## Facts

- A spouse filed a New York action seeking divorce and ancillary relief, alleging a Hindu marriage ceremony in India in 1952.
- After a nonjury trial, the Supreme Court (Nassau County) found the parties were validly married under Hindu law in 1952.
- The alleged marriage occurred before India’s Hindu Marriage Act of 1955, which later codified Hindu marriage and divorce law.
- The trial court’s finding required determining what rites, customs, and practices were necessary and sufficient for a valid Hindu marriage for a particular caste and region.
- The defendant challenged the determination as an unconstitutional religious adjudication not resolvable by neutral, secular legal standards.

## Issues

1. Whether a New York civil court may determine the validity of a purported 1952 Hindu marriage in India when the determination requires deciding religious rites, customs, and doctrine rather than applying neutral principles of secular law.
2. Whether the First Amendment bars such a determination and, if so, requires dismissal of the divorce action where the existence of a valid marriage is a necessary predicate.

## Decision

- The Appellate Division reversed the order determining a valid 1952 marriage.
- The court dismissed the complaint.
- The court held the validity determination could not be made using neutral principles of law and would improperly involve the court in a religious matter barred by the First Amendment.

## Legal Principles

- Civil courts may decide disputes touching on religion only if they can be resolved through objective, well-established principles of secular law (neutral principles).
- When adjudication requires interpreting or choosing among religious doctrines, rites, customs, or practices, the First Amendment precludes judicial resolution.
- Where the claimed validity of a marriage depends on uncodified, religion-based requirements (such as pre-statute religious marriage rites), and those requirements cannot be translated into neutral secular criteria, the court must decline to adjudicate, even if that forecloses divorce relief.

## Conclusion

Because determining whether the parties entered a valid Hindu marriage in India in 1952 required resolving religion-based questions about which ceremonial practices were necessary and sufficient, the First Amendment barred the inquiry; the appellate court therefore reversed and dismissed the divorce complaint.


Rukminamma Madireddy v. Subba Reddy Madireddy, 66 A.D.3d 647 (N.Y. App. Div. 2d Dep’t 2009)