Wedding photographs and videos decide more matrimonial cases than any statute — if they get into evidence. In Chandrahas v. Smt. Sunita, MFA Nos. 101273-101274 of 2021, decided on 21 September 2026, the Karnataka High Court confronted a husband’s claim that his 2015 marriage never validly happened, and upheld the family court’s twin decrees: his nullity suit dismissed, the wife’s petition for restitution of conjugal rights allowed. The doctrinal centrepiece: Section 14 of the Family Courts Act, 1984 permits family courts to receive electronic material without the Section 65-B certification that ordinary courts demand.
The dispute: a marriage denied
The parties’ marriage was solemnised — or, on the husband’s case, staged — on 22 November 2015. He sued for a declaration that the marriage was null and void, alleging absence of consent; she petitioned under Section 9 of the Hindu Marriage Act for restitution of conjugal rights after he abandoned her. The family court decided both against him, and the High Court’s Division Bench of Justices M.I. Arun and Raghavendra Seetharam Srivatsa affirmed, finding the ceremony proved by photographs, video recordings, invitation cards and the officiating priest’s testimony.
The evidentiary holding
The husband’s attack on the electronic material — that it lacked the Section 65-B certificate mandatory in ordinary litigation — met the statutory answer of Section 14 of the Family Courts Act. The Bench held that family courts may receive such material without the certification requirement, because the legislature intentionally freed these courts from strict admissibility rules to let them reach the truth of intimate disputes effectually. The certificate regime guards ordinary trials against unreliable secondary electronic records; Section 14 substitutes the family judge’s evaluative discretion for that gatekeeping.
Ordinary civil or criminal court
Electronic records are admissible as documents only on proof per the certification regime — Section 65-B Evidence Act for legacy proceedings, Section 63 BSA for new ones. No certificate, no admissibility (with narrow exceptions).
Family Court under Section 14
The court may receive any material that assists effectual adjudication, whether or not admissible under the Evidence Act. The contest shifts from admissibility to authenticity and weight.
What this means in practice
For parties relying on electronic material in family courts:
✓ Produce the material with its context — device, source, date — even though no certificate is demanded; weight is earned, not presumed.
✓ Corroborate where possible: the priest’s testimony here did as much work as the video.
✓ Preserve originals; an opponent alleging fabrication invites forensic comparison, and the party holding originals wins that exchange.
✓ Remember the limits: Section 14 governs family courts’ own proceedings. The same chats tendered in a parallel criminal case will face the ordinary certification regime.
The decision also carries a sobering message for spouses who deny solemnisation as a litigation strategy: marriages leave modern evidentiary trails — invitations, albums, videos, guests, officiants — and family courts are equipped to read them without technical obstruction. Nullity claims must stand on substantive grounds, not on evidentiary gamesmanship.
A converging national practice
High Courts have repeatedly endorsed the liberal reception of electronic material in family disputes — from WhatsApp exchanges in maintenance cases to call recordings in cruelty trials — while insisting that privacy and authenticity objections go to weight and, in appropriate cases, to costs. Chandrahas adds a clear Division Bench statement of the principle, and its logic will be immediately familiar to practitioners before Delhi’s family courts.
This article is for general information only and is not legal advice or a solicitation.
Frequently Asked Questions
What does Section 14 of the Family Courts Act actually say?
That a Family Court may receive as evidence any report, statement, document, information or matter that in its opinion may assist it to deal effectually with a dispute — whether or not it would be relevant or admissible under the Indian Evidence Act, 1872. It is a deliberate legislative loosening of technical admissibility rules for family disputes.
Does that mean certification rules never apply in family courts?
The Karnataka Division Bench held that Section 14 permits receipt of electronic evidence without the certificate that Section 65-B of the Evidence Act (now Section 63 of the BSA for new proceedings) requires in regular courts. Weight remains a separate question — the court still assesses authenticity, and a party alleging tampering can lead evidence to that effect.
What proved the marriage here?
Photographs and video recordings of the ceremony, invitation cards, and the testimony of the priest who performed it. Against that convergence, the husband’s case that the marriage was conducted without his consent failed in both courts.
How does this help litigants in Delhi?
Delhi’s family courts operate under the same Section 14. WhatsApp chats, call recordings, photographs and similar material can be placed before them without the certification battles that stall civil suits — though parties should still preserve originals and metadata, because credibility is always in play even when admissibility is not.