Showing posts with label S 7 of family courts Act. Show all posts
Showing posts with label S 7 of family courts Act. Show all posts

Saturday, 23 July 2022

Whether the family court has jurisdiction to entertain a suit between mother-in-law and daughter-in-law?

 Unquestionably, the dispute in this case revolves around Clause (d) of explanation to Section 7 (1) of the Family Courts Act. A mere glance at the provision indicates that it has been worded in careful and cautious terms. It states that a suit or proceeding for an order or injunction in circumstances arising out of a marital relationship would lie exclusively before the Family Court. 

{Para 21}

22. What has to be seen is whether the circumstances in which the order or injunction is sought in the present case arise out of a marital relationship. The test is not whether the cause of action, forming the the basis of the prayer for injunction, arises out of a marital relationship or whether the marital relationship is the reason for the grievance ventilated by the plaintiff. All that has to been seen are the circumstances in which the injunction is sought. Once the Court identifies the circumstances, if those circumstances arise out of a marital relationship, Clause (d) of the Explanation to Section 7 (1) of the Family Courts Act would ipso facto be attracted.

23. Explanation (d) in Section 7 (1) of the Family Courts Act does not, either expressly or by necessary implication, require the parties to the lis to be husband and wife. Clearly, in so opining, the learned SCJ has effectively re-written the statutory provision. There is nothing in Clause (d) of the explanation to Section 7 (1) of the Family Courts Act in which indicates that the clause would apply only where the litigation is between husband and wife. For the clause to apply, all that is required is that (i) there is a marital relationship, (ii) the martial relationship has resulted in a certain set of circumstances and (iii) the order or injunction which is sought in the suit is sought in those circumstances.

24. Applying these tests to the case at hand, if one examines the plaint, and the case set up by the respondents in the plaint, it is clear that the circumstances in which injunction has been sought by them have arisen out of the marital relationship between the petitioner and Pardip. Had the petitioner not married Pardip, she would never had been the daughter-in-law of the respondents, she would never had come to stay in the residence of the respondents, the respondents would never had given her any permissive licence to reside therein, and the entire chiaroscuro of events, which have been emphasised in the plaint by the plaintiffs, to highlight the alleged ignominy and persecution to which petitioner allegedly subjected the respondents, would not be in existence. The fact that the petitioner married the respondents’ son was the foundation of the relationship that emerged between the petitioner and the respondents, and it was in the circumstances which arouse out of that relationship that the entire dispute between the respondents and the petitioner, as per the allegations contained in the plaint, filed by the respondents, arose.

28. That being so, in my view, the case squarely falls within Clause (d) of the explanation to Section 7 (1) of the Family Courts Act.

29. I am unable, therefore, to subscribe to the view expressed by the learned SCJ in the impugned order 30th October, 2019 in Suit 12114/2016 that the suit was not required to be transferred to the Family Court.

IN THE HIGH COURT OF DELHI AT NEW DELHI

CM(M) 69/2020 & CM APPL. 2707/2020

AVNEET KAUR  Vs SADHU SINGH & ANR .

CORAM:

HON'BLE MR. JUSTICE C. HARI SHANKAR

Dated: 01.06.2022

Print Page

Thursday, 9 July 2020

Supreme Court: Family Court has jurisdiction to adjudicate upon any question relating to the properties of divorced parties

The fact of the matter, as noticed hereinbefore, clearly shows that the dispute between the parties to the marriage arose out of the properties claimed by one spouse against the other. The respondent herein made a categorical statement to the effect that the properties were purchased out the amount paid in cash or by way of ornaments and the source of consideration for purchasing the properties described in Schedules 'A' and 'B' of the suit having been borne out of the same, the appellant herein was merely a trustee in relation thereto and could not have claimed any independent interest thereupon. It is also apparent that whereas the agreement marked as Exhibit A1 was executed on 17.09.1994, the appellant pronounced Talaq on 01.11.1995. The wordings 'disputes relating to marriage and family affairs and for matters connected therewith' in the view of this Court must be given a board construction. The Statement of Object and Reasons, as referred to hereinbefore, would clearly go to show that the jurisdiction of the Family Court extends, inter alia, in relation to properties of spouses or of either of them which would clearly mean that the properties claimed by the parties thereto as a spouse of other, irrespective of the claim whether property is claimed during the subsistence of a marriage or otherwise.

IN THE SUPREME COURT OF INDIA

Civil Appeal No. 3322 of 2003

Decided On: 10.04.2003

 K.A. Abdul Jaleel  Vs.  T.A. Shahida

Hon'ble Judges/Coram:
V.N. Khare, C.J., S.B. Sinha and A.R. Lakshmanan, JJ.

Citation : MANU/SC/0301/2003

Print Page