Supreme Court has held in Labishwar Manjhi v. Pran Manjhi,(2000) 8 SCC 587, that if members of Tribes are Hinduised, the provisions of the HMA, 1955 would be applicable.
2) the manner in which the marriage had been conducted in the present matter and the customs being followed by the parties show that as in the case of Hindus, the marriage is conducted in front of the fire. The Hindu customary marriage involves the ceremony of Saptapadi which has also been performed in the present case.
3)members of a tribe voluntarily choose to follow Hindu customs, traditions and rites they cannot be kept out of the purview of the provisions of the HMA, 1955.