INTRODUCTION
In a historic ruling, the Supreme Court of India has ordered all States and Union Territories to operationalise the registration of Sikh marriages under the Anand Marriage Act, 1909, within four months. The Court observed that the Anand Marriage (Amendment) Act, 2012 recognized Sikh marriages statutorily, but several states did not implement the law, resulting in Sikh couples registering their marriages under the Hindu Marriage Act, 1955. This failure of implementation reduced the distinct identity of the Sikh community and incorrectly deprived couples of their rights applicable to statutory recognition.
BACKGROUND
The Anand Marriage Act, 1909 was the first law to recognize Sikh marriages, held through the traditional Anand Karaj ceremony, during British Rule. The 2012 amendment inserted Section 6 to the Act, requiring state governments to frame rules to register Sikh marriages; however, over a decade later, many states still either did not frame rules, or simply continued to require couples to register under the Hindu Marriage Act to receive a marriage certificate.
This failure was challenged before the Supreme Court mainly on the grounds that it violated Sikh couples’ rights under Articles 14, 19, 21, 25, and 26 of the Constitution, for the state was not recognizing a Sikh couple’s personal law and religious practices.
On September 19, 2025, the Supreme Court bench headed by Chief Justice D.Y. Chandrachud, called upon the states to complete the following prerequisites within four months:
- Frame and notify the rules under the Anand Marriage Act, 1909 (as amended in 2012).
- Prepare to register Sikh marriages with the appropriate infrastructure (online and offline).
- Make sure that the marriage registration certificates recognize marriage under the Anand Karaj ceremony.
The Court cautioned that failure to do so would result in contempt proceedings against non-compliant states.
KEY POINTS
- Administrative Apathy – Several states delayed rule-making despite clear legislative mandate in 2012.
- Overlap with Hindu Marriage Act – Officials often insisted Sikh couples register under the Hindu Marriage Act, citing convenience.
- Lack of Awareness – Many Sikh couples themselves were unaware of their right to register under the Anand Marriage Act.
- For Sikh Couples: They will finally be able to obtain marriage certificates under their own religious law, strengthening community identity and ensuring easier access to legal remedies in matrimonial disputes.
- For State Governments: They must urgently create rulebooks, online portals, and registration offices to comply with the deadline.
- For Indian Legal System: It highlights the judiciary’s proactive role in enforcing minority rights when executive inertia persists.
RECENT DEVELOPMENTS
The Court stressed that whether or not to recognize Sikh marriages is not a question just about process, it is a question of identity, and of the rights of freedom of religion. By compelling Sikh couples to have their union registered under the Hindu Marriage Act, the States materially violated Article 25, which recognizes substantive Sikh practices as part of an independent religion.
It is therefore also a reaffirmation of India’s commitment to pluralism and equality under the law. This is in keeping with the jurisprudence from previous cases, e.g. S.R. Bommai v. Union of India 1994 Supp (1) SCC 1, where it was said, “Secularism is a basic feature of the Constitution”.
CONCLUSION
In conclusion, the Supreme Court’s ruling in Amanjot Singh Chadha v. Union of India & Ors. Writ Petition (Civil) No. 911 of 2022 marks a significant end to 13 years of waiting to see justice realized from the affirmation of the 2012 amendment. The Supreme Court’s instruction to the states to implement the Anand Marriage Act within a period of four months affirms both protection of freedom of religion and equality under the Constitution. This finding will be significant to acknowledging diversity in personal laws in India and protect fundamental rights where the Centre and states might undermine constitutional guarantees.
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Written by- Anwesha Anant
