BHAURAO SHANKAR LOKHANDE & ANR. vs STATE OF MAHARASHTRA & ANR.

The Supreme Court held that for an offence under Section 494 IPC, it is necessary for the prosecution to prove that the second marriage was validly performed according to the applicable law. The Court clarified that a marriage is not considered 'solemnised' under Section 17 of the Hindu Marriage Act, 1955 unless essential ceremonies are performed. In this case, the essential ceremonies of a Hindu marriage were not conducted, leading to the conclusion that the second marriage was not valid, and thus the conviction under Section 494 IPC was overturned.