Marriage Under Nigerian Law: Customary Marriage, Statutory Marriage, Validity And Succession

By C.K. Anyanwu, Ll.M., P.N. Vitalis, Esq. Precious Chidiadi Eti, Esq.

Introduction

Marriage under Nigerian law can take different forms, including marriage under the Marriage Act, customary law marriage, Islamic marriage, and marriages celebrated in licensed places of worship. Because these forms of marriage operate under different legal rules, questions often arise about whether one form of marriage affects another, whether a marriage is legally valid, how a marriage can be proved, and what happens to the estate of a person who dies intestate. These issues have been considered in several decisions of the Nigerian appellate courts. The courts have examined, among other things, the effect of a subsequent statutory marriage on an earlier customary relationship, the circumstances that can make a marriage void or voidable, procedural defects, requirements for a valid customary marriage, proof of marriage, church marriages, and succession to the estate of a person married under the Marriage Act. This article discusses these principles in simple terms, with particular attention paid to marriage under the Act and customary marriage.

MEANING OF MARRIAGE UNDER THE ACT

Marriage under the Marriage Act generally means the legal union of a couple as spouses. In other words, it is the voluntary union for life of one man and one woman to the exclusion of all others.

See: Amobi v. Nzegwu (2014) 2 NWLR (Pt. 1392) 510 S.C.

Different Forms of Marriage Recognized Under Nigerian Law

The courts have recognized different forms of marriage under Nigerian law.

In Obiozor v. Nnamua (2014) LPELR-23041(CA), the Court of Appeal stated:

‘I also agree with the submission of Learned Counsel for the respondent that under Nigerian law, a marriage can be either a marriage under the Marriage Act or customary Islamic law marriage.’

The court referred to Obiekwe v. Obiekwe (1963) 1 NLR 196, where Palmer J held as follows:

‘if the parties had not been validly married under the Ordinance, then either they are married under the custom or they are not married at all.’ (Per EMMANUEL AKOMAYE AGIM, JCA, Pp 80 – 80 Paras A – C)

However, these different forms of marriage do not necessarily have identical legal consequences. For example, a customary marriage is governed principally by the applicable customary law, while a statutory marriage is governed by the Marriage Act and, in appropriate matters, the Matrimonial Causes Act.

In Sunmonu v. Sunmonu (2021) LPELR-56002(CA), the Court of Appeal considered section 69 of the Matrimonial Causes Act and stated that, for purposes of the Matrimonial Causes Act, marriage does not include a marriage entered into according to Muslim rites or other customary law. The court relied on Enwezor v. Enwezor (2012) LPELR-8544 C.A., where Mukhtar, JCA, held inter alia:

‘The marriage under the Matrimonial Causes Act for purposes of maintenance, custody and settlements does not include one conducted under customary law.’

PROOF OF MARRIAGE UNDER THE ACT

Another important issue in matrimonial cases is the evidence required to establish that a marriage exists.

In Osho & Ors v. Phillips & Ors (1972) LPELR-2802(SC), the Supreme Court stated:

‘Section 32 of the Marriage Act, a marriage could be proved by the production of a copy of the certificate of marriage filed in the office of the registrar.’ (Per CHARLES OLUSOJI MADARIKAN, JSC, Pp 9 – 10 Paras F – A)

Furthermore, the approach in Adeoye v. Adeoye & Anor (2024) LPELR-62221(CA) appears more restrictive in the particular context considered by that court. The Court of Appeal held:

‘The only proof of marriage acceptable under the law is a marriage certificate, whether original or a Certified True Copy under Section 86 of the Matrimonial Causes Act, 1970 from either Nigeria or elsewhere. The Matrimonial Causes Act certainly did not specify an advert in the Newspaper for a change of name to constitute proof of marriage under the law.’ (Per ADEBUKUNOLA ADEOTI IBIRONKE BANJOKO, JCA, Pp 72 – 72 Paras A – B)

However, in Anyaegbunam v. Anyaegbunam (1973) LPELR-507(SC), the Supreme Court made it clear that a marriage certificate is not necessarily the only way to establish the existence of a marriage:

‘…it will be inappropriate to suggest that the only way to prove a birth, death or marriage is by the production of the relevant certificate or a certified copy thereof. Thus, where there is evidence of a ceremony of marriage having been gone through, followed by the cohabitation of the parties, everything necessary for the validity of the marriage will be presumed, in the absence of decisive evidence to the contrary…’ (Per ATANDA FATAI-WILLIAMS, JSC, Pp 14 – 15 Paras D – C)

THE NATURE OF MARRIAGE UNDER THE MARRIAGE ACT

In Bibilari v. Bibilari (2011) 13 NWLR (Pt. 1264) 207 CA, the Court of Appeal stated that:

‘A marriage under the Marriage Act is between two persons that is, the husband and wife. This union is what the Matrimonial Causes Act recognizes.’

The court also emphasized that disputes involving other members of the extended family do not automatically amount to grounds for dissolving a statutory marriage.

Similarly, in Amobi v. Nzekwu (2014) 2 NWLR (Pt. 1392) 510 SC, the Supreme Court described marriage under the Marriage Act generally as the legal union of a couple as spouses:

”marriage’ under the Marriage Act generally means the legal union of a couple as spouses. In other words, it is the voluntary union for life of one man and one woman to the exclusion of all others.’

The court also stressed that an existing statutory marriage must be properly terminated before another marriage can validly be contracted.

MARRIAGE CELEBRATED IN CHURCH

A marriage celebrated in a church may also constitute a statutory marriage where the requirements of the Marriage Act are satisfied.

In Motoh v. Motoh (2010) LPELR-8643(CA), the Court of Appeal considered the status of church marriages under the Marriage Act. The court explained that section 21 of the Marriage Act permits marriage to be celebrated in a licensed place of worship by a recognized minister, in accordance with the rites of the relevant church.

‘Under Sections 21 – 26 of the Marriage Act, a marriage in facie ecclesiae, a marriage celebrated or solemnized in a church service is a marriage under the Act irrespective of what other sacramental significance and value the adherents of the said church may wish to attach to such celebration.’

The court identified three categories of marriage recognized under the Marriage Act:

1. Normal registry marriages;
2. Marriages by special licence; and
3. Marriages celebrated in places of worship licensed for that purpose under section 6 of the Marriage Act. (Per ABDU ABOKI, JCA, Pp 51 – 57 Paras C – E)

The same principle was discussed in Agbakoba v. A-G, Federation & Anor (2021) LPELR-55906(CA). The court explained that where a couple simply has a religious ceremony in a church without complying with the Marriage Act, that ceremony may be recognized within the religious institution but does not automatically become a statutory marriage.

‘If they decided to simply opt for a marriage in the Catholic Church, with divine blessings pronounced on them, that would suffice as a marriage under the Catholic Church… while such marriage celebrated within the Catholic Church, without compliance with the Marriage Act, may be recognized as a valid marriage within the Catholic Church, it will not be recognized as a statutory marriage.’

However, where the church is licensed under the Marriage Act and the couple actually marries under the Act, the marriage is a statutory marriage. (Per ONYEKACHI AJA OTISI, JCA, Pp 47 – 48 Paras A – C)

WHEN IS A MARRIAGE VOID?

The courts have repeatedly stated that certain marriages are legally invalid from the beginning (void ab initio).

In Ogwuche v. Odeh & Ors (2022) LPELR-58152(CA), the Court of Appeal considered the effect of an existing marriage on a subsequent marriage. Section 3(1) of the Matrimonial Causes Act provides circumstances in which a marriage is void, including where one of the parties is already married to another person. Similarly, section 33(1) of the Marriage Act provides that a marriage is invalid where, at the time of its celebration, either party was already married under customary law or under the Act to another person.

The Court of Appeal explained:

‘Now, by Section 3(1) of the Matrimonial Causes Act 1970, a marriage shall be void in the following circumstances namely where – (a) Either of the parties is at the time of the marriage already married to someone else. …’

The court further stated that where there is no evidence that an earlier marriage had been validly dissolved, a subsequent marriage may be a nullity.

‘It never existed in the eyes of the law. It is not just voidable but void ab initio. It was dead on arrival and without any legal consequences whatsoever.’ (Per BIOBELE ABRAHAM GEORGEWILL, JCA, Pp 35 – 37 Paras D – D)

This principle is also reflected in the recent case of Sogules v. Sogules (2026) LPELR-83920(CA). The Court of Appeal stated that under section 3 of the Matrimonial Causes Act, a marriage is void where, at the time of its celebration, either party is already lawfully married to another person. The court described such a marriage as void ab initio, meaning that it is treated as having had no legal effect from the beginning.

The court also referred to Towoeni v. Towoeni (2001) 12 NWLR (Pt. 727) 445 C.A., concerning bigamous statutory marriages, and Nasiru v. Bindawa (2006) 1 NWLR (Pt. 961) 355 C.A., concerning the effect of a void act. (Per FADAWU UMARU, JCA, Pp 21 – 23 Paras D – E)

WHEN IS A MARRIAGE VOIDABLE?

While a void marriage is invalid from inception, Nigerian law also recognizes voidable marriages. Under Section 5(1) of the Matrimonial Causes Act, a marriage that takes place after the commencement of the Act (not being a void marriage) shall be voidable in the following cases, and not otherwise, where at the time of the marriage:

1. Either party to the marriage is incapable of consummating the marriage;
2. Either party to the marriage is:

Of unsound mind,

A mental defective, or

Subject to recurrent attacks of insanity or epilepsy;

3. Either party to the marriage is suffering from a venereal disease in a communicable form; or
4. The wife is pregnant by a person other than the husband.

Section 5(2) defines a ‘mental defective’ as a person who, owing to an arrested or incomplete development of mind (whether arising from inherent causes or induced by disease or injury), requires oversight, care, or control for their own protection or for the protection of others, and is by reason of that fact unfitted for the responsibilities of marriage.

Unlike a void marriage, a voidable marriage remains valid and subsisting for all legal purposes until a competent court issues a decree of nullity dissolving it.

WHEN CAN A MARRIAGE CEREMONY BE DECLARED INVALID BECAUSE OF PROCEDURAL DEFECTS?

The Marriage Act sets out explicit procedural rules regarding notices, certificates, and licences before a marriage can be celebrated.

In Obiozor v. Nnamua (2014) LPELR-23041(CA), the Court of Appeal examined the statutory framework governing these requirements.

Section 13 of the Marriage Act empowers the Minister, upon proof by affidavit that there is no lawful impediment and that necessary consents have been obtained, to dispense with notice and a registrar’s certificate by granting a licence (Form D) authorizing the celebration.

Section 22 of the Marriage Act strictly prohibits a minister from celebrating any marriage without receiving either the registrar’s certificate or a licence issued under Section 13.

Section 33(2)(c) & (3) of the Marriage Act mandates that a marriage shall be null and void if both parties knowingly and willfully acquiesce in its celebration without a registrar’s certificate of notice or a Section 13 licence.

Reviewing these provisions alongside the Supreme Court’s decision in Anyaegbunam v. Anyaegbunam (supra), Emmanuel Akomaye Agim, JCA, held:

‘In the absence of evidence that the registrar’s certificate or a minister’s license was obtained and delivered to A. F. D. Mgbemena before he celebrated the marriage or that the omission to obtain it was not willful or knowingly, the ceremony of marriage, even if it is proved to have held, will be void… The respondent/appellant testified in categorical terms that no registrar’s certificate was obtained… This omission on her part not only makes the purported marriage null and void, it also lends additional support to our view that the learned trial judge, faced with all these irregularities, was in error in entertaining the petition.’ (Pp 71–73 Paras G–D)

Crucially, Nigerian courts distinguish between deliberate non-compliance and administrative failure. Under Section 33(2)(c), non-compliance renders a marriage void only if both parties knowingly and willfully acted in defiance of the law.

Where parties act in good faith and cohabit as husband and wife, a mere administrative omission by church or registry officials (“the sin of the registry”) or the inability to produce a certificate in court will not invalidate the union.

See: Halliburton Energy Services (Nig.) Ltd. v. Manson & Ors (2025) LPELR-81445(SC); Ike v. Ike & Anor (2018) LPELR-44782(CA).

IS A VOID MARRIAGE STILL A MARRIAGE?

There is an important distinction between saying that a marriage is ‘void’ and saying that no marriage ceremony took place at all.

In Oghoyone v. Oghoyone (2010) LPELR-4689(CA), the Court of Appeal considered the meaning of ‘marriage’ under section 69 of the Matrimonial Causes Act. The court held:

‘section 69 states that ‘marriage’ includes a purported marriage that is void. A void marriage is a marriage that produces no legal consequences. That is to say it is a marriage that never took place. See Section 3(1) of the Matrimonial Cause Act. A void marriage is still a marriage by the provisions of Section 69 supra.’ (Per OLABODE RHODES-VIVOUR, JCA, Pp 11 – 11 Paras D – F)

This illustrates the technical nature of matrimonial law. A ceremony may be described as a marriage for certain legal purposes even though the law treats the marriage itself as void.

CAN A PERSON ASSUME THAT AN EARLIER MARRIAGE HAS BEEN DISSOLVED?

It is not enough for a person to claim that an earlier marriage has ended. Where the validity of a later marriage depends on the dissolution of an earlier marriage, the person relying on the alleged dissolution must prove it.

This was considered in Okwusogu v. Okwusogu & Ors (2022) LPELR-58673(CA). The court held that the burden was on the appellant to prove that her previous marriage had been properly dissolved before she entered into another marriage.

The Court of Appeal held:

‘By carefully reading the paragraph 1 of the Appellant’s pleading in Reply, it is rather clear that she wanted badly to have the Court believe the existence of the fact she legally ended her marital relationship with Mr. Peter Umunna of her first marriage before contracting her subsequent marriage with Akunne Joshua O. Okwusogu. If that be the case as indeed it is then, the onus is on her (Appellant) to prove the fact that she ended her marriage with Mr. Peter Umunna before her subsequent marriage with Late Akunne Joshua O. Okwusogu…’ (Per FREDERICK OZIAKPONO OHO, JCA, Pp 52 – 55 Paras F – F)

The court further held that proper proof of dissolution was an order of court dissolving the marriage. Merely separating, agreeing to go separate ways, or describing a marriage as having ‘broken down’ does not by itself establish legal dissolution.

CAN AN EXISTING CUSTOMARY LAW MARRIAGE AFFECT A SUBSEQUENT STATUTORY MARRIAGE?

The law also protects an existing customary marriage against an attempted subsequent statutory marriage involving another person.

In Nola & Ors v. Graham-Douglas & Anor (2019) LPELR-48285(CA), the court considered section 33(1) of the Marriage Act, which provides:

‘No Marriage in Nigeria shall be valid where either of the parties thereto at the times of the celebration of such marriage is married under Customary law to any person other than the person with whom such marriage is had.’

The Court of Appeal accepted the trial court’s reasoning that the provision gives legal recognition to an existing customary marriage.

‘The above provision is very clear, it gives due respect and credence to a preexisting customary marriage. It provides no dichotomy between a marriage under the Act and under Customary Law in the sense of one being main and the other minor…’ (Per ISAIAH OLUFEMI AKEJU, JCA, Pp 14 – 16 Paras E – A)

The court therefore held that, where there was an existing customary marriage between the deceased and his first wife, his subsequent statutory marriage to another woman was invalid.

A similar position was taken in Okafor & Ors v. Okafor & Anor (2022) LPELR-59136(CA), where the court held that a man who had already contracted a statutory marriage could not legally contract another marriage under customary law while the statutory marriage remained in existence (Per PATRICIA AJUMA MAHMOUD, JCA, Pp 14 – 14 Paras A – E).

WHAT MAKES A VALID CUSTOMARY MARRIAGE?

Customary marriages are governed by the customs of the particular community concerned. However, Nigerian courts have identified certain broad requirements.

In Obi & Ors v. Bosah & Ors (2019) LPELR-47243(CA), the Court of Appeal held:

‘It is the law that there are two essentials of a valid customary marriage. These are (1) payment of bride price and handing over of the bride to the groom.’ (Per MISITURA OMODERE BOLAJI-YUSUFF, JCA, Pp 33 – 33 Paras D – F; see also Agbeja v. Agbeja (1985) 3 NWLR (Pt. 11) 11 C.A. and Okolonwamu v. Okolonwamu (2014) LPELR-22631(CA).

A more detailed explanation can be found in Nsirim v. Nsirim (1995) 9 NWLR (Pt. 418) 144 CA:

1. The parties must have the capacity to marry each other under the applicable customary law.
2. There must be payment of dowry or bride price to the parent or guardian of the bride.
3. There must be a marriage ceremony and the handing over of the woman to the man’s family.

Failure to establish these requirements can be fatal to a claim, as demonstrated in Anionwu & Anor v. Anionwu & Anor (2009) LPELR-8754(CA), where the court found that the alleged customary marriage had not been sufficiently proved due to lack of evidence of bride price payment (Per AMIRU SANUSI, JCA, Pp 60 – 62 Paras C – A).

PRESUMPTION OF EXISTENCE OF CUSTOMARY MARRIAGE

For customary or Islamic marriages, the Evidence Act also provides an important presumption.

In Ekong & Anor v. Akpan (2020) LPELR-49575(CA), the court referred to section 166 of the Evidence Act, which provides that where there is evidence satisfactory to the court that a man and woman have cohabited as husband and wife under Islamic or customary law, the court may presume the existence of a valid and subsisting marriage unless the contrary is proved.

EFFECT OF MARRIAGE UNDER THE MARRIAGE ACT ON AN EXISTING WILL

One important issue considered by the Supreme Court in Jadesimi v. Okotie-Eboh & Ors (1996) LPELR-1590(SC) was whether a person who had already made a will automatically revoked that will by subsequently contracting a marriage under the Marriage Act.

The court considered the Nigerian situation and the common practice of couples undergoing traditional marriage or engagement before later celebrating their marriage under the Marriage Act. The court observed that such traditional ceremonies are generally not intended to be cancelled or replaced by the statutory marriage. Instead, the statutory marriage usually supplements the earlier traditional ceremony.

The Supreme Court, per Muhammadu Lawal Uwais, JSC, held as follows:

‘It is a matter of common knowledge that most people in Nigeria who contract marriages under the Marriage Act, undergo a form of customary marriage earlier as a matter of practice and adherence to the custom of their forefathers. Some refer to such practice as “traditional engagement” while others simply refer to it as solemnization of customary marriage. It is never intended by the practice that the marriage under the Marriage Act should nullify the customary marriage or engagement but rather that it would supplement the practice or custom. The parties are of course aware that by applying the Marriage Act to their relationship, their marriage would become monogamous. However, it is a matter of common knowledge that in spite of the punishment provided under Section 47 of the Marriage Act against any of the parties entering another customary marriage, the male folk in particular observe the restriction more in breach than obedience with impunity. In my opinion, therefore, the circumstances of Nigeria militate against the application of Section 18 of the Wills Act, 1837 to nullify a will made prior to contracting a marriage under the Marriage Act.’

The court further relied on section 15 of the Wills Law of Western Nigeria, Cap. 133 of the Laws of Western Nigeria, 1959, which provides:

‘Every will made by a man or woman shall be revoked by his or her marriage (other than a marriage in accordance with customary law) except a will made in exercise of a power of appointment when the real or personal estate thereby appointed would not in default of such appointments pass to his or her heir, executor or administrator or the person entitled as his or her next of kin under any written law relating to the distribution of the estate of persons dying intestate.’ Per MUHAMMADU LAWAL UWAIS, JSC (Pp 25 – 26 Paras A – C).

The decision is important because it shows that the effect of marriage on an existing will cannot always be considered without looking at the particular form of marriage and the applicable Nigerian law.

TRADITIONAL ENGAGEMENT DOES NOT AUTOMATICALLY MEAN THAT A CUSTOMARY MARRIAGE EXISTS

It is important to distinguish between a customary marriage and the traditional ceremonies that often take place before a church or registry wedding.

In Salubi v. Nwariaku (1997) 5 NWLR (Pt. 505) 442 CA, the court held that merely paying dowry or going through preliminary customary practices before a church or registry wedding does not automatically make the eventual marriage a customary marriage.

The court recognized the common Nigerian practice in which couples undergo traditional ceremonies such as engagement or betrothal before celebrating their statutory marriage.

The principle is that the mere performance of such preliminary traditional ceremonies does not, by itself, determine the legal nature of the marriage.

This point fits with the observation of the Supreme Court in Jadesimi v. Okotie-Eboh & Ors (1996) LPELR-1590(SC) that many Nigerians undertake customary ceremonies before contracting marriage under the Marriage Act.

Therefore, the court will look at the nature and circumstances of the ceremonies and the intention of the parties rather than simply assuming that a traditional ceremony automatically created a customary marriage.

SUCCESSION WHERE A PERSON MARRIED UNDER THE MARRIAGE ACT DIES INTESTATE

The form of marriage can also have important consequences for inheritance.

Section 36(1) of the Marriage Act deals with persons subject to native law and custom who contract a marriage under the Act and subsequently die intestate.

In Okafor & Ors v. Okafor & Anor (2022) LPELR-59136(CA), the Court of Appeal considered section 36(1) of the Marriage Act and explained that the estate of a person who falls within the provision is distributed according to the applicable statutory rules rather than contrary customary rules.

The court held:

‘where any person who is subject to native law and custom contracts a marriage in accordance with the provisions of this ordinance and such a person dies intestate subsequently to the commencement of this ordinance leaving a widow or husband, or any issue of such marriage; and also where… the personal property of such intestate and also any real property of which the said intestate might have disposed by will, shall be distributed in accordance with the provisions of the law of England relating to the distribution of the personal estates of intestate, any native law or custom to the contrary notwithstanding.’

Also, in Obusez v. Obusez (2007) 10 NWLR (Pt. 1043) 430 SC, the Supreme Court similarly explained the effect of section 36(1) of the Marriage Act. Where the statutory conditions are satisfied, the estate is distributed according to the applicable statutory rules notwithstanding contrary customary law.

THE POSITION OF A SPOUSE IN AN INTESTATE ESTATE

In Motoh v. Motoh (2011) 16 NWLR (Pt. 1274) 474 CA, the Court of Appeal considered succession to the estate of a person who had married under the statute and died intestate.

The court held that:

‘Where a man who marries under the statute dies intestate, his estate is only inheritable by the wife legally married under the Marriage Ordinance or Marriage Act.’

The court also referred to Osho v. Phillips (1972) All NLR 279; Cole v. Akinyele (1960) SCNLR 180; In Re: Williams WACA 156.

This demonstrates why establishing the legal nature of a marriage can become particularly important after the death of a spouse.

CUSTOMARY LAW AND THE DISTRIBUTION OF ESTATE

The application of customary law to succession is not always automatic. The particular circumstances of the deceased and the estate must be considered.

In Ayoriinde v. Kuforiji (2022) LPELR-56600(SC), the Supreme Court considered the relationship between customary law and English law in the distribution of an intestate estate.

The court referred to section 1(3) of the Administration of Estate Law and explained that customary law may govern the inheritance or succession of an estate where the relevant circumstances make customary law applicable.

The court also considered Olowu v. Olowu (1985) 3 NWLR (Pt. 13) 372, Coker v. Coker (1943) 7 NLR 55, and Cole v. Cole (1898) 1 NLR 15.

The Supreme Court emphasized that there is no absolute rule that one system of law will apply in every situation. Much depends on the facts and circumstances of the individual case. Per MARY UKAEGO PETER-ODILI, JSC (Pp 49 – 53 Paras D – F).

CONCLUSION

The Nigerian law of marriage involves several overlapping but distinct legal principles. The courts have consistently recognized that the legal consequences of a marriage depend greatly on the type of marriage involved and the circumstances in which it was celebrated. A person already married under the Marriage Act cannot validly contract another marriage during the subsistence of that marriage. Similarly, an existing customary marriage can prevent a subsequent statutory marriage to another person from being valid. A party relying on the dissolution of a previous marriage must be able to prove that the marriage was legally dissolved.

The courts have also identified essential requirements for a customary marriage, including capacity, payment of bride price or dowry, the marriage ceremony, and the handing over of the bride. At the same time, traditional engagement or preliminary customary ceremonies do not automatically establish that a customary marriage exists.

Proof of marriage is another important issue. Although a marriage certificate is an important form of evidence, the courts have recognized that, depending on the circumstances and the type of marriage, other evidence may establish the existence of a marriage. The precise requirements may differ between statutory and customary marriages.

Finally, the form of marriage can have significant consequences for inheritance. Where a person subject to customary law contracts a marriage under the Marriage Act and later dies intestate, section 36 of the Marriage Act may bring the estate within the statutory rules of distribution rather than the applicable customary rules.

The court will consider the type of marriage, the applicable law, whether an earlier marriage existed, whether it was properly dissolved, the evidence establishing the marriage, and the legal consequences that follow from that status. These distinctions are particularly important in disputes involving the validity of marriage, divorce, wills, and inheritance.

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