Telangana High Court Declares Inter-Caste Marriage Void, Overrules Family Court's Jurisdictional Error
In a landmark judgment, the Telangana High Court has dissolved a marriage between a tribal woman and a man belonging to a Scheduled Caste, citing a jurisdictional error by the family court. The court ruled that the Hindu Marriage Act, 1955, does not apply to the petitioner, who hails from a Scheduled Tribe community, making the marriage legally unsustainable.
Background of the Case
The case dates back to 2014 when the woman, a dental student from Nizamabad at the time, filed for divorce on grounds of cruelty and forcible marriage. She alleged that the man, a police constable from the Scheduled Caste Mala community, had been stalking and harassing her since 2010. In May 2012, he forcibly took her to a temple in Nellore and coerced her into marriage under the threat of an acid attack, later presenting her with an alleged marriage certificate in August 2013.
The man contended that their relationship was consensual and that they were married according to Hindu rites and customs. However, the family court in Nizamabad dismissed the woman's plea in July 2014, thereby recognizing the marriage under the Hindu Marriage Act.
High Court's Ruling on Statutory Inapplicability
A division bench of Justices K Lakshman and Vakiti Ramakrishna Reddy, in their judgment on January 19, 2026, emphasized that mere performance of marriage according to Hindu rites or registration under the Hindu Marriage Act is legally insufficient. The court noted that as per section 2(2) of the Act, it does not apply to members of Scheduled Tribes unless extended by a central government notification, which was absent in this case.
The woman's counsel argued that she belonged to the Gond Scheduled Tribe community, while the man was from the Mala Scheduled Caste community, rendering the Hindu Marriage Act inapplicable. The court observed that statutory exclusion cannot be neutralised by registration, ceremony, or mutual consent, and there was no evidence to suggest the woman had abandoned tribal customs or was governed exclusively by Hindu personal law.
Jurisdictional Error by Family Court
The High Court faulted the family court for adjudicating the case under the Hindu Marriage Act without first determining its applicability. Failure to adjudicate this foundational issue rendered the entire exercise jurisdictionally infirm, warranting appellate interference. The court concluded that the family court committed a jurisdictional error by applying provisions of an Act that did not govern one of the parties.
Outcome and Legal Implications
Allowing the woman's appeal, the High Court declared the marriage void and unenforceable in law. This judgment underscores the critical importance of verifying statutory applicability in matrimonial cases, particularly involving inter-caste marriages where personal laws may differ. It sets a precedent for ensuring that courts do not overstep jurisdictional boundaries based on registration or ceremonial aspects alone.
The ruling highlights the complexities of India's personal laws and the need for careful legal scrutiny in cases involving Scheduled Tribes and other protected communities. It reaffirms that legal validity hinges on statutory provisions, not just social or ceremonial factors.
