IN THE HON’BLE FAMILY COURT OF THANE, MAHARASHTRA

IN THE MATTER OF

SHEKHAR MARATHE …PETITIONER

V.

VIMLA MARATHE …RESPONDENT

WRITTEN SUBMISSION ON BEHALF OF THE RESPONDENT

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 TABLE OF CONTENTS

LIST OF ABBREVIATIONS - - - - - - - - II

INDEX OF AUTHORITIES - - - - - - - - III

STATEMENT OF JURISDICTION - - - - - - - VII

STATEMENT OF FACTS - - - - - - - - VIII

STATEMENT OF ISSUES - - - - - - - - IX

ARGUMENT BY RESPONDENT-------------X

I. WHETHER THE CONVERSION OF GIRLS FATHERS SURNAME WAS VALID.

II. WHETHER THE MISREPRESENTATION OF VIMLAS FAMILY ABOUT THEIR CASTE AMOUNT TO
FRAUD.

III. WHETHER THE ANNULMENT OF MARRIAGE BE GRANTED TO SHEKHAR.

A. WHETHER THE MARRIAGE BETWEEN SHEKHAR MARATHE AND VIMLA MARATHE IS

VALID.

SUMMARY OF ARGUMENTS - - - - - - - - IX

PRAYER - - - - - - - - - - XII

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 LIST OF ABBREVIATIONS

& And
¶ Paragraph

AIR All India Reporter

ALL Allahabad

Anr. Another
MAH Maharashtra

Art. Article
Cr. Criminal

Edn. Edition
Govt. Government

HMA Hindu Marriage Act

Hon’ble Honourable

i.e. That is
No. Number

PC Privy Council
SC Scheduled Caste

SC Supreme court
SCC Supreme Court Cases

u/s. Under Section

v. Versus

Vol. Volume
www World Wide Web

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 INDEX OF AUTHORITIES

1. Table of Cases

S.No. Name of the Cases and Case Citation Page No.

1. Anurag Anand v. Sunita Anand 14

2. Harbhajan Singh v. Smt. Brij Balab, AIR 1964 Punjab 359. 12

3. Kedar Nath vs Smt. Suparva AIR 1963 17

4. Lily Thomas vs UOI, AIR 2000 SC 1650 18

5. Vinita Saxena vs Pankaj Pandit, AIR 2006 SC 1662(2) CCC52 (SC). 18

6. M.M. Malhotra vs UOI, AIR 2006 SC 80. 18

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 STATEMENT OF JURISDCITION

The Hon’ble Family Court of Thane, Maharashtra is vested with Jurisdiction to Hear the Present
Petition under Section 7 (1) (a) of the Family Courts Act, 1984 1.

Section 7- Jurisdiction.-

(1) Subject to the other provisions of this Act, a Family Court shall- (1) Subject to the other provisions of this Act, a Family Court shall-"

(a) Have and exercise all the jurisdiction exercisable by any district court or any subordinate civil court under any law for the time being in force in respect of suits and proceedings of the
nature referred to in the explanation. Explanation.-The suits and proceedings referred to in this sub-section are suits and proceedings of the following nature, namely:

(a) a suit or proceeding between the parties to a marriage for a decree of nullity of marriage (declaring the marriage to be null and void or, as the case may be, annulling the marriage) or
restitution of conjugal rights or judicial separation or dissolution of marriage.

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 STATEMENT OF FACTS

For the sake of brevity and convenience of this Hon’ble Court the facts of the present case are
summarised as follows:

1. SHEKHAR MARATHE was born in a reputed Hindu family. The family of Shekhar resides at
Thane. Shekhar had enrolled himself for MBA Executive programme from a reputed
institute. Shekhar had completed his course while he was employed and busy at work.

2. VIMLA MARATHE also belongs to a Hindu family. Vimla’s Family resides at Mumbai. Vimla
too had enrolled her name in Executive MBA programme from a same reputed institute
same as Shekhar was.

3. Shekhar Marathe and VIMLA MARATHE met in a bank where they attracted to each other.
Later they both enrolled for same programme i.e., Executive MBA programme from a same
reputed institute same year. Both of them were already employed and they remain
extremely busy still they successfully completed the course.

4. Shekhar Marathe and VIMLA MARATHE both share good bound with each other and their
intimacy grew leaps by time. After a long time they decided to marry each other. Shekhar
Marathe and VIMLA MARATHE informed to their families about their relationship. Soon
Family came into the picture; met each other to know each other better and fix the
marriage.

5. No sooner Shekhar Marathe and VIMLA MARATHE marriage was solemnized in Thane with
Hindu rites in 2018 in presence of bride and grooms family, relative and friends. Shekhar
Marathe and VIMLA MARATHE was married in year 2018 and thereafter they started
habituating in Thane which was Shekhar Marathe’s family house.

6. Later, family of groom Shekhar Marathe found some information about the family of their
daughter in law (VIMLA MARATHE Marathe) which was very shocking to them. They found
that Girls family is not a reputed High caste Hindus as they claimed earlier before marriage.

7. Later, grooms family discovered that the Girls family had cheated them and made fraud w.r.t
their surname which makes them High Caste Hindus “SHINDE” whereas their real and earlier
Surname was Gaichor. This revelation made them think that they had been cheated and

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 their consent for marriage was acquired by the brides family by falsely misrepresenting the
frame of brides family as one of the High caste Hindus which was not real.

8. In 1965, VIMLA MARATHE’s father changes his surname from “GAICHOR” to “SHINDE” and
notified the same in official gazette too.

9. Due to such incident, Shekhar Marathe filed petition for Annulment of Marriage on the
ground that Vimla and her family had falsely misrepresented that they were high caste
Hindus. They had a malafide intention to cheat on them.

10.The case is before Family Court of Thane for arguments.

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 STATEMENT OF ISSUES

IV. WHETHER THE CONVERSION OF GIRLS FATHERS SURNAME WAS VALID.

V. WHETHER THE MISREPRESENTATION OF VIMLAS FAMILY ABOUT THEIR CASTE AMOUNT TO

FRAUD.

VI. WHETHER THE ANNULMENT OF MARRIAGE BE GRANTED TO SHEKHAR.

A. WHETHER THE MARRIAGE BETWEEN SHEKHAR MARATHE AND VIMLA MARATHE IS

VALID.

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 ARGUEMENTS ON BEHALF OF RESPONDENT

i. WHETHER THE CONVERSION OF GIRLS FATHERS SURNAME WAS VALID.

The Official Gazettes Act, 1863 (Act XXXI of 1863) was passed by the Governor-General of

India in Council and received the assent of the Governor-General on 16 December 1863,
which is as follows :-

"An Act to give effect to the publication of certain orders and other matters in the  Gazette of
India.

WHEREAS the Governor-General of India in Council has resolved to publish

an Official Gazette to be called the Gazette of India containing such orders, notifications, and
other matters as the Governor-General of India in Council shall direct to be inserted therein;
it is enacted as follows :-

The Gazette Department, the Government of Maharashtra provides online facility for user to
Apply for Change of Name. User can read the instructions and fill the form. Online service is
provided by the government to save time of the user. The portal is available in two
languages, English and Marathi.

Procedure for Name Change in India

There are three mandatory things, which are needed to be done for authorizing the name
change:

1. Affidavit Submission: An affidavit needs to be prepared for the name change.

2. Ad Publication: An announcement should be published in the newspaper.

3. Gazette Notification: A notification should be published in the Gazette of India regarding

the name change.

NOTE: Gazette meaning – Gazette means any form of a journal, newspaper where it is
published officially.

1. Affidavit Submission

The first step in the legal procedure is affidavit submission. You need to contact a notary to
do the needful. The following steps would make the process simpler and clearer:

1. Approach your local notary and mention your request.

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2. The notary will suggest the stamp paper of the required value on which the affidavit for
the name change is made.

3. Once you have the paper, you need to provide the following details:

a. Name and New name

b. Current address

c. Reason for the name change (Astrology, numerology, marriage, etc)

4. Once the affidavit is printed on a plain stamp paper, it needs to be signed by two
witnesses. The legal procedure is to get it signed by two persons of gazetted officer rank.
Ensure that you have their signature, along with their stamp (rubber stamp).

5. The procedure for a name change, in the case of a central government employee, needs
to be done in lieu with the Ministry of Home Affairs O.M. No. – 190016/1/87-Estt. Dated
12.03.1987. Ask the Notary for advice or read the guidelines.

6. Married women, who would like to change their surname or add their husband’s name as
initials, are required to provide the following details:

a. Old name with the father’s name and address;

b. A new name with husband’s name and address;

c. Marriage date.

The affidavit reflects both your old and new names. Affidavits can be used for changing the
whole name, surname or just a few letters.

Keep a copy of the affidavit. This is a crucial document and comes in handy for any future
legal formalities.

For overseas Indians, who would like to change their name, one needs to submit a deed
stating the change of name, duly signed by the Indian High Commission office or the Indian
Embassy.

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2. Newspaper Publication

If you have made the affidavit, the next step is to publish an advertisement/notification in
the local newspaper that you have changed your name. For this, you need to select two
newspapers, one published in the official language of the state and the other, an English
daily.

For instance, if you reside in Madhya Pradesh, you can opt for Dainik Bhaskar and Times of
India/Hindustan Times. If you are from Tamil Nadu, you can opt for Dinakaran/Dina Thanthi
and The Hindu/Indian Express.

The requirement is to pick two popular daily and send a request to them, stating the
following details:

a. Your new name

b. Your old name

c. Date of Birth

d. Address

A government gazette (also known as official gazette, official journal, official newspaper,
official monitor or official bulletin) is a periodical publication that has been authorised to
publish public or legal notices.

Gazette Notification for change in name / surname is accepted by various Government body
in India and it’s a Valid Document.

Since it is legal and accepted by various government body, the name / surname change done
through the Gazette notification is a Valid Document.

Therefore, Vimla’s Shinde father had followed all above rules and his conversion of surname
is fully accepted and VALID.

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ii. WHETHER THE MISREPRESENTATION OF VIMLAS FAMILY ABOUT THEIR CASTE AMOUNT
TO FRAUD.

The question of consent of the parties to the marriage arise at two stages; firstly at the
time when the parties consent to solemnize the marriage and secondly at the time when
the marriage itself is solemnized."

The marriage according to Hindu law not being a contract, the consent at the first stage
though obtained by fraud cannot affect the validity of the marriage. The consent at the
time of the solemnization is the material consent. It is well settled that the consent at the
time of solemnization of marriage though a marriage is a sacrament according to the
Hindus, if obtained by fraud, affects the validity of the marriage.

The same view has been taken by the Punjab High Court in Harbhajan Singh v. Smt. Brij
Balab, AIR 1964 Punjab 359. Pandit, J. said in that case thus:

"The word 'fraud' as a ground for the annulment of the marriage under the Hindu law is
limited only to those cases where the consent of the petitioner at the solemnization of the
marriage was obtained by some sort of deception. For example, take a case where A was
given to understand that he was being married to B and, in fact, he was married to C.
Again, where the marriage of the petitioner was solemnized when he or she, as the case
may be, was under the influence of liquor. In case of a marriage under the Hindu law,
'fraud' is not used in a general way and on every misrepresentation or concealment, the
marriage cannot be dissolved. If the term 'fraud' is to be interpreted according to the
definition given in the Indian Contract Act, then it would become impossible to maintain
the sanctity of the marriage. All sorts of misrepresentation will be alleged by the
petitioners in order to break the marriage tie. This, obviously could not be the intention of
the Legislature. The fact that the respondent was of bad character before the
solemnization of the marriage cannot be a ground for the annulment of the marriage,
because there is a specific clause (d) of this very section dealing with this matter. Under
that, if the respondent was pregnant by some persons other than the petitioner at the time
of the marriage, then this can afford a ground for the annulment of the same. It means that
the Legislature did not intend that the past conduct of the respondent, except what is
mentioned in clause (d), should become a ground for the dissolution of the marriage."

As per statement of facts it was very much clear that Mr. Shinde had changed his surname
through Official Gazette Notification in 1965 which clear indicates that he doesn’t have any
malafide intention to misrepresent the changed surname in front of anyone. Before 1965,
he and his family had a surname GAICHOR and they were legally known by this surname
but after gazette notification they are officially known as “SHINDE”. Since it was also
published in Local Newspaper about his changed Surname from GAICHOR and SHINDE it
indiciates that it was publicly known that he is SHINDE officially.

Hence, there is no Misrepresentation of Vimlas family about their caste and also it doesn’t
amount to fraud at all.

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 iii. WHETHER THE ANNULMENT OF MARRIAGE BE GRANTED TO SHEKHAR.

Section 5 Condition for a Hindu Marriage

Section 5 Condition for a Hindu Marriage

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

(i) Neither party has a spouse living at the time of the marriage;

(ii) At the time of the marriage, neither party,-

(a) is incapable of giving a valid consent of it in consequence of unsoundness of mind; or

(b) though capable of giving a valid consent has been suffering from mental disorder of such a kind
or to such an extent as to be unfit for marriage and the procreation of children; or

(c) has been subject to recurrent attacks of insanity or epilepsy;

(iii) The bridegroom has completed the age of twenty one years and the bride the age of eighteen
years at the time of the marriage;

(iv) The parties are not within the degrees of prohibited relationship unless the custom or usage
governing each of them permits of a marriage between the two;

(v) The parties are not sapindas of each other, unless the custom or usage governing each of them
permits of a marriage between the two:

An annulment may be granted when a marriage is automatically void under the law for public policy
reasons or voidable by one party when certain requisite elements of the marriage contract were not
present at the time of the marriage.

VOID MARRIAGES

A marriage is automatically void and is automatically annulled when it is prohibited by law. Section
11 of Hindu Marriage Act, 1955 deals with:

Nullity of marriage and divorce- Void marriages - Any marriage solemnized after the commencement
of this Act shall be null and void and may, on a petition presented by either party thereto, against
the other party be so declared by a decree of nullity if it contravenes any one of the conditions
specified in clauses (i), (iv) and (v), Section 5 mentioned above.

Voidable Marriages

A voidable marriage is one where an annulment is not automatic and must be sought by one of the
parties. Generally, an annulment may be sought by one of the parties to a marriage if the intent to
enter into the civil contract of marriage was not present at the time of the marriage, either due to
mental illness, intoxication, duress or fraud.

Section 12 of Hindu Marriage Act, 1955 deals with Voidable Marriages-

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(1) Any marriage solemnized, whether before or after the commencement of this Act, shall be
voidable and may be annulled by a decree of nullity on any of the following grounds, namely:-

(a) that the marriage has not been consummated owing to the impotency of the respondent; or

(b) that the marriage is in contravention of the condition specified in clause (ii) of Section 5; or

(c) that the consent of the petitioner, or where the consent of the guardian in marriage of the
petitioner was required under Section 5 as it stood immediately before the commencement of the
Child Marriage Restraint (Amendment) Act, 1978, the consent of such guardian was obtained by
force or by fraud as to the nature of the ceremony or as to any material fact or circumstance
concerning the respondent; or

(d) that the respondent was at the time of the marriage pregnant by some person other than the
petitioner.

2) Notwithstanding anything contained in sub-section (1), no petition for annulling a marriage-

(a) on the ground specified in clause (c) of sub-section (1) shall be entertained if-

(i) the petition is presented more than one year after the force had ceased to operate or, as the case
may be, the fraud had been discovered ; or

(ii) the petitioner has, with his or her full consent, lived with the other party to the marriage as
husband or wife after the force had ceased to operate or, as the case may be, the fraud had been
discovered;

(b) on the ground specified in clause (d) of sub-section (1) shall be entertained unless the court is
satisfied-

(i) that the petitioner was at the time of the marriage ignorant of the facts alleged;

(ii) that proceedings have been instituted in the case of a marriage solemnized before the
commencement of this Act within one year of such commencement and in the case of marriages
solemnized after such commencement within one year from the date of the marriage; and

(iii) that marital intercourse with the consent of the petitioner has not taken place since the
discovery by the petitioner of the existence of the said ground.

Fraud or Force - If the consent to the marriage contract was obtained either by fraud or force, then
there are grounds for an annulment. The person who has been threatened or deceived about the
marriage contract continues to live with the spouse after the discovery of the fraud or the deception
or after being forced into the marriage, it is possible that this ground will not apply. In Anurag Anand
v. Sunita Anand, the court held that false particulars in bio data based upon which the marriage was
solemnized amounts fraud and the aggrieved party may annul the marriage.

As per Statement of Facts it is very much clear that Mr. Shekhar Marathe knew Mrs. VIMLA
MARATHE very well since they met in Bank and attracted to each other. Both were very well
educated and of sound mind. Therefore the annulment of Marriage cannot be granted to Mr.

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Shekhar Marathe as they do not satisfy the above mentioned annulment grounds to annul the
marriage.

With reference to the para II we had clearly mentioned that, there is no Misrepresentation of Vimlas
family about their caste and also it doesn’t amount to fraud. Since there is no fraud done by VIMLA
MARATHE and her family the given Act for Annulment of Marriage doesn’t satisfy the rule and
thereby NO ANNULMENT OF MARRIAGE TO BE GRANTED TO MR. SHAEKHAR MARATHE.

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WHETHER THE MARRIAGE BETWEEN SHEKHAR MARATHE AND VIMLA MARATHE IS VALID.

Conditions For A Valid, Void And Voidable Hindu Marriage

Section 5 Condition for a Hindu Marriage

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

1. Neither party has a spouse living at the time of the marriage;

2. At the time of the marriage, neither party,-

i. is incapable of giving a valid consent of it in consequence of

unsoundness of mind; or

ii. though capable of giving a valid consent has been suffering from
mental disorder of such a kind or to such an extent as to be unfit for
marriage and the procreation of children; or

iii. has been subject to recurrent attacks of insanity or epilepsy;

3. The bridegroom has completed the age of twenty one years and the bride
the age of eighteen years at the time of the marriage;

4. The parties are not within the degrees of prohibited relationship unless the
custom or usage governing each of them permits of a marriage between the
two;

5. The parties are not sapindas of each other, unless the custom or usage
governing each of them permits of a marriage between the two.

Explanations:

Marriage solemnized between the two Hindus, any one already married subsequent marriage was
void. The two parties should not married at the time of marriage. The parties was unsound mind at
the time of marriage, the marriage was void. The party was sound mind, but the party was affect any
recurrent attacks or unfit for the procreation of child in this marriages also not consider a valid
marriage. The bridegroom was complete age of 21 and the bride was complete age of 18 after only
fix the marriage.

The parties not complete this age limit, the marriage was consider child marriage. This age limits
fixing year of 2006, under child marriage prohibition act of 2006(6 of 2006).the Act of 1955 as well as
Yajnavalkya prohibits marriage between Sapindas. Yajnavalkya says Sapindas relationship extends
upto 7 degrees for fathers side and upto 5 degrees for mothers side.

But, this was relaxing the degrees, fathers sides 5 degrees and mothers side 3 degrees. Yajnavalkya
Smriti mentions the girl should be Yaviyaseem i.e., the girl should be younger than bridegroom. But,
this conditions was not mandatory. It was not affect the valid marriage. Under the present law no
requirement that the bride should be younger than bridegroom.

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Ex; male age 17 years and female age 13 years such a marriage was contrary to section 5clause(iii) of
Hindu marriage act, 1955. But this marriage was valid. The only consequence is punishment under
section 18 of Hindu marriage act.

There was no requirement that a bride should be a virgin.

Section 7 says ceremonies of Hindu marriage; A Hindu marriage may be solemnized in accordance
with the customary rites of either party satisfied. All customary rites included the saptapadi (that is
the taking seven steps by the bridegroom and the bride jointly before the sacred life).

Section 8 explained the registration of Hindu marriage, registration purpose was evidence of the
marriage. Non- registration is punishable with fine which extend to be 25 rupees. This registration
was any time everyone can inspection. Section 8(5) specifically states non registration shall not
affect the validity of marriage.

But the recent judgment by the supreme court in Seema vs Ashwani kumar AIR 2006 SC 1158, the
court issued the directions that the marriage of all Indian citizen belonging various religious, should
be made compulsory registration. If the marriage is registered, most of the disputes was easily
avoided. Registration was protect the women’s rights, and also avoid the legitimacy issues of
children’s. It’s also safe the children’s rights.

In P. Ramesh Kumar vs Secretary Kannapuram Gram Penchant, AIR 1998 ker. 95, in this case learned
single judge of the Kerala high court held that a Japanese Buddhist lady having a Japanese
citizenship, this lady was marry Hindu boy. But the registration certificates was not issues because he
was not domicile of India.

Conditions for void marriage under Hindu law

Section 11 of the Hindu marriage act, 1955 was explained void marriages. Any Hindu marriage
controversy to the section FIVE clause (i), (iv) and (V) in this marriage was void.

In Kedar Nath vs Smt. Suparva AIR 1963. In this case, A was married B, and then A was married C. B
was the legitimate and first wife of the A. C was file a relief petition to A. but, B was not present in
this petition. C file case was opposed the law. So, under amendment section also stranger cannot
seek relief under the act. He may seek under general law.

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In Vinita Saxena vs Pankaj Pandit, AIR 2006 SC 1662(2) CCC52 (SC). In this case parties was affecting
the mental disorder and not possible to procreation of children, it may furnish the ground for
nullifying the marriage.

Another case M.M. Malhotra vs UOI, AIR 2006 SC 80. In this husband was marrying the other
women. But, the first marriage was not terminated. The court held that, second marriage was void
and null. Because, this marriage was violate the valid marriage condition section FIVE clause (i).

Another land mark case Lily Thomas vs UOI, AIR 2000 SC 1650. A Hindu wife was filing a complaint
for the offense under section 494, IPC on the ground for bigamous of the marriage. Husband was
marrying other women in subsisting of first marriage.

He was firstly marring Hindu girl, and he was converting to Islamic religion. Marrying to the Islamic
girl, he thinks now he was Muslim and also apply the Muslim law only. But, the laws says the person
was marrying women dissolve the marriage after only convert any religion. Before dissolving the
marriage, at the time of marriage law only govern the parties.

Conditions for Voidable Marriage under Hindu law

Section 12 of Hindu marriage act 1955, says voidable marriage:

i. As to impotence;- under old clause (a), decree of nullity on the ground of impotence, it had
shown that the disability was existing from the time of marriage onward. But, now this
provision was omitted. The fact of non consummation of the marriage owes to the
respondent’s impotence are all the need be proved under the amendment clause. It was
most advanced provision.

ii. That the marriage was been in the contravention of the condition specified in clause (ii) of
section 5;

iii. The consent to the marriage has been obtained from force or fraud.

iv. The respondent was pregnant at the time of marriage by some other persons other than the
petitioner.

Section 12 clause (2) says no petition file for annulling and void marriage:

i. the petition is presented more the one year after discover fraud.

ii. The petitioner has, with his or her full consent, lived with the another party to the marriage
as husband or wife after the force had ceased to conduct or, in case may be, the fraud had
been discovered (more than one year).

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From above sections it is very much clear that MR. SHEKHAR MARATHE and VIMLA MARATHE fulfils
and satisfy all above rule which clearly indicates that their MARRIAGE is completely LEGAL and
VALID.

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 SUMMARY OF AGRUEMENTS ON BEHALF OF PETITIONER

In summary , on the basis of the detailed arguments presented hereinabove, the respondent
respectfully submits that all the allegations by Mr. Shekhar Marathe and his family is completely
void, false, imitate, fake, imaginary and concocted.

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 PRAYER

In the light of the arguments presented and the authorities cited., it is humbly prayed that this
Hon’ble Court may be pleased to:

i. To grant their Marriage as a Valid Marriage.

ii. Dismiss the petition for Annulment of Marriage by Mr. Shekhar Marathe.

iii. That, the cost of suit be saddled on the Respondent;

iv. Any other order as this Hon’ble Court may deem fit and proper.

And for this act of kindness the respondent ever prays.

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