Philosophy of Hindu Marriage In India

Q. 6 Discuss the Nature and Philosophy of Hindu Marriages under Hindu Law? What are the various types of  Hindu  Marriage?

Philosophy of Hindu Marriage
Definitions of Marriage
The legal status, condition, or relationship that results from a contract by which one man and women who have the capacity to enter into such an agreement, mutually promise to live together in the relationship of Husband and Wife in law for life, or until the legal termination of the relationship.[1]
Collins Dictionary of Sociology
“Marriage is a socially acknowledged and sometimes legally ratified union between an adult male and adult female”
Definition of Hindu Marriage
According to Raghunandan, a well known Bhasyakar, “the acceptance of bride as his wife by the bridegroom  in a gift by her parents is defined as marriage”[2]
According to Veda, A marriage is, “the union of flesh with flesh and bone with bone”[3]
Nature of Hindu Marriages,
A Sacrament
Marriage according to Hindu law is a samaskara (sacrament) a purificatory ceremony prescribed by religion and is not a contract. The maxim “Conjuctic martitet peminae eet de nature”  means that to keep husband and wife together is the law of nature and the maxim “ Viretunor consenture in lege una persona” means that the husband and wife are considered one in the eye of law.
Marriage, according to Shastras is a holy sacrament and the gift of the girl (kanyadan) to a suitable boy is sacred duty put upon the father after the performance of which the father gets great spiritual benefits. In Purushottam v. Purushottam[4] it was held that the father or guardian of the girl enjoys the absolute right to settle the marriage and the assent of the girl does not carry any material significance. In Gopal Krishan v Mithilesh Kumar[5]  Allahabad High Court observed that the “The institution of matrimony under the Hindu law is a sacrament and not a mere socio-legal contract. It is not performed for mere emotional gratification and is not a mere betrothal. It is regarded as part of the life of the soul. A Hindu marriage thus performed regarded indissoluble”.
Marriage was considered as a sacrament and not a contract under Hindu Laws for the following reason:-
(i)                 Unlike a contract, marriage was an indissoluble tie and could not be dissolved by decree of Divorce.
(ii)               Marriage between minors has been considered valid if contracted by lawful guardians.
(iii)             Moreover no consideration is required to render the marriage valid; on the other hand payment of sulka or bride price has been deprecated in old Hindu Law.

A Contract
 Some argue that Hindu marriage is a contract as Mannu Smriti makes it clear that there is a gift of the bride to a bridegroom in Hindu Marriage. Modern writers on Hindu laws after codification have generally taken the view that a Hindu Marriage is not only a sacrament but also a contract.
In Purushottam Das v. Purushottam Das[6] the court observed that the “marriage of Hindu children is a contract. In Mathusami v. Masilamani[7], the court has observed that “A marriage whatever else it is i.e., a sacrament or an institution, is undoubtedly a contract entered into for consideration with correlative rights and duties”.
In Anjana Dasi v. Ghose[8] , the Calcatta High Court has observed that “Suits relating to marriage deals with that which in the eye of law must be treated as a civil contract and important civil rights, arise out of that contract”. In Bhagwati Saran Singh v. Parmashwaeri Manoher Singh[9], the court after quoting extensively from Macnaghton’s Hindu Law, Strange’s Hindu Law and Vyavahara Chandrika, expressed that a Hindu marriage is not only a sacrament but also a contract. [10]
In spite of the fact that the ancient Hindu Marriage was a sacrament, some elements of the contract were present even in the old concept of Hindu Marriage:-
(i)                 Firstly, acceptance of the bride was an important element in the ceremony of the marriage.
(ii)                Secondly, both the bride and the bridegroom must be physically and mentally capable of marriage. Marriage with a congenital idiot who is unable to have any comprehension of marriage is invalid.
(iii)             Thirdly, a marriage contracted by force or fraud is invalid and the court may in appropriate cases pass a decree of nullity of marriage.
(iv)             Moreover, although the ancient Hindu law did not favour payment of any consideration by the bridegroom to the father or the guardian of the bride, payment of such consideration or bride price did not render the marriage invalid.
Changes were made by Hindu Marriage Act, 1955.—
The Hindu Marriage Act, 1955 has changed the concept of marriage and introduced some element of contract in marriage. According to the new codified Hindu, Law marriage is a union of one man and woman to the exclusion of the other. Some elements of are set out as follows:-
(i)                 Firstly, the Minimum age of marriage as prescribed by Sec 5(iii) is 18 years for the bride and 21 years for the bridegroom. Any marriage solemnised in the contravention of this rule is neither void nor voidable but gives an option of puberty to a female and a decree of divorce can be granted under Sec 13 subsection 2  clause (iv).
(ii)               Secondly, the marriage can be avoided by the court by decree of nullity, If the consent of the parties/guardian was obtained by force or fraud on the ground of insanity or importance.
(iii)             Thirdly, newly codified law conferred the right of judicial separation and dissolution of marriage by a decree of divorce.
Forms of Marriage:-
The ancient Hindu Laws recognized Eight forms of marriage, namely:-
The four obsolete approved forms of Hindu marriage are:-
(i)                 Brahma – The old Brahma form of marriage was peculiar to Brahmin only. According to Manu , the gift of a daughter bedecked and bejeweled with costly ornaments and present, to a man learned in veda and good conduct whom her father or guardian voluntarily invites and respectfully receives. The chief feature of this form is that the parents do not receives any kind of consideration for giving the girl in marriage.
(ii)                Daiva – According to Manu, the gift of a daughter who has been decked with ornaments, to a priest who dully officiates at a sacrifice during the course of its performance, they call the Daiva rite. This form of marriage is inferior to the Brahma form because the father gives away his daughter for deriving a spiritual benefit. The Daiva is only different from the Brahma in that the gift was made to a priest officiating at a sacrifice during its performance.
(iii)             Arsha--   In this form of marriage father gives away his daughter according to the rule, after receiving from the bridegroom a cow, bull or two pairs, for the fulfilment of the sacred law, that is named as Arsha rite. There being no intention to sell the sell the child; the bull and caw were returned back to the bridegroom after the marriage.
(iv)             Prajapatya – Prajapatya marriage is similar to Brahma form except that the bridegroom need not be a bachelor. According to manu, the gift of a daughter by her father after he address the couple with the text, “May both of you perform together your duties ” and has shown  honour  to bridegroom  is called Prajapatya rite.
Four unapproved form of Hindu marriage:-
(i)                 Asura ---According to Asvalayana, a wedding is called Asura where a man marriage to a girl after gladdening her father by money. This form of marriage is almost a sale of a girl.
(ii)               Gandharwa – According to Asvalayana, where a man marriage  a women after a mutual agreement has been made between the lover and the damsel, it is called the Gandharwa marriage.
(iii)             Rakshasa—According to Manu, the forcible abduction of a maiden from her home, while she cries out and weeps, after her kinsmen have been slain or wounded and their houses broken open, is called the Rakshasa rite.
(iv)             Paishacha—According to Manu, when a man by stealth seduces a girl who is sleeping, intoxicated, or unconscious, is the eighth, the most base and sinful paishacha rite.       
Classification of marriage
The verna notion and classification of marriage propounded by Manu found unquestioned acceptance in later Dharmshstras. Kane State[11]that “all writers on Dharmshastra” start with two propositions: first, the descending scale of the social status of Brahmans, Kshatriyas,Vaishyas and Shudras; and Second, the classification of marriage into anuloma and partiloma.
Marriages were classified as anuloma (according to the order of castes) and partiloma (against the order of castes). Under the anuloma form of marriages, a Brahman could take not only a Brahman wife, but also a Kshatriya, a Vaishya and a Shudra women,. Kshtriya man apart from Kshtriya women, also a vaishya, and sudra women in marriage. Vaishya man apart from vaishya, also a Shudra woman in marriage. However, a disapproved an anuloma marriage was recognized, and the offspring were treated as legitimate. However, a partiloma marriage, that is, the marriage of a male belonging to a lower caste with a female of a higher caste, was prohibited and condemned.  
 



[1] https://legal-dictionary.thefreedictionary.com/marriage
[2] Cited in Myneni’s Dr.S.R., “Family Law in India” p. 142 Ist Ed. 2009 (Asia Law House Hyderabad)
[3] ibid
[4] [21 Bom. 28]
[5] AIR 1979 ALL 316
[6] [21 Bom 23]
[7] [33Mad 342]
[8] [Bengal Law Reporter, P.243]
[9] [1942 ILR ALL 518]
[10] Cited in Myneni’s Dr.S.R., “Family Law in India” p. 146 Ist Ed. 2009 (Asia Law House Hyderabad)
[11] Kane,P.V., , “History of Dharmshatra,”P.1.27 Vol.II(2nd Ed…1947)

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