Facts: The appellant Nagalingam and his purported second wife, Kasturi, both residents of Tamil Nadu, entered into marriage at Thiruthani Temple within the state. Notably, Tamil Nadu has enacted a State amendment known as Section 7-A, which abolishes the requirement for a priest's presence for a marriage to be considered valid. Under this provision, parties to the marriage can solemnize their union in the presence of relatives, friends, or other individuals. Each party must verbally declare in a language understood by both that they accept the other as their spouse. Subsequently, the marriage is consummated through a simple ceremony, which may entail exchanging garlands, placing rings on each other's fingers, or tying a thali. Any of these rituals suffices to confer validity upon the marriage.

Sub-section (2)(a) of Section 7-A explicitly stipulates that marriages solemnized subsequent to the commencement of the Hindu Marriage (Tamil Nadu Amendment) Act, 1967, to which this provision pertains, shall be deemed legally valid, notwithstanding any provisions to the contrary in Section 7.

Additionally, sub-section (2)(b) asserts that marriages covered by this section, conducted prior to the aforementioned commencement, shall be retrospectively validated, irrespective of any conflicting provisions within Hindu law, customary practices, or prior legal enactments, judgments, decrees, or court orders.

The essentiality of the "saptapadi" ceremony for the validity of a marriage is contingent upon its acknowledgment by the parties as a requisite ritual according to their applicable matrimonial customs. However, in the present case, the appellant did not assert the indispensability of the "saptapadi" ceremony within the framework of their personal law. Instead, the provisions outlined in Section 7-A are pertinent to the parties involved.

The court concluded that a valid marriage existed between the appellant and the second accused, Kasturi. Consequently, the appellant was found guilty of bigamy as the subsequent marriage occurred while his earlier marriage, held on September 6, 1970, was still in effect.