A Critique of Child Marriage Law: A Legal Lacuna?

The National Family Health Survey-III of 2005-2006 confirmed that more than 47% women in India, aged between 20-24 1 , were married before the age of eighteen years. This 15-year- old statistic highlighted the prevalence of Child Marriage, whose consequences are grave for girl child. India while being a signatory of various international conventions and treaties, ratifying some, had an obligation to bring a change in its legal framework towards the protection of children, but has continuously failed or rather ignored its duty till now.

The Convention on the Elimination of All Forms of Discrimination against Women (CEDAW), ratified in 1993 by India, clearly stated that “the marriage of a child shall have no legal effect.” It thus required a legislature to specify a minimum age for marriage and to bring the same within the state’s purview. However, 28 years on, the practice still continues while being entrenched in an argument based on tradition under various personal laws, coupled with a vague ineffective legislative framework. The present paper discusses the dilution, contradictory nature and ineffectiveness of laws introduced in the fight against child marriage, and how the inaction fails in recognising not just the constitution’s moral but the country’s international obligation.

By Chetan Soni

child marriage

Introduction:

Child Marriage in India stands on obscure legal grounds. A country which prides itself with the world’s lengthiest Constitutions somehow, has not been able to clearly clarify its stance on an issue which violates the very basics of a child’s human rights. Important definitions under section 2 of The Prohibition of Child Marriage Act, 2006 (PCMA) state that:

  • a “child” means a person who, if a male, has not completed twenty-one years of age, and if a female, has not completed eighteen years of age.
  • “child marriage” means a marriage to which either of the contracting parties is a child.

The same act lays down punishments in sections 9, 10 and 11 for the offense of abetting and being part of a child marriage. Thus, even while classifying it as a criminal activity, it still recognizes the validity of a marriage, unless made void at the option of the contracting minors. According to NFHS-IV [1] , 11.9% of girls in India were married before the legal age, further, 12 states went on to show a higher prevalence than this national average. A pitiful stat highlights an increase of child marriages from 2005-06 to 2016 in the states of Himachal Pradesh and Manipur.

It is imperative to highlight here that India is still not a signatory of the United Nations Convention on Consent to Marriage, Minimum Age of Marriage, and Registration of Marriage, 1962 [2] . Back then the stance taken by the Indian delegate while refusing to ratify was the inability during that time to introduce such a legislation. However, about 60 years later, they have still not been able to introduce a legislation which effectively overrides personal laws in respect to the age of marriage and is not only a silent spectator, but rather an upholder of child marriages.

By not signing the convention, the government is already faltering in its obligation under the CEDAW and the Convention on the Rights of Children (CRC) [3] ratified by them in 1992 with article 32 of the same requiring them to prevent any work interfering with a child’s education, or harmful to the child’s physical, mental, spiritual, moral or social development. The Judiciary too has failed in its duty and has been woeful in its ability to bring social change. It has held a minors’ marriage valid due to the existing grey area between the applicability of PCMA and personal laws, and further hid behind the application of the doctrine of factum valet.

Incidence and Causes:

The inability of the government to present effective legislations to curb child marriages till date highlights the neglected nature with which this social problem has been dealt with. However, the impact it has on a child’s life, more importantly, on the girl child is too immense to be ignored. There is growing discontentment with the actions taken by the state in the protection of the girl child. The practice puts a girl in grave danger of sexual violence from a small age. A child marriage robs her of necessary time to develop physically, mentally, and emotionally, and concludes into early pregnancy, malnutrition, and maternal mortality [4].

This social evil must be dealt with accordingly, and provisions to amend the loopholes in the acts must be introduced. The judiciary must take responsibility for judgements clarifying the stance of the legislature in a positive light and be the catalyst of change, rather than uphold a damnifying practice in the name of tradition. A survey carried out by UNICEF in 2018 [5] , stated that more than 7% of the girl child were married before the age of 15, while more than 27% are married before the age of 18. Multiple causes for the same are embedded in the deep-rooted patriarchal nature of Indian society.

Firstly, much of the society considers the economic cost of development of a girl child a burden, and her treatment is that of as a mathematical factor associated with the dowry to be given. And therefore, the attitude is that of marrying a girl child off as soon as possible. Secondly, the same is done in order to protect her chastity till marriage. With the onset of puberty there is fear of her being sexually active and choosing her own partner and as it is believed that a girl must remain “pure” till marriage, she is married as soon as possible with her chastity intact.

As punishment to opposing a long-standing tradition of child marriage, Banwari Devi was gruesomely gang raped in 1984. The marriage of thousands of children on auspicious days like Akshaya Tritya [6] is representative of a sad reality, one where child marriage is treated as a practice associated with pride and honour.

Legislations through the Years:

A. The Child Marriage Restraint Act, 1929

During the British period, their customs and thoughts were inspiring the reformist movement brewing at that time. The same lead to the movement against child marriage. The law is many a times used to bring about a social reform. In 1929, in consonance with the same thought, Rai Sahib Hariblas Sarda introduced a Bill in Parliament seeking the declaration of child marriages invalid for Hindus. However, when the Bill become an Act, it was secular in its application and applied to every citizen of India. Initially the age bar was set at 14 years for girls and 18 years for boys.

The same was raised to 15 years in 1949, and then to 18 and 21, for boys and girls respectively, in 1978. This Act played the role of penalizing an adult male categorized between the age brackets of 18-21, and above the age of 21, and also penalized other stake holders who facilitated the marriage. The guardians are assumed to have great responsibility in this Act, as their negligence to prevent the same is also to be penalized. The Act goes on to ascribe the powers to prevent a child marriage from happening.

However, it limits the effectiveness of the police, because even while recognizing the cognizable nature of
the crime, they could not make any arrest without a warrant. After the expiry of one year from the date of its commission the court was not allowed to take cognizance of any offence under the Act. The Act while allowing the court to issue an injunction limited this power by requiring the court to provide the parties in question with a prior notice, allowing them to escape liability per their convenience.

Peculiar things about this Act were that no woman could be held complicit in any case. A loophole much exploited. Further, even though the act made the occurring of a child marriage punishable, it did not comment on the validity or voidability of the marriage. Hence, the message conveyed is one that allows all those willing to pay a price, that is, the punishment for the crime which could extend to 3 months of Simple Imprisonment and a fine, may do so. And the limitation clause leaves one stranded post the 1-year mark with no recourse to render a child marriage invalid.

B. The Prohibition of Child Marriage Act, 2006

The consistent efforts of The National Commission for Women (NCW) [7] and the National
Human Rights Commission [8] led to the ineffectiveness of the CMRA, 1929 and its inadequacies being brought to light. And hence, the legislators while accepting the criticisms and suggestions brought forth the PCMA, and repealed CMRA. One would expect the new Act to be rather progressive and a much-refined version of the previous Act.

Section 3 of the PCMA addressed the question of validity of child marriages and rendered it ‘voidable’ only at the option of either contracting minor party, that is, the ‘children’ during the marriage. If at the time of filing the petition, the petitioner is a minor as per the Majority Act, 1875 then they may do so only through their guardian. Therefore, a child marriage before the petitioner attains adulthood may only be rendered void if their guardian is unsupportive of the chid marriage and is willing to file legal proceedings, which may potentially make them the subject of punishment.

A highly unlikely condition when one keeps in mind the societal conditions. The limitation period for the petitioner is here set at 2 years post the attainment of his/her majority. A more welcome provision was the Section 12 of PCMA where in cases when the minor child is abducted, kidnapped or trafficked, all child
marriages are rendered null and void. It also renders any marriage solemnized in contradiction of an injunction order to be void ab initio under section 14 of the Act.

Along with making such a marriage void, the NCW in its recommendation [9] had advised for a significant increase in the punishment so as to increase the deterrence with respect to the crime. In response to the same, PCMA had quite enhanced punishments as compared to the 1929 Act. The punishment for a male adult marrying a minor girl child was increased from a simple imprisonment for 3 months, along with a fine, to a rigorous imprisonment of 2 years along with Rs. 1 lakh as fine.

It also no longer made a distinction between the age bracket of 18-21, and above 21 and classified a male adult as one above 18 years old per the Majority Act, 1875. Further, the punishment for solemnizing the child marriage, and also for the guardians of such children had been increased in a similar proportion. However, the PCMA much like the CMRA could not hold any woman liable for an offense under it.

In addition to the enhancement in punishments, all the offences under the act have been made non-bailable and cognizable through section 15. The court too has an increased ambit under Section 13 to issue an injunction without necessarily sending a prior notice, with the District judge conferred with the powers of a Child Marriage Prohibition Officer to prevent mass marriages on days such as Akshaya Tritiya. While earlier, the powers of a police officer were extremely restricted for any significant action, now the Child Marriage Prohibition Officer had been granted significant powers under Section 16 to stop a child marriage, where he may take any action deemed fit to prevent the child marriage.

However, the ground reality revealed that the state governments had failed to even appoint officers to the said post, and many are vacant till date.

C. Indian Penal Code, 1860 and POCSO, 2012

It is imperative to mention here the criminal code of the country, along with the POCSO act, the establishment of which was done with the intention of protecting children from sexual assault, sexual harassment, and pornography. A thorough reading of both the acts in harmony can be said to create a discrepancy with respect to the age of consent at the time of rape and the age of consent for rape within a marriage.

A long-awaited judgement of the apex court in Independent Thought V. Union of India [10], cleared this conundrum. The IPC prior to this judgement failed to protect the rights of a girl child married and the same went on to have severe implications on the legality of child marriages [11] . Section 375 of the IPC stated the legal definition of rape and set the age of consent at 16 years, thereby implying child rape to be under 16 years.

However, exception 2 to section 375 explicitly stated that “sexual intercourse by a man with his own wife, the wife not being under fifteen years of age, is not rape”. The section does not talk about consent or will and therefore comes under marital rape, which has no legal penalty. A marital rape of a child wife between the ages of 12-15 however, does have punishment amounting to a maximum of rigorous imprisonment of 2 years, along with fine, in comparison to a minimum of 10 years rigorous imprisonment if she was not married.

The POCSO act at the same time has multiple sections against non-consensual sexual activity against a girl under 18 years of age, and it does not draw a distinction between a married or unmarried girl child. More specifically, the provision is contradictory to Section 5 and 6 of the POSCO Act, where it is stated that if the husband of a girl child commits penetrative sexual assault on his wife, he is liable for aggravated penetrative sexual assault as has been provided under Section 5(n) of the POSCO Act. It is punishable under Section 6 by rigorous imprisonment of not less than ten years which may even extend to imprisonment for life and fine. Therefore, a scenario existed, where the IPC protects, rather it recognises an immunity against rape provided due to marriage, while the same act will still constitute a criminal
punishment under POCSO.

However, in Independent Thought V. Union of India, 2017 [12] , the court finally recognised these contradictory provisions and held that the exception must be read down. The Apex Court while quoting India’s international obligation per the Treaties and Conventions, it has signed or ratified towards women and child rights opined that such a law inhibited the overall well-being of a girl child and ruled that the age for the marital rape exception must be increased from 15 years to 18 years. However, even while denouncing child marriages, it did not rule them to be void.

D. Miscellaneous

Various legislations exist in Indian law which are based on the assumption of the validity of a child marriage. The Hindu Minority and Guardianship Act, 1956, under section 6 (c) explicitly declares that in case of a married girl who is a minor, her husband is her natural guardian. The Dowry Prohibition Act, 1961, under section 6(1)(c) also incorporates the validity of occurrence of a child marriage and provides that the dowry of a minor wife shall be held in trust for her benefit by any person who received it, which shall be transferred to her within one year after she attains 18 years of age.

The Criminal Procedure Code, 1973, under proviso to section 125(1)(d) makes it obligatory for the father of a minor bride to provide maintenance to her in case her husband lacks the sufficient means to maintain her. Thus, the undertone of such legislations highlighted the general acceptance and nonchalance shown towards child marriages by the country’s legislators.

Validity under Personal Laws

India’s legislature allows for the personal laws of different communities to govern matters intrinsic to their culture and history, one such being marriage. Currently, the stances with respect to child marriage, under the various personal laws are as follows:

Hindu Marriage Act, 1955

Section 5 of the act lays down the conditions for a valid Hindu marriage. The Act under Section 5 (iii) requires that the bridegroom should have completed 21 years of age, and the bride, the age of 18 years at the time of marriage. Initially the ages were 15 and 18, respectively. The Child Marriage Restraint (Amendment) Act, 1978, increased the same and further removed the clause which allowed a marriage below the ages of 15 and 18 with the consent of the guardians. Presently, a marriage in contravention of the above clause is not void as it is not a ground for making a marriage void under section 11 of the act which
specifically mentions clauses (i), (iv), and (v) of section 5 but omits sub-section (iii).

Further, Section 12 of the act which concerns itself with the voidability of marriage under HMA also does not mention sub-section (iii) as a ground while again specifying other sections. Hence, prima facie, child marriage is neither void nor voidable under the Hindu Marriage Act. Later, under Section 18 (a), it assigns penal consequences to the contracting parties in a child marriage, which in this case would be the children, for 2 years rigorous imprisonment along with a fine [13].

Under Muslim Personal Law, which is not codified in India, but derived from multiple sources such as the Quran, Hadis, Ijmas, and Qiyas. The valid age to marriage as interpreted is said to begin post the onset of puberty, or 15 years of age, whichever comes earlier [14]. And, any marriage under 7 years is considered void ab initio. Further, even someone who has not attained puberty can be married with the consent of a guardian [15]. Section 2 (vii) of The Dissolution Of Muslim Marriages Act, 1939 read with section 275 of Mulla’s Principle of Mohamedan Law provided a girl child the option of puberty where if she is given in marriage by her father or other guardian before attaining the age of 15 years, then in such a situation, she could seek dissolution of the marriage provided that she repudiates the marriage before attaining 18 years of age, and also, that it should occur prior to the consummation of the marriage.

The need for such a section highlights the validity of such a marriage in Muslim Personal law in case it is not repudiated by the girl child.

Under Section 3 of the Christian Marriage Act, 1872, a minor according to age has been defined as a person under 21 years of age. Section 19 of the act stipulates the requirement of consent of a guardian to approve the marriage of such a minor for the marriage to be held valid. Further, the Act under section 15, 18, 22, 39, 42(b), and 43 specifically provides for the requirements which need to be met for different situations in case of a marriage between minors so that it may be held valid in the eyes of law, thereby granting it full legitimacy.

The Special Marriages Act, 1954, under section 4 (c) states the requirement of a male to be 21 years and of a female to be 18 years, for a marriage to be held valid. Further, unlike HMA, the Special Marriages Act under section 24(1)(i), declares a marriage null and void if the requirements under clause (c) of Section 4 are not met.

Additionally, the Parsi Marriage and Divorce Act, 1936 under section 3(c) declares the valid age of marriage to be 21 years for a male and 18 years for a female. Further, in the absence of provisions being actively omitted or selected as in the Hindu Marriage Act, then, unless all requirements under section 3 are met, including sub-section (c) then such a marriage is void ab initio.

Judicial Interpretation

The general trend followed by various high courts since earlier times has been to uphold child marriage as valid, while citing the relevant sections from the various personal laws. Except a few decisions, one can find a judge’s seal of approval on child marriages.

In 1962, the Madras High court in Sivanandy V. Bhagwathyamm [16] clarified and spoke about the inadequacy of the CMRA. It highlighted that there is no provision which renders a marriage invalid, and then went on to clarify that the validity of marriage is beyond the subject of this act. Further, the court went on to highlight the validity under HMA, and stated that “A minor’s marriage without the consent of the guardian can be held to be valid also on the application of the doctrine of factum valet.”

In 1963, the Himachal Pradesh High Court can be seen reiterating the same in Naumi V. Narottam [17], where it was held that a child marriage is neither void nor voidable under HMA, with no mention of the CMRA. Budhan V. Mamraj [18] is a 1970 judgement of the Punjab and Haryana High Court which ruled
against the popular perception and trend and observed that a marriage may not be valid if it does not meet the age requirement, but the same cannot be an answer for a RCR petition. The P&H high court upheld the same while delivering a judgement in 1972 in Krishni Devi v. Tulsan [19].

However, the 59th Law Commission report in 1974 [20] cleared the ambiguity created by this judgement and held child marriages to be valid marriages under the HMA. The Andhra Pradesh high court in P.A. Sarramma v. G. Ganpatalu [21], 1975 held all child marriages to be void ab initio. However, the full bench of the same high court in 1977 overturned the previous judgement.

As the HMA only confers validity to children born out of void or voidable marriages therefore, it was believed that such a decision will render innocent children ‘bastards’. The Supreme Court very interestingly in 1978 [22] mentioned child marriages to be an example which does not render a marriage void but only punishable.

The Delhi High Court in the year 1999, in Neetu Singh V. State [23] quashed a lower court order of sending an under aged bride to Nari Niketan. It held that the HMA only requires age to be a ground for voidability, further, it pronounced the penal punishment set out under Section 18. These cases have further held the natural guardianship of the minor girl, that is, transferred to her husband under the Hindu Minority and Guardianship act. The same was reiterated and followed in early 2000s in Manish Singh V. State Govt. of NCT [24], and Ravi Kumar V. The State [25].

With the coming of the PCMA in 2006, a new batch of cases now came to light. These were cases related to the elopement of children, and the parents or guardians seeking to render the marriage void ab initio claiming the ground of kidnapping which renders a marriage void under section 12 of the PCMA.

In 2009, in Amrinder Kaur V. State of Punjab and Haryana [26], the court refused the couple to
be granted protection from the girl’s family who were threatening them. It held that the bride who was 16 at the time of marriage was enticed out of lawful guardianship and therefore, the same falls under section 12 of the PCMA, rendering the marriage void. The Delhi High Court in Jitender Kumar Sharma V. State and Another, held that the PCMA is in fact a secular law and has an overriding effect over personal laws.

Further, with respect to the application of section 12, the court read Sections 6 and 14 of the Hindu Minority and Guardianship Act and presented a tolerant view where it held that the girl is capable enough for deciding for herself and hence, cannot be forced into living with her parents or in a Nari Niketan. The question of age of discretion again came up in 2011 in front of the Madras High court in T Sivakumar V.
Inspector of Police, Thiruvallur Town Police Station & others [27]. The court held that the marriage is not valid in a strict sense, and not invalid either. Further, as per the court, keeping in mind the provisions of the PCMA be said that the husband cannot be the natural guardian, even if the female child expresses her desire.

However, with respect to the age of discretion, the court believed that the age may be determined per facts and circumstances and in the present case, where the girl can be said to be capable of making a decision, then it cannot compel the girl to live with her parents and may entrust her in the custody of a fit person subject to her volition.

The attitude of the courts has been similar with respect to the Muslim Personal Law, where it was usually said to overrule the PCMA. In 1980, the Patna High court in Md. Idris V. State of Bihar & Ors [28], held that there is no requirement of consent for marriage from parents post the age of puberty, and article 251 of Mulla’s Principle of Mahomedan Law was referred. The Delhi Hight court in 2006, in Vivek Kumar v. The State [29] held that no law prohibits a girl under 18 years to fall in love and upheld the validity of a marriage after eloping under Muslim Personal law. In Shamsuddin v. State [30], the passing of the age of puberty of the girl child was again highlighted and therefore the immunity from Section 12, PCMA was again granted.

The Delhi high court also held the same in a 2012 judgement, that is, in Mrs. Tahra Begum V. State of Delhi & Ors. [31] the court upheld that the ‘option of puberty’ or khiyar-ul-bulugh must apply in consonance with PCMA. In this case, the minor girl expressed her choice to reside with her husband rather than her parents and the court upheld her agency and choice, over her age and minority status. However, the same Delhi High Court in another 2012 judgement, Association for Social Justice and Research V. Union of India [32], had upheld the overriding power of the PCMA over all personal laws, referring to it as a ‘special act’.

The most recent opportunity for the Supreme Court to voice its opinion on the validity of child marriages was in Hardev Singh V. Harpreet Kaur [33] in 2019. However, the court absolved all liability and said that “by way of abundant caution, we wish to clarify that we are not commenting on the validity of marriages entered into by a man aged between eighteen and twenty one years and an adult woman.”

As can be inferred, apart from the odd judgement, the courts have largely held child marriages to be valid under Indian law and not attempted to present anything binding to prevent this social evil from continuing.

Conclusion

Therefore, the Indian law as it stands on inadequate and inept grounds to curb the societal evil of child marriage. The punishments meted out under the PCMA and previously the CMRA do not serve the purpose of deterring child marriages. As it in itself plays a negative role where children many a times do not wish to see their parents behind bars.

The large-scale recognition of child marriage, and a reluctance of the government to fill the same void at the first instance is appalling when one considers its impact on the development of a child read in consonance with the various international treaties and conventions, such as CEDAW and CRC, which India has signed and ratified. As was highlighted in the NHFS-IV, the majority of the cases take place in the rural areas, and therefore, an effort to generate public awareness about the detrimental repercussions of the said practice, which leads to the multiple violations of one’s basic rights must be made.

An effective way to curb child marriages would be the ratification and implementation of obligations under the Convention of Consent, Minimum Age, and Registration of Marriages. As the situation stands now, change must begin with at least a uniform, secular act overriding all personal laws with respect to the minimum age of marriage.

The states and centre have been advised by the Supreme Court in Independent Thought V. Union of India, to follow the Karnataka model [34], which does not only uphold the application of the PCMA above all personal laws but has inserted a sub-section in section 3 of the PCMA and declared all child marriages henceforth to be void ab initio.

References:

  1. National Family Health Survey, available at: National Family Health Survey (rchiips.org)
  2. Treaties, Conventions and Agreements of the United Nations available at: Treaties, Conventions and
    Agreements | Global Library (jgu.edu.in)
  3. Supra 2
  4. UN Department of Public Information, “Women – The Right to Reproductive and Sexual Health” (1997)
  5. UNICEF, “Annual Report” (2018)
  6. Akshaya Tritiya- Hotbed of Child Marriages, available at:
    https://www.aljazeera.com/features/2012/5/4/akshaya-tritiya-hotbed-of-child-marriages
  7. National Commission for Women, “Annual report” (1995-96)
  8. National Human Rights Commission, “Annual report” (2001-02)
  9. National Commission for Women, “Annual Report” (1995-96)
  10. Independent Thought V. Union of India, LNIND 2017 SC 12307
  11. Law Commission of India, “205th Report on Proposal to Amend the Prohibition of Child Marriage Act,2006 and Allied Laws.” (February, 2008)
  12. Supra 10
  13. Dr. Vandana. "Child Marriage Under Hindu Personal Law: Factum Valet or An Issue for Protection Of Human Rights Of Women" ILI Law Review, Summer Issue, Volume I, 2017
  14. Dinshaw Mulla, Section 270 of Mulla’s Principle of Mahomedan Law (20th Edition)
  15. Ibid
  16. B Sivanandy V. P Bhagavathy Amma, LNIND 1961 Mad 54
  17. Naumi v. Narotam, LNIND 1962 HP 9
  18. Amrinder Kaur v. State of Punjab, LQ 2014 HC 2832
  19. Krishni Devi v. Tulsan Devi, AIR 1972 P&H 30
  20. Law Commission of India, “59th Report on Hindu Marriage Act, 1955, and Special Marriage Act, 1954” (Ministry of Law, Justice and Company Affairs, Government of India, 1974)
  21. Panchireddi Appala Suramma v. Gadela Ganapatlu, AIR 1975 AP 193
  22. Lila Gupta v. Laxmi Narayan, 1978 AIR 1351
  23. Nitu Singh V. The State, LNIND 1999 Del 44
  24. Manish Singh vs State Govt Of NCT, AIR 2006 Delhi 37
  25. Ravi Kumar v. The State, 124 (2005) DLT 1, II (2005) DMC 731
  26. Amrinder Kaur v. State of Punjab, LQ 2014 HC 2832
  27. T Sivakumar v. The Inspector Of Police Thiruvallur Town Police Station, LNIND 2011 Mad 4101
  28. Md. Idris vs State Of Bihar And Ors, 1980 CriLJ 764
  29. Vivek Kumar v. The State, MANU/DE/7222/2007
  30. Shamsuddin vs State, MANU/DE/2189/2009
  31. Mrs. Tahra begum v. State of Delhi, LNIND 2012 Del 1139
  32. Association For Social Justice v. Union of India, 2010 SCC OnLine Del1964
  33. Hardev Singh v. Harpreet Kaur, LNIND 2019 SC 932
  34. Gupta, Pallavi. “Child Marriages and the Law: Contemporary Concerns.” Economic and Political Weekly, vol. 47, no. 43, 2012, 49–55. JSTOR, available at: www.jstor.org/stable/41720300

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