ValkyaEditorial

Matrimonial Law, 498A & Divorce — 36 Valkya Editorial digests

Matrimonial litigation — cruelty and dowry harassment under Section 498A (and its misuse), maintenance and permanent alimony, divorce on irretrievable breakdown, the Section 13B cooling-off period, and child custody. Digests tracking how the courts balance protection against weaponisation.

Supreme CourtSupreme Court of India

Amardeep Singh v. Harveen Kaur (2017): the s.13B(2) cooling-off period is directory, not mandatory

The Supreme Court held that the six-month waiting period for mutual-consent divorce under s.13B(2) of the Hindu Marriage Act is directory and may be waived where reconciliation is impossible, the statutory separation is over, and the parties have genuinely settled custody, maintenance and alimony. The waiting period exists to allow second thoughts, not to prolong an agreed parting.

Valkya Editorial··6 min
Supreme CourtSupreme Court of India

Geeta Mehrotra v. State of U.P. (2012): No s.498A prosecution of relatives on bald, omnibus allegations

The Supreme Court quashed a s.498A IPC and Dowry Prohibition Act prosecution against a husband's brother and unmarried sister, holding that relatives cannot be dragged into a matrimonial dispute on a casual reference to their names without specific allegations of active involvement. The decision deprecates the practice of roping in the entire household and treats it as an abuse of process.

Valkya Editorial··6 min
Supreme CourtSupreme Court of India

Kiran Jyot Maini v. Anish Pramod Patel (2024): the factors for fixing permanent alimony

The Supreme Court restated the broad factors a court must weigh in fixing permanent alimony — status, the wife's reasonable needs, qualifications and employment, independent income, the marital standard of living, sacrifices for the family, litigation costs and the husband's capacity. Dissolving the marriage under Article 142, it fixed a one-time settlement of roughly ₹2 crore, holding that alimony must secure a decent life without being punitive.

Valkya Editorial··6 min
Supreme CourtSupreme Court of India

Mohtashem Billah Malik v. Sana Aftab (2026): welfare of the child is paramount but not the sole factor in custody

In a cross-border custody dispute over two minor sons, the Supreme Court set aside the High Court's 'welfare alone' approach. The Court held that while the child's welfare is paramount, financial capacity, standard of living, comfort and education of the children — and the conduct of the parents — are all relevant. The matter was remanded for fresh consideration.

Valkya Editorial··6 min
High CourtHigh Court of Rajasthan

Satyapal Sharma v. State of Rajasthan (2026): pursuing a dowry case after taking ₹20 lakh alimony and a mutual divorce is an abuse of process

On 12 June 2026, the Rajasthan High Court held that a former wife who continued Section 498A IPC proceedings against her ex-husband and his family after accepting ₹20 lakh as alimony and obtaining a decree of mutual divorce was abusing the process of law. The Court rejected the argument that the criminal case stood wholly independent of the settled matrimonial dispute.

Valkya Editorial··6 min
LandmarkSupreme Court of India

Shilpa Sailesh v. Varun Sreenivasan (2023): Article 142 can dissolve a marriage on irretrievable breakdown

A five-judge Constitution Bench held that the Supreme Court may, under Article 142, dissolve a marriage that has irretrievably broken down to do complete justice — even without one spouse's consent and bypassing the family-court reference — and that the six-month cooling-off period under section 13B(2) of the Hindu Marriage Act is waivable in a fit case.

Valkya Editorial··7 min
Supreme CourtSupreme Court of India

SVT v. CA (2026): psychological testing of children in custody disputes only on demonstrable necessity

The Supreme Court held that psychological or psychiatric evaluation of children in custody and visitation disputes is not barred, but is permissible only on demonstrable necessity, with minimum intrusion, institutional neutrality and proportionality, the child's welfare paramount. Courts must distinguish therapeutic care from adversarial evaluation and guard against parental-alienation dynamics.

Valkya Editorial··7 min
Supreme CourtSupreme Court of India

Mary Roy v. State of Kerala (1986): equal inheritance for Syrian Christian women

In 1986 a two-judge Bench led by Bhagwati, CJI held that the discriminatory Travancore Christian Succession Act 1916 had already been repealed in 1951, so Syrian Christian daughters of former Travancore take an equal share with sons under the Indian Succession Act 1925. A digest of the facts, the statutory ratio, and the retrospectivity controversy that followed.

Valkya Editorial··8 min
Supreme CourtSupreme Court of India

Sarla Mudgal v. Union of India (1995): conversion, the second marriage, and bigamy under Section 494

In 1995 a two-judge Bench of the Supreme Court held that a Hindu husband who converts to Islam cannot validly contract a second marriage while his first Hindu marriage subsists — the second marriage is void and the convert is guilty of bigamy under Section 494 IPC. A digest of the facts, the ratio on conversion and bigamy, and the obiter call for a Uniform Civil Code.

Valkya Editorial··9 min
Supreme CourtSupreme Court of India

Animal Welfare Board of India v. A. Nagaraja (2014): Jallikattu, the Five Freedoms, and Article 21 for animals

In 2014 a two-judge Bench of the Supreme Court banned Jallikattu and bullock-cart races as cruelty under the Prevention of Cruelty to Animals Act, read the Five Freedoms into the statute, and gave the welfare of animals a constitutional vocabulary. A digest of the holding, the Five Freedoms standard, and how a 2023 Constitution Bench later distinguished the decision.

Valkya Editorial··9 min
Supreme CourtSupreme Court of India

ASD v. LCSIBD: career, child welfare and the limits of matrimonial cruelty

On 12 May 2026, a two-judge bench expunged findings of cruelty and desertion against a dentist wife who had relocated from Kargil to Ahmedabad for tertiary medical care and to pursue her practice, holding that 'marriage does not eclipse her individuality' and retaining the divorce decree on the ground of irretrievable breakdown under Article 142.

Valkya Editorial··10 min
High CourtKarnataka High Court

Income Tax Officer & CPIO v. Gulsanober: RTI section 8(1)(j) and a spouse's tax returns

On 21 February 2026, the Karnataka High Court set aside a CIC order directing disclosure of a husband's income tax returns to his wife under the RTI Act, holding that IT returns are 'personal information' exempt under section 8(1)(j) and issuing gender-neutral guidelines for financial-disclosure discovery in maintenance proceedings.

Valkya Editorial··9 min
High CourtPunjab & Haryana High Court

Maternal grandmother's locus to maintain a section 125 CrPC plea for a minor: Punjab & Haryana HC

Justice Neerja K. Kalson held that a maternal grandmother in actual care and custody of her granddaughter has sufficient eligibility to maintain a section 125 CrPC application on the minor's behalf where the parental relationship has broken down; the minor's statutory right to maintenance cannot be defeated by a technical objection to who instituted the petition.

Valkya Editorial··12 min
Supreme CourtSupreme Court of India

ADM Jabalpur v. Shivkant Shukla: the Emergency's habeas corpus case — and the dissent that was overruled into doctrine

On 28 April 1976, in the depths of the Emergency, a five-judge Constitution Bench held by 4:1 that a person detained under the Maintenance of Internal Security Act could not move habeas corpus because the right to life and personal liberty under Article 21 stood suspended by the Presidential Proclamation under Article 359. Justice H.R. Khanna's sole dissent — that life and liberty are not the Constitution's gift to be taken away by it — cost him the Chief Justiceship. Forty-one years later, in K.S. Puttaswamy v. Union of India, a nine-judge Bench explicitly overruled the majority and adopted the Khanna dissent as the constitutional position. A digest of the judgment, its setting, the dissent, the supersession, and the doctrine that has supplanted it.

Valkya Editorial··10 min
LandmarkSupreme Court of India

Danial Latifi v. Union of India: how the Supreme Court preserved Shah Bano's maintenance architecture through the 1986 Act

On 28 September 2001, a five-judge Constitution Bench upheld the constitutional validity of the Muslim Women (Protection of Rights on Divorce) Act, 1986 — but read its principal provision as requiring the husband to make reasonable and fair provision for the maintenance of the divorced wife beyond the iddat period, including for her future. The judgment is the foundational doctrinal contribution that preserved the maintenance architecture of Shah Bano through interpretation of the 1986 Act, and supplies the doctrinal frame within which the more recent Mohd Abdul Samad v. State of Telangana operates.

Valkya Editorial··9 min
Supreme CourtSupreme Court of India

Mohd Abdul Samad v. State of Telangana: divorced Muslim women, Section 125 CrPC, and the restoration of Shah Bano

On 10 July 2024, a two-judge bench of Justices B.V. Nagarathna and Augustine George Masih held that a divorced Muslim woman is entitled to claim maintenance under Section 125 of the Code of Criminal Procedure, 1973 (now Section 144 of the BNSS, 2023) against her husband, and that the Muslim Women (Protection of Rights on Divorce) Act, 1986 operates in addition to — not in derogation of — that secular maintenance right. The judgment is the most consequential restoration of the Shah Bano line in the post-1986 period.

Valkya Editorial··8 min
Supreme CourtSupreme Court of India

Mohd. Ahmed Khan v. Shah Bano Begum: maintenance under Section 125 CrPC and the constitutional engagement with personal law

On 23 April 1985, a five-judge Constitution Bench led by Chief Justice Y.V. Chandrachud held that Section 125 of the Code of Criminal Procedure — the secular maintenance framework — applies to Muslim women, and that the right to maintenance does not end with the iddat period where the divorced wife is unable to support herself. The judgment's substantive disposition was reversed by the Muslim Women (Protection of Rights on Divorce) Act, 1986; the constitutional architecture it articulated, however, has continued to govern subsequent engagement with the question. A digest of the holding, the reasoning, and the doctrinal trajectory.

Valkya Editorial··10 min