557
- Bhaurao Shankar Lokhande vs. State of Maharashtra (1965) AIR 1965 1364
- THE PROHIBITION OF CHILD MARRIAGE ACT, 2006
- ‘Neither a widow nor a wife’: India’s abandoned brides,” The Fuller Project, https://fullerproject.org/story/abandoned-brides-india-nri-dowry-2/ (Visited on July 15, 2025).
- Sonia Sarkar, INDIA: ABANDONED BRIDES FIGHT FOR JUSTICE, https://www.dw.com/en/india-abandoned-brides-fight-for-justice/a-65192676, (Visited on October 01, 2025).
- Suhasini Raj and Atul Loke, INDIA'S 'ABANDONED BRIDES,' LEFT ABROAD AND ADRIFT, https://www.nytimes.com/2023/06/13/world/asia/india-brides-women.html, (Visited on October 01, 2025).
- National Institute of Public Cooperation and Child Development, PROBLEMS OF DESERTED WOMEN AND THEIR CHILDREN IN INDIA, https://www.nipccd.nic.in/file/reports/desertion.pdf, (Visited on October 01, 2025).
- Himani Khatreja, 'I HELP ABANDONED BRIDES GET JUSTICE': HOW ONE WOMAN SAVED 2500+ NRI BRIDES, https://thebetterindia.com/310790/punjab-satwinder-kaur-abb-nahi-social-welfare-society-helps-abandoned-brides-find-justice/, (Visited on October 01, 2025).
- The German Civil Code (Bürgerliches Gesetzbuch or BGB)
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- Citizens for Justice and Peace, THE UNIFORM CIVIL CODE (UCC) OF UTTARAKHAND: ADVANCEMENT IN GENDER JUSTICE OR VIOLATING INDIVIDUAL LIBERTIES?, https://cjp.org.in/the-uniform-civil-code-ucc-of-uttarakhand-advancement-in-gender-justice-or-violating-individual-liberties/, (Visited on October 01, 2025).
- Debomitra Das, WHAT IS THE UNIFORM CIVIL CODE IN UTTARAKHAND? HOW TO REGISTER MARRIAGE AND LIVE-IN RELATIONSHIPS ONLINE, https://timesofindia.indiatimes.com/life-style/relationships/love-sex/what-is-the-uniform-civil-code-in-uttarakhand-how-to-register-marriage-and-live-in-relationships-online/articleshow/117629213.cms, (Visited on October 01, 2025).
- The Hindu Bureau, UTTARAKHAND EASES MARRIAGE REGISTRATION RULES UNDER UCC FOR PEOPLE OF NEPAL, BHUTAN, AND TIBET, https://www.thehindu.com/news/national/uttarakhand/uttarakhand-eases-marriage-registration-rules-under-ucc-for-people-of-nepal-bhutan-and-tibet/article70158884.ece, (Visited on October 01, 2025).
- K. Suresh and Mr. Arulkannappan, "A Study on Special Marriage Act, 1954", INTERNATIONAL JOURNAL OF PURE AND APPLIED MATHEMATICS, Vol. 120 No. 5 2018, p. 2955.
- THE SPECIAL MARRIAGE ACT, 1954.
- Patil Neha, "The Special Marriage Act 1954: A Critical Examination of its Constitutionality and the Need for Legislative Action", INTERNATIONAL JOURNAL OF LAW MANAGEMENT & HUMANITIES, Vol. 6 No. 1 2023, p. 723.
[1] Muskan Kumari, "Whether Hindu Marriage is a Contract or a Sacrament", JOURNAL OF LEGAL RESEARCH AND JURIDICAL SCIENCES, Vol. 2 No. 3 2023, p. 312.
[2] AIR 2011 SC 479
[3] ibid
[4] Rupa Hazarika, "Transformation of Hindu Marriage from Sacrament to Agreement", JOURNAL FOR RE ATTACH THERAPY AND DEVELOPMENTAL DIVERSITIES, Vol. 6 No. 1s 2023, p. 179.
[5] ibid
[6] CHAPTER XIV MARRIAGE, MAINTENANCE OF WIVES AND RESTITUTION OF CONJUGAL RIGHTS Mulla: Principles of Mahomedan Law, Updated 20th Edition Mulla
[7] Tamanna Singh, "Navigating the Hindu Marriage Act of 1955: A Journey of Law, Society and Changing Times", INDIAN JOURNAL OF INTEGRATED RESEARCH IN LAW, Vol. 5 No. 1 2024, p. 241.
[8] Aisha Ahmed, "The Controversial Recognition of a Woman’s Right to Divorce", SZABIST LAW JOURNAL, Vol. 2 No. 1 2021, p. 40
[9] Dinshah Fardunji Mulla, PRINCIPLES OF MAHOMEDAN LAW, $24^{th}$ ed. 2025
[10] The Indian Christian Marriage Act of 1872
[11] THE PARSI MARRIAGE AND DIVORCE ACT, 1936
[12] RITUALS IN PARSI CULTURE S.A.M.Tayaru (Asst.Prof of English, Dept. of Basic science,Shri Vishnu Engineering college of Women, Bhimavaram, A.P, India.)
[13] THE PARSI MARRIAGE AND DIVORCE ACT, 1936
[14] S. Manjula, "Marriage Under Various Personal Laws of India: An Analysis", INTERNATIONAL JOURNAL OF LAW MANAGEMENT & HUMANITIES, Vol. 6 No. 6 2023, p. 3230.
[15] AIR 1965 1364
[16] Joydeep Chowdhury, "The Hindu Marriage Registration Act, 2012: Legal Recognition, Challenges, and the Path toward Gender Equality in Bangladesh", SCHOLARS INTERNATIONAL JOURNAL OF LAW, CRIME AND JUSTICE, Vol. 8 No. 2 2025
[17] K Syamalamma, CHILD MARRIAGE, https://www.nls.ac.in/wp-content/uploads/2021/03/faculty-seminar-child-marriage.pdf, (Visited on October 01, 2025).
[19] (2011) 1 SCC 141
[20] 1978 AIR 1557
[21] Badri Prasad vs. Dy. Director of Consolidation (1978) 1978 AIR 1557
[22] Bhaurao Shankar Lokhande vs. State of Maharashtra (1965) AIR 1965 1364
[23] THE PROHIBITION OF CHILD MARRIAGE ACT, 2006
[24] ‘Neither a widow nor a wife’: India’s abandoned brides,” The Fuller Project, https://fullerproject.org/story/abandoned-brides-india-nri-dowry-2/ (Visited on July 15, 2025).
[25] Sonia Sarkar, INDIA: ABANDONED BRIDES FIGHT FOR JUSTICE, https://www.dw.com/en/india-abandoned-brides-fight-for-justice/a-65192676, (Visited on October 01, 2025).
[26] Suhasini Raj and Atul Loke, INDIA'S 'ABANDONED BRIDES,' LEFT ABROAD AND ADRIFT, https://www.nytimes.com/2023/06/13/world/asia/india-brides-women.html, (Visited on October 01, 2025).
[27] National Institute of Public Cooperation and Child Development, PROBLEMS OF DESERTED WOMEN AND THEIR CHILDREN IN INDIA, https://www.nipccd.nic.in/file/reports/desertion.pdf, (Visited on October 01, 2025).
[28] Himani Khatreja, 'I HELP ABANDONED BRIDES GET JUSTICE': HOW ONE WOMAN SAVED 2500+ NRI BRIDES, https://thebetterindia.com/310790/punjab-satwinder-kaur-abb-nahi-social-welfare-society-helps-abandoned-brides-find-justice/, (Visited on October 01, 2025).
[29] The German Civil Code (Bürgerliches Gesetzbuch or BGB)
[30] ibid
[31] Dale Hurd, INDIA'S INNOCENT SECRET: WEDDINGS OF CHILD BRIDES, https://cbn.com/news/world/indias-innocent-secret-weddings-child-brides, (Visited on October 01, 2025).
[32] Formatted Footnote: The Pixel Project, INSPIRATIONAL INTERVIEW: KRITI BHARTI (PART I), https://www.thepixelproject.net/2014/07/27/inspirational-interview-kriti-bharthi-part-i/, (Visited on October 01, 2025).
[33] ibid
[34] ibid
[35] Citizens for Justice and Peace, THE UNIFORM CIVIL CODE (UCC) OF UTTARAKHAND: ADVANCEMENT IN GENDER JUSTICE OR VIOLATING INDIVIDUAL LIBERTIES?, https://cjp.org.in/the-uniform-civil-code-ucc-of-uttarakhand-advancement-in-gender-justice-or-violating-individual-liberties/, (Visited on October 01, 2025).
[36] Debomitra Das, WHAT IS THE UNIFORM CIVIL CODE IN UTTARAKHAND? HOW TO REGISTER MARRIAGE AND LIVE-IN RELATIONSHIPS ONLINE, https://timesofindia.indiatimes.com/life-style/relationships/love-sex/what-is-the-uniform-civil-code-in-uttarakhand-how-to-register-marriage-and-live-in-relationships-online/articleshow/117629213.cms, (Visited on October 01, 2025).
[37] The Hindu Bureau, UTTARAKHAND EASES MARRIAGE REGISTRATION RULES UNDER UCC FOR PEOPLE OF NEPAL, BHUTAN, AND TIBET, https://www.thehindu.com/news/national/uttarakhand/uttarakhand-eases-marriage-registration-rules-under-ucc-for-people-of-nepal-bhutan-and-tibet/article70158884.ece, (Visited on October 01, 2025).
[38] ibid
[39] K. Suresh and Mr. Arulkannappan, "A Study on Special Marriage Act, 1954", INTERNATIONAL JOURNAL OF PURE AND APPLIED MATHEMATICS, Vol. 120 No. 5 2018, p. 2955.
[40] THE SPECIAL MARRIAGE ACT, 1954.
[41] ibid
[42] Patil Neha, "The Special Marriage Act 1954: A Critical Examination of its Constitutionality and the Need for Legislative Action", INTERNATIONAL JOURNAL OF LAW MANAGEMENT & HUMANITIES, Vol. 6 No. 1 2023, p. 723.
[43] ibid
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