The Supreme Court of India, in a judgment dated 19 September 2025, directed all States and Union Territories to frame rules under Section 6 of the Anand Marriage Act, 1909, to facilitate the registration of Sikh Anand Karaj marriages. A Bench comprising Justice Vikram Nath and Justice Sandeep Mehta issued the directive to remedy the longstanding gap between the statutory right to register Anand Karaj marriages and the absence of procedural machinery to exercise that right.
Background
The Anand Marriage Act, 1909, was originally enacted to validate marriages performed in accordance with the Sikh Anand Karaj ceremony. The Act was amended in 2012 by the Anand Marriage (Amendment) Act, which inserted Section 6 providing for the registration of Anand Karaj marriages. However, Section 6 required the State Governments and Union Territory administrations to frame rules prescribing the procedure and fees for such registration.
Despite the passage of over a decade since the 2012 amendment, a significant number of States and Union Territories had failed to frame the requisite rules, leaving Sikh couples without a functional mechanism to register their marriages under the Anand Marriage Act. This compelled many Sikh families to register marriages under other statutes not specifically designed for their religious ceremonies, causing practical difficulties and a sense of institutional neglect.
Key Holdings
The Supreme Court directed the following:
Mandatory rule-framing: All States and Union Territories that have not yet framed rules under Section 6 of the Anand Marriage Act, 1909 (as amended in 2012) were directed to do so within a prescribed timeframe.
Registration facilitation: The Court directed that once rules are framed, States must establish accessible registration facilities to ensure that Sikh couples can register Anand Karaj marriages without undue procedural burden or delay.
Statutory right must be effective: The Bench observed that a statutory right conferred by Parliament becomes illusory if the executive machinery necessary to exercise that right is not put in place. The failure to frame rules under Section 6 amounted to executive inaction that deprived citizens of a legal entitlement.
Compliance reporting: States and Union Territories were directed to report compliance to the Court, ensuring that the directive is translated into administrative action.
Implications for Practitioners
Family law practitioners advising Sikh clients can now point to a binding Supreme Court directive requiring States to establish Anand Karaj registration machinery. In States that have been non-compliant, this judgment provides the basis for mandamus proceedings if rules are not framed within the prescribed period.
For State law departments, immediate attention is required to draft and notify rules under Section 6. The rules must prescribe the registering authority, the form of application, the documentation required, the fee structure, and the form of the marriage certificate.
The broader significance of this judgment extends beyond Sikh personal law. It establishes the principle that where Parliament confers a registration right, executive inaction in framing enabling rules can be remedied through judicial direction — a principle potentially applicable to other statutory registration requirements that remain unimplemented across various domains.