The Jharkhand High Court has held that the non-disclosure of a prior live-in relationship before marriage constitutes fraud as to a material fact under Section 12(1)(c) of the Hindu Marriage Act, 1955. The Court emphasised that while Hindu marriage is a sacrament and not a contract, the concealment of such a relationship to obtain consent renders the marriage voidable and liable to be annulled by a decree of nullity. BackgroundThe marriage between the parties was solemnised on 02 December 2015 as per Hindu rites. She later discovered that her husband had been in a live-in relationship with that woman prior to the marriage, a fact allegedly concealed from her and her family. Both the Hindu Marriage Act and Contract Act are not pari materia...the definition of fraud given under the Contract Act cannot be brought with lock, stock and barrel to a marriage which is sacrament".