The Supreme Court, invoking its extraordinary power under Article 142 of the Constitution, dissolved the marriage on the ground of irretrievable breakdown. It quashed the pending criminal proceedings under Section 498-A IPC, finding the allegations to be vague and arising from marital discord, while upholding the terms of a settlement agreement for a clean break.
Facts Of The Case:
The marriage between Anurag Goel (appellant-husband) and the second respondent (wife) took place on July 25, 2015, following prior divorces for both. After approximately one year and nine months of conjugal life, the relationship soured. The husband alleged constant harassment, leading him to abandon the matrimonial home—a Mumbai apartment he owned—in April 2017 to move to Faridabad with his autistic child from his first marriage. The wife, however, claimed she was a victim of domestic violence and was abandoned without any means of survival, forcing her to bring her parents to live in the flat. This led to a flurry of litigation, including a complaint under Section 498-A of the IPC by the wife in 2018 and a divorce petition filed by the husband. During mediation in 2022, the parties reached a settlement where the husband agreed to gift the Mumbai apartment to the wife in exchange for mutual consent divorce and the withdrawal of all cases. However, the wife resiled from this agreement before the second motion for divorce, demanding significantly higher alimony, which prompted the husband to approach the Supreme Court.
Procedural History:
The procedural history of this case commenced with the wife filing a criminal complaint under Section 498-A IPC, leading to the registration of FIR No. 63 of 2018 before the Metropolitan Magistrate in Mumbai. The husband subsequently approached the Bombay High Court under Section 482 CrPC seeking to quash these proceedings, a plea that was dismissed. Concurrently, the husband filed for divorce in a Delhi family court, where mediation resulted in a settlement agreement. When the wife resiled from this settlement, the husband initiated contempt proceedings in the Delhi High Court. A Single Judge found her in contempt, but this was overturned by a Division Bench. The husband then appealed the Bombay High Court’s order to the Supreme Court, while also filing a separate application under Article 142 of the Constitution seeking a divorce on the ground of irretrievable breakdown of marriage. The Supreme Court clubbed these matters and passed the final judgment.
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Court Observation:
The Court observed that the allegations in the FIR, even taken at face value, disclosed nothing beyond ordinary marital squabbles blown out of proportion and were vague, banal, and devoid of specific instances of cruelty. It found the criminal proceedings under Section 498-A IPC to be an abuse of the process of law. The Court noted that the marriage had irretrievably broken down, was emotionally dead, and beyond salvation, making it a fit case for the exercise of its extraordinary power under Article 142 of the Constitution to dissolve the union. It upheld the validity of the mediation settlement agreement, rejecting the wife’s allegations of coercion and fraud as unsubstantiated. The Court further observed that gifting the valuable, encumbrance-free Mumbai apartment to the wife, a qualified and employable engineer, was sufficient and just compensation, eliminating the need for further permanent alimony.
Final Decision & Judgement:
Based on its observations, the Supreme Court allowed the appeal and exercised its extraordinary power under Article 142 of the Constitution. The final decree of divorce was granted on the ground of irretrievable breakdown of the marriage. The Court quashed all criminal proceedings arising from the matrimonial dispute, specifically CC No.1336/PW/2018 pending before the Metropolitan Magistrate in Mumbai. The judgement mandated that the husband must clear all outstanding maintenance dues for the Mumbai apartment and execute a gift deed transferring its ownership to the wife by a specified date. Furthermore, it issued a blanket injunction, ordering that all civil and criminal proceedings between the parties related to the marriage shall stand closed permanently, and no future cases on these matters can be initiated. The dissolution of the marriage was contingent upon the successful transfer of the property.
Case Details:
Case Title: Anurag Vijaykumar Goel vs. State of Maharashtra & Anr. Citation: 2025 INSC 926 Criminal Appeal No.: Criminal Appeal No. 5277 of 2024 Date of Judgement: August 05, 2025 Judges/Justice Name: Justice B.R. Gavai & Justice K. Vinod Chandran & Justice N.V. Anjaria
Download The Judgement Here