LILA GUPTA vs LAXMI NARAIN & ORS.

The Supreme Court held that a marriage contracted in contravention of the proviso to Section 15 of the Hindu Marriage Act, 1955, is not void but merely invalid, thus allowing the appellant to be recognized as the widow of Rajendra Kumar. The Court emphasized that the Act distinguishes between void marriages and those that are merely punishable, and since no specific consequences are provided for marriages violating Section 15, such marriages cannot be deemed void. Consequently, the appellant's claim to inherit Bhumidari rights was upheld.