Unregistered marriage certificate may still be used for collateral purposes despite lack of registration.

Under the Hyderabad Transfer of Property Act, a transaction among Mohammedans could still rest on an oral gift, and writing it down did not necessarily make registration compulsory. An unregistered document did not lose all evidentiary value merely because it could not operate as a registrable instrument. The document could still be admitted for a limited collateral purpose, and an unregistered marriage certificate was therefore not wholly inadmissible.

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Issues: Whether the marriage certificate and the alleged transfer in lieu of dower required compulsory registration, and whether an unregistered document could be admitted in evidence for a collateral purpose.

Analysis: The issue concerned the effect of the Hyderabad Transfer of Property Act on transactions relating to gifts among Mohammedans. The document was treated as evidence of the transaction, while the law permitted oral gift. Even where the transaction was reduced into writing, the question was whether lack of registration destroyed its evidentiary value altogether or only prevented it from operating as a registrable instrument. The reasoning recognised that an unregistered document could still be relied upon for a limited collateral purpose.

Conclusion: An unregistered marriage certificate was not wholly inadmissible and could be used for collateral purposes.

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