Murugaiah vs Annathai

The Madras High Court set aside the lower appellate court's judgment and restored the trial court's decree for restitution of conjugal rights under Section 9 of the Hindu Marriage Act, 1955. The court held that the lower appellate court erred in dismissing the case based on the absence of compulsory registration of marriage, as Section 7(1)(c) of the Hindu Marriage (Tamil Nadu Amendment) Act, 1967 recognizes certain forms of marriage as valid. The High Court concluded that the evidence presented established the factum of marriage, thus upholding the trial court's findings.