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Delhi HC: Civil courts allowed for in-law disputes jurisdiction

Author : Nimisha Nayak

September 14, 2024

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In a recent ruling, the Delhi High Court has clarified the jurisdictional landscape regarding civil suits filed by in-laws against their daughter-in-law. The division bench, comprising Justice Yashwant Varma and Justice Dharmesh Sharma, asserted that family courts do not hold exclusive jurisdiction over such matters when the reliefs sought pertain to possession or injunction.

As outlined by the Court, the crux of the matter revolves around whether the circumstances directly impact the marital relationship. It was emphasized that family court jurisdiction is warranted only when the dispute significantly affects the marriage.

Key Aspects of the Ruling

The ruling stemmed from a series of conflicting opinions among judicial benches regarding the jurisdiction of family courts versus civil courts in these disputes. Notably, the Court was prompted to examine whether claims made by third parties, such as parents-in-law against their daughter-in-law, should be exclusively tried before family courts, thus excluding civil court jurisdiction.

An earlier judgment in the case of Avneet Kaur v Sadhu Singh had leaned towards the exclusivity of family court jurisdiction, citing marriage as the foundation of such disputes. However, the recent ruling has overturned this interpretation, stating that the mere existence of a marital relationship does not automatically confer jurisdiction to family courts.

The Court dissected the concept of a "marital relationship" to clarify that the term should be interpreted independently of the broader notion of "family." It emphasized that every suit or legal proceeding under the Family Courts Act must present a cause of action directly related to the marital relationship to fall under the jurisdiction of family courts.

Moreover, the Court underscored that the dispute's circumstances must demonstrate a close connection to matters integral to the marital relationship. Mere tangential involvement of marital ties does not suffice to justify the exclusive jurisdiction of family courts.

The ruling also addressed the issue of the husband's impleadment or non-impleadment in disputes filed by his parents. It asserted that the determination of family court jurisdiction should not hinge solely on the husband's presence or absence in the proceedings. Instead, the cause of action and its direct nexus to the marital relationship should be the determining factors.

The Court's decision to allow civil courts to adjudicate such disputes aims to prevent family courts from being overburdened with cases unrelated to marital relationships. By prioritizing the cause of action in determining jurisdictional forums, the Court seeks to maintain the specialized focus of family courts on matrimonial matters.