crafted rules that declared Gandharva marriage for most Hindus as inappropriate and disapproved (aprasasta), because traditional marriages were a source of their income, and Gandharva marriages made them poorer or obsolete. Indian courts' perspective In 1817, Gandharva marriages in India were ruled legal for some social groups by the Bengal Saddar Court. In 1930, Justice Abdur Rahim held that the marriage in Gandharva form was not valid in India. This ruling came from the Madras High Court, with the statement that amongst the Hindus, the Gandharva form of marriage was obsolete (as of 1930). This was appealed based on the fact that the case was in court is proof that Gandharva weddings among Hindus is not obsolete. In 1946, the Patna High Court in Kamani Devi v. Kameshwar Singh, ILR 25 Pat 58 = (AIR 1946 Pat 316) held that the relationship of husband and wife, created by Gandharva marriage is binding. The husband, the court ruled, cannot escape his responsibility of financially caring for his wife married in Gandharva form. The Patna High Court went further and held that the celebration of Gandharva form of marriage must be attended with nuptial rites and ceremonies including Homa (invocation before the sacred fire) and Saptapadi (the taking of seven steps by the groom and the bride together) for its validity. This ruling was cited in a decision by the Supreme Court in the case of Bhaurao v. State of Maharashtra. In a 1974 case, Justice Mukherji noted, "Gandharva form of marriage should not be regarded as concubinage or quasi-marital union, more so in the context of the modern Society and in the background of the forward thinking of the present law givers. The possibility of legal validity of this form of marriage in the whole of India in near future even without being backed by custom, is too notorious to be ignored. In a sense, Gandharva form of marriage is trying to come back very fast (in India), pushing parental domination to the background." Reemergence In modern India, particularly in urban regions, Gandharva marriage is re-emerging. One term for couples choosing their own partners is 'love marriage' in India which usually means a couple choosing each other of their own accord but in most cases following it up with Hindu wedding rituals. However, to that extent 'love marriages' do not fulfill the criterion of Gandharva marriage but the English term 'relationship'