LAKSHMI DEVI vs SATYA NARAYAN .

The Supreme Court held that the prosecution failed to prove the essential ceremony of 'Sapatpadi' required for establishing the factum of second marriage under Section 494 IPC. The Court reiterated that mere eyewitness accounts are insufficient without proof of essential marriage ceremonies, as established in Kanwal Ram v. H.P. Administration and Bhaurao Shankar Lokhande v. State of Maharashtra. Consequently, the appeal was dismissed, affirming the lower courts' decisions that the evidence did not justify a conviction for bigamy.