Q: On the contravention of which of the provisions of Section 5 of the Hindu Marriage Act, 1955 is a Hindu marriage treated as void, voidable and valid? Comment.

Section 5 of the Hindu Marriage Act, 1955 lays down the essential conditions for a valid Hindu marriage. The legal status of a marriage—whether it is valid, void, or voidable—depends on the contravention of specific clauses of this section.


Section 5 – Conditions for a Hindu Marriage:

A marriage may be solemnized between any two Hindus if the following conditions are fulfilled:

  1. Neither party has a spouse living at the time of the marriage.
  2. Neither party is incapable of giving valid consent due to unsoundness of mind, or suffering from mental disorder, or is unfit for marriage and procreation of children.
  3. The bridegroom has completed 21 years and the bride 18 years of age.
  4. The parties are not within the degrees of prohibited relationship, unless custom permits.
  5. The parties are not sapindas of each other, unless custom permits.

Classification of Marriages Based on Contravention:

1. Void Marriages – Section 11

A Hindu marriage is void ab initio if it contravenes any of the following conditions of Section 5:

  • Section 5(i): Bigamy – If either party has a living spouse at the time of marriage.
  • Section 5(iv): Prohibited relationship, unless permitted by custom.
  • Section 5(v): Sapinda relationship, unless permitted by custom.

Such marriages have no legal validity and can be declared void by a decree of nullity.

Case Law:

Yamunabai Anantrao Adhav v. Anantrao Shivram Adhav (1988) – A second marriage during the lifetime of a legally wedded spouse is void under Section 11.


2. Voidable Marriages – Section 12

A Hindu marriage is voidable at the option of one of the parties if it contravenes:

  • Section 5(ii): Mental capacity – If either party was:
    • Incapable of giving valid consent due to unsoundness of mind,
    • Suffering from mental disorder making them unfit for marriage,
    • Subject to recurrent attacks of insanity.
  • Section 5(iii): Age of parties – Marriage of minors is not void, but voidable at the option of the minor party, provided action is taken within two years of attaining majority.
  • Other grounds under Section 12, such as fraud, coercion, or concealment of material facts.
Case Law:

Anurag Anand v. Sunita Anand (1997) – A marriage solemnized with a person of unsound mind was declared voidable.


3. Valid Marriages (Despite Contravention)

In some cases, a marriage may still be treated as valid, despite contravention, if:

  • The marriage violates Section 5(iii) (age condition) but both parties later cohabit voluntarily after attaining majority.
  • The contravention does not involve Sections 5(i), (iv), or (v).
  • The marriage is not challenged in a court of law, and both parties live as husband and wife.
Note:

Violation of age condition under Section 5(iii) is punishable under Section 18 of the Act, but the marriage is not void.


Conclusion:

The classification of Hindu marriages under the Hindu Marriage Act, 1955, depends on which clause of Section 5 is contravened:

Provision of Section 5Legal Status if Contravened
Clause (i), (iv), (v)Void under Section 11
Clause (ii), (iii)Voidable under Section 12
Clause (iii) (only age)Valid but punishable (under Section 18)

The intent of the legislature is to uphold the sanctity of marriage while protecting the rights of individuals, especially in cases of coercion, unsoundness of mind, or exploitation of minors.