Recognition of Foreign Decree in Foreign Marriages

Marriage and matrimonial causes raise questions where there is conflict of laws viz., where the marriage is contracted between persons governed by different laws. The parties in question may have contracted marriage which, though valid, according to the lex loci celebrationis, may not be valid marriage according to the Indian law. When such a case of conflict of law arises in the Indian Courts the law to be applied will depend upon the rules of Private International law as recognised in India. A case of Indian conflict of laws may require that the law of a foreign country ought to be applied in a given situation which contains a foreign element. An understanding of foreign law in a parallel jurisdiction would be a useful guideline in determining the rules of Private International Law in India.