Landmark Supreme Court Judgment on Matrimonial Disputes: Rinku Baheti vs. Sandesh Sharda & Misuse of Protective Laws 

In the landmark judgment of Rinku Baheti vs. Sandesh Sharda (Transfer Petition (Civil) No. 278/2023), delivered on December 19, 2024, the Supreme Court of India, comprising Justices B.V. Nagarathna and N.K. Singh addressed critical issues concerning matrimonial disputes, misuse of protective laws, and the application of Article 142 of the Constitution in the matrimonial cases for grant of Divorce.

Background of the Case:

The petitioner, Rinku Baheti, and the respondent, Sandesh Sharda, entered into matrimony on July 31, 2021. This union marked the second marriage for both parties. However, discord emerged shortly after their wedding, primarily revolving around the husband's obligations towards his children from a previous marriage, his former spouse, and his ailing father. The marital strife led to multiple legal proceedings initiated by both parties.​

The husband filed three divorce petitions: the first was withdrawn, the second—a mutual consent divorce petition—was dismissed due to non-fulfillment of the statutory separation period, and the third was filed under Section 13(1)(ia) of the Hindu Marriage Act, alleging cruelty. Concurrently, the wife lodged criminal complaints against the husband and his family members under various sections of the Indian Penal Code, including Sections 498A (cruelty), 376 (rape), 377 (unnatural offences), and 506 (criminal intimidation). These actions culminated in the husband's arrest and subsequent release on bail. Additionally, the wife sought to transfer the divorce proceedings from Bhopal to Pune, citing concerns for her safety and convenience by filing a Transfer Petition before the Supreme Court.

Supreme Court's Observations and Judgment:

In this rare case, the Supreme Court agreed to invoke its power under section 142 of the constitution at the request of the Respondent-Husband. While exercising its authority under Article 142(1) of the Constitution, the Supreme Court dissolved the marriage of the parties on the grounds of irretrievable breakdown. The bench noted that compelling the parties to continue in a fractured marital relationship would only exacerbate their suffering. The Court emphasized that when a marriage is beyond repair, it is prudent to dissolve it to enable both parties to pursue independent lives.

A significant aspect of the judgment was the Court's concern over the misuse of stringent legal provisions in matrimonial disputes. The bench observed that laws intended for the protection and empowerment of women are sometimes misused as instruments for coercion or extortion. Specifically, the Court highlighted the frequent invocation of Sections 498A, 376, 377, and 506 of the IPC in matrimonial complaints, noting that such practices have been condemned in previous rulings. The judgment stated:​

"The provisions in criminal law are for the protection and empowerment of women but sometimes are used by certain women more for purposes that they are never meant for."

ISSUE OF PERMANENT ALIMONY: ​

Regarding permanent alimony, the Court addressed the tendency of seeking maintenance as an equalization of wealth between parties. The wife had demanded ₹500 crore, citing the husband's substantial net worth and the alimony paid to his first wife. The Court found this demand disproportionate, especially considering the brief duration of the marriage. The bench held that while the wife is entitled to maintenance reflecting the standard of living during the marriage, expecting the husband to maintain her at his current status indefinitely is unreasonable. The judgment noted:​

"The wife is entitled to be maintained as far as possible in a manner that is similar to what she was accustomed to in her matrimonial home while the parties were together. But once the parties have separated, it cannot be expected of the husband to maintain her as per his present status all his life." ​

Finally, the Court directed the husband to pay ₹12 crore as permanent alimony to the wife, along with ₹3 lakh towards litigation expenses. Additionally, the wife was instructed to vacate properties belonging to the husband's father in Pune and Bhopal within two months of receiving the alimony.

Importance of Judgment :

1. Misuse of Women-Centric Laws-

The Court expressed concern over the increasing misuse of legal provisions intended for the protection and empowerment of women. It observed that certain women invoke serious charges as a combined package in matrimonial disputes, often as a strategy for negotiation or monetary gain. The judgment emphasized that such misuse not only undermines the intent of these protective laws but also leads to the harassment of innocent individuals, including aged parents and relatives of the husband.

1. Application of Article 142 in Matrimonial Cases-

The Supreme Court exercised its plenary power under Article 142(1) of the Constitution to dissolve the marriage on the grounds of irretrievable breakdown. This article empowers the Court to pass decrees necessary for doing complete justice in any cause or matter. The Court noted that when a marriage is emotionally dead and beyond salvation, it is appropriate to dissolve it to enable both parties to move forward in life.

1. Determination of Permanent Alimony-

Addressing the issue of permanent alimony, the Court clarified that maintenance should not serve as a punitive measure against the ex-husband nor as a means for the ex-wife to equalize wealth. The wife is entitled to be maintained in a manner similar to what she was accustomed to during the marriage, but it is unreasonable to expect the husband to maintain her at the same level indefinitely, especially if his financial status changes post-separation. The Court highlighted that there is no fixed formula for calculating maintenance; instead, it should be based on a balanced consideration of various factors, including:

• • Status of the parties, social and financial.​

  • Reasonable needs of the wife and dependent children.​

  • Qualifications and employment status of the parties.​

  • Independent income or assets owned by the parties.​

  • Standard of living during the marriage.​

  • Any sacrifices made for family responsibilities.​

  • Reasonable litigation costs for a non-working wife.​

  • Financial capacity of the husband, including his income, obligations, and liabilities. ​

 Conclusion:

The judgment passed in the present case Rinku Baheti vs. Sandesh Sharda serves as a significant precedent in addressing the complexities of matrimonial disputes in India and cautions towards misuse of criminal laws for one's own benefit. It underscores the necessity for a balanced approach in applying protective laws, ensuring they serve their intended purpose without being misused. The ruling also highlights applications of Article 142 in matrimonial cases to dissolve marriages that are beyond repair, promoting justice and fairness for both parties involved.