The Supreme Court of India recently delivered a significant judgment in the case of *Kiran Jyot Maini v. Anish Pramod Patel* (2024 INSC 530), which revolved around the dissolution of marriage under Article 142 of the Constitution due to an irretrievable breakdown of the marital relationship.
This case sheds light on the Supreme Court’s discretionary powers in granting divorce and determining fair permanent alimony, offering valuable insights into the evolving landscape of family law in India.
The marriage between the appellant, Kiran Jyot Maini (the wife), and the respondent, Anish Pramod Patel (the husband), was solemnized in 2015. However, the relationship quickly deteriorated, and the couple separated within a year. The wife alleged cruelty, dowry demands, and domestic violence, leading to a series of civil and criminal cases filed by both parties.
Over the course of nine years, the litigation dragged on, with multiple attempts at mediation failing to reconcile the couple. The prolonged separation and the absence of any possibility of reconciliation prompted the Supreme Court to step in and exercise its extraordinary powers under Article 142 of the Constitution to dissolve the marriage.
The Court also ordered the husband to pay ₹2 Crore as a one-time permanent alimony to the wife.
One of the key issues in this case was the dissolution of marriage on the grounds of an irretrievable breakdown, even though no formal grounds for divorce existed under statutory laws like the Hindu Marriage Act, 1955. The Supreme Court has, in several precedents, recognized that prolonged separation and failed reconciliation efforts are indicative of a marriage that is beyond repair.
Court cited earlier judgments ,such as
*Hitesh Bhatnagar v. Deepa Bhatnagar* (2011),
*Shilpa Sailesh v. Varun Sreenivasan* (2023), and
*Ashok Hurra v. Rupa Bipin Zaveri* (1997)
to emphasize that when a marriage has irretrievably broken down, continuing it serves no useful purpose. The Court’s decision to grant divorce under Article 142 was based on the principle that the institution of marriage should not be preserved when it has become a source of misery and conflict for both parties.
Irretrievable Breakdown of Marriage under Article 142
The Supreme Court has the discretion to dissolve a marriage even if no formal divorce grounds exist under law.
Citing Hitesh Bhatnagar v. Deepa Bhatnagar (2011), Shilpa Sailesh v. Varun Sreenivasan (2023), and Ashok Hurra v. Rupa Bipin Zaveri (1997), the Court emphasized:
Prolonged separation is proof that the marriage is beyond repair.
Multiple failed reconciliation efforts indicate there is no scope for reunion.
No useful purpose is served by continuing the marriage
Another critical aspect of the case was the determination of fair permanent alimony. The Supreme Court, relying on precedents like *Rajnesh v. Neha* (2020) and *Vinny Paramvir Parmar v. Paramvir Parmar* (2011), highlighted that the purpose of alimony is not to penalize either party but to ensure financial security for the spouse in need.
The Court considered several factors in determining the amount of ₹2 Crore as a one-time settlement, including the income and assets of both parties, the standard of living enjoyed during the marriage, the responsibilities and liabilities of each party, and their future earning potential. The aim was to strike a balance between fairness and financial independence, ensuring that the wife could maintain a reasonable standard of living post-divorce.
The issue of interim maintenance arrears also came up during the proceedings. The wife had alleged that the husband had failed to pay interim maintenance as ordered by the lower courts. The Supreme Court addressed this issue by ensuring that the one-time alimony settlement of ₹2 Crore would cover all past and future financial obligations, thereby bringing finality to the matter.
Court’s Ruling
Marriage dissolved under Article 142 due to complete breakdown.
₹2 Crore granted as one-time settlement, balancing fairness and financial independence.
Pending criminal and civil cases to be closed, bringing finality to litigation.
In its final ruling, the Supreme Court dissolved the marriage under Article 142, citing the irretrievable breakdown of the relationship. The ₹2 Crore one-time settlement was deemed fair and just, considering the financial circumstances of both parties. Additionally, the Court ordered the closure of all pending criminal and civil cases between the parties, putting an end to the prolonged litigation that had spanned nearly a decade.
Fair Permanent Alimony
The Court, relying on Rajnesh v. Neha (2020) and Vinny Paramvir Parmar v. Paramvir Parmar (2011), held that:
Maintenance should not be penal but ensure financial security.
Factors considered:
Income & assets of both parties.
Standard of living during marriage.
Responsibilities and liabilities of both parties.
Future earning potential.
The judgment in *Kiran Jyot Maini v. Anish Pramod Patel* is a landmark decision that underscores the Supreme Court’s role in addressing complex family disputes where statutory laws may fall short. By invoking Article 142, the Court has once again demonstrated its commitment to delivering justice in cases where the continuation of a marriage would cause undue hardship to both parties.
This case also highlights the importance of considering financial fairness and independence when determining alimony, ensuring that the rights and dignity of both spouses are upheld. As family dynamics continue to evolve, judgments like this one will play a crucial role in shaping the future of matrimonial law in India.
Disclaimer
(This blog is for educational and general informational purposes only and does not constitute legal advice. The analysis of Kiran Jyot Maini v. Anish Pramod Patel (2024 INSC 530) reflects the author’s interpretation and may not cover current legal developments. Readers should consult a legal professional for specific advice. The author and publisher disclaim liability for actions based on this content. Discussions on Article 142, alimony negotiations, and interim maintenance are case-specific. This blog does not create an attorney-client relationship)
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