Family Court's Jurisdiction Affirmed; Respondent Recognized as Legally Wedded Widow of Deceased Soldier
In a landmark judgment dated November 28, 2025, the Allahabad High Court, comprising Justices Arindam Sinha and Satya Veer Singh, upheld the Family Court's decision affirming Sadhna Devi as the legally wedded widow of deceased soldier Arve Shanker Yadav. This decision comes after a contentious legal battle initiated by Rajdhari and another, parents of the deceased, challenging the legitimacy of the marriage between Sadhna Devi and their late son.
The court meticulously reviewed the evidence and legal provisions, emphasizing the jurisdiction of Family Courts under Section 7(b) of the Family Courts Act, 1984, to adjudicate disputes concerning the legality of marriage. The appellants contended that the marriage was never consummated and alleged that only an engagement ceremony had occurred. However, the Family Court had conducted an exhaustive trial, examining various pieces of evidence including marriage invitation cards, oral testimonies, and documentary evidence, which established the marriage's validity.
The appellants' argument centered around Sadhna Devi's age at the time of marriage, claiming she was below 18 years, thus rendering the marriage void. However, the High Court clarified that under the Hindu Marriage Act, 1955, a marriage is not void if the bride is below 18 years, and only the parties involved in the marriage have the locus to challenge it. The Family Court's refusal to entertain the appellants' late-stage contentions regarding age was upheld.
Furthermore, the High Court distinguished this case from the precedent set in the R. Kasthuri case, highlighting the clear family dispute involved, which justified the Family Court's jurisdiction. The judgment underscored the importance of preserving the institution of marriage and resolving family disputes with sensitivity and adherence to legal statutes.
The appellants had previously sought relief from the Gujarat High Court, which dismissed their applications, affirming Sadhna Devi's receipt of posthumous honors as the widow of the deceased. The Allahabad High Court's ruling reinforces the Family Court's findings and dismisses the appeal, confirming Sadhna Devi's legal status as the widow entitled to the deceased's benefits.
This judgment underscores the judiciary's role in meticulously balancing legal provisions with evidentiary findings, ensuring justice in familial disputes involving sensitive issues of marital status and posthumous recognition.
Bottom Line:
Hindu Law - Declaration of marital status - Family Court has jurisdiction to adjudicate disputes concerning legality of marriage under Section 7(b) of the Family Courts Act, 1984.
Statutory provision(s): Family Courts Act, 1984 Section 7(b), Hindu Marriage Act, 1955 Sections 5(iii), and 11
Rajdhari v. Sadhna Devi, (Allahabad)(DB) : Law Finder Doc Id # 2825467
