Court case(1988) 3 SCC 513

Bhupinder Singh married Gurbax Kaur according to Sikh rites while his earlier marriage with another woman was subsisting, a fact he concealed from her. When she discovered it she filed a complaint for bigamy. He was convicted, and in the Supreme Court contended, among other things, that the complaint by the second wife was not maintainable because she was not his lawful wife and so not a person aggrieved, and that the second marriage had not been shown to be properly solemnised.

The Supreme Court dismissed the appeal and upheld the conviction. The woman whom the accused married while concealing his existing marriage is the person most directly wronged by the offence and is a "person aggrieved" entitled to complain under s. 198 CrPC, even though the marriage is void. The evidence showed that the marriage with her had been performed according to the customary rites, and the accused, who had himself gone through that ceremony and held her out as his wife, could not escape on the plea that the marriage was not validly solemnised.