LAKSHMI SANYAL vs SACHIT KUMAR DHAR

The Supreme Court upheld the High Court's decision that Section 19 of the Indian Christian Marriage Act, 1872, does not apply to marriages solemnized by a minister of the Roman Catholic Church under Section 5(1). The appellant's claim of lack of parental consent was dismissed as the marriage was validly solemnized according to Canon Law, which allows for dispensation in cases of consanguinity. The Court concluded that the marriage was not null and void despite the appellant being a minor at the time of marriage.