सरला मुद्गल बनाम भारत संघ
| Citation | AIR 1995 SC 1531 |
| Court | Supreme Court of India |
| Date | 10 May 1995 |
| Year | 1995 |
| Bench | Kuldip Singh, R.M. Sahai JJ. |
| Acts/Articles | Article 44, Hindu Marriage Act, IPC Section 494 |
| Category | Constitutional Law |
Key Principle Established
A Hindu converting to Islam solely to contract a second marriage commits bigamy under Section 494 IPC. Strong call for Uniform Civil Code under Article 44.
Hindu men were converting to Islam solely to marry a second time, taking advantage of Muslim personal law which permits polygamy. Their first Hindu wives challenged this practice.
The Court held that a Hindu husband who converts to Islam and marries again is guilty of bigamy under Section 494 IPC. The first Hindu marriage remains valid and subsisting. The conversion to Islam for the sole purpose of contracting a second marriage is an abuse of personal law.
This judgment is one of the strongest judicial calls for a Uniform Civil Code under Article 44. It protected the rights of Hindu wives against husbands who sought to circumvent monogamy provisions through fraudulent conversion.
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Read AnalysisThis judgment summary is for educational and research purposes. While care has been taken to accurately represent the ratio and findings, for authoritative reference always consult the original judgment text from official sources (SCC Online, AIR, Manupatra, or court websites).
22+ years of practice before Punjab & Haryana High Court and Supreme Court of India.