DHANANJAY RATHI v. RUCHIKA RATHI
Quashing of Vexatious Domestic Violence Proceedings and Grant of Divorce Under Article 142 Following Breach of Mediated Settlement Agreement.
Court: Supreme Court of India
Citation: 2026 INSC 360
Decision Date: 13-04-2026
List of Laws
The Constitution of India, Article 142; Protection of Women from Domestic Violence Act, 2005; Hindu Marriage Act, 1955; Bharatiya Nagarik Suraksha Sanhita, 2023 (Section 528); Family Law - Irretrievable Breakdown of Marriage; Mediation and Settlement Jurisprudence
- Facts: The Appellant-Husband and Respondent-Wife, married in 2000, entered into a mediated Settlement Agreement in 2024 to resolve long-standing matrimonial disputes. Under the agreement, the Husband paid ₹89,00,000 and returned jewellery in exchange for a mutual consent divorce and the Wife's withdrawal of all claims. While the first motion for divorce was granted, the Wife subsequently resiled from the settlement, refused to sign the second motion, and filed a fresh complaint under the Domestic Violence (DV) Act. She alleged the Husband failed to fulfill an oral promise to return additional jewellery worth ₹120 crores. The Husband sought to quash the DV proceedings, arguing they were a vexatious attempt to extort money after he had partially fulfilled his obligations.
- Procedural Posture: The Husband challenged an interim order of the Delhi High Court which had allowed the DV proceedings to continue subject to the Wife depositing the settlement money. The Husband approached the Supreme Court via Special Leave Petition and additionally moved an application under Article 142 of the Constitution seeking a decree of divorce.
- Issue: 1. Whether the DV Act proceedings initiated after a mediated settlement should be quashed as an abuse of process. 2. Whether the Supreme Court can exercise powers under Article 142 to dissolve a marriage on the ground of irretrievable breakdown when one party resiles from a settlement.
- Holding: 1. Yes, the DV proceedings were quashed. 2. Yes, the marriage was dissolved under Article 142.
- Reasoning: The Court reasoned that the Wife's allegations regarding additional jewellery worth ₹120 crores were "egregious" and lacked credibility, as they were not mentioned in the written settlement or subsequent communications. Since the parties had lived apart since 2022 and the Wife had already received significant benefits from the settlement, her withdrawal of consent was deemed a tactic to harass the Husband. The Court held that once a mediated settlement is authenticated, parties cannot be allowed to reverse its effects by filing subsequent complaints. Finding the marriage "emotionally dead" and the relationship "snapped for long now", the Court invoked Article 142 to do complete justice, quashing all pending litigations and granting a divorce.
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