Summary and Analysis of A. Ranjithkumar vs E. Kavitha

1. Heading of the Judgment

A. Ranjithkumar vs E. Kavitha
(Supreme Court of India, Civil Appellate Jurisdiction, Civil Appeal arising from SLP(C) No. 31247 of 2018)

Citation

A. Ranjithkumar vs E. Kavitha, (2025) INSC 978.

Judges

Vikram Nath and Sandeep Mehta, JJ.

Date

August 14, 2025.

2. Related Laws and Provisions

The judgment involves:

• Section 13(1)(ia) of the Hindu Marriage Act, 1955:
  Grounds for divorce (cruelty).

• Article 142 of the Constitution of India:
  Empowers the Supreme Court to pass any order necessary for "complete justice."

3. Basic Judgment Details

• Parties:
  Appellant: A. Ranjithkumar (husband).
  Respondent: E. Kavitha (wife).

• Core Issue:
  Whether the marriage could be dissolved on grounds of irretrievable breakdown despite the High Court reversing the divorce decree granted by the Family Court.

• High Court’s Decision (Impugned):
  Set aside the Family Court’s divorce decree, holding the wife could not be held liable for her father’s alleged cruelty.

• Supreme Court’s Decision:
  Allowed the appeal, dissolved the marriage under Article 142, and awarded permanent alimony of ₹1.25 crores to the wife and son.

4. Explanation of the Judgment

A. Factual Background

• Marriage & Separation:
  Solemnized on 15.02.2009.
  Couple moved to the USA (husband’s workplace).
  A son was born on 07.04.2010.
  Separated since 2010 (15 years of separation).

• Legal Proceedings:
  2012: Husband filed for divorce (F.C.O.P. No. 245 of 2014) under Section 13(1)(ia) HMA (cruelty) and adultery.
  2016: Family Court granted divorce on cruelty grounds (adultery not proven).
  2017: Wife appealed; High Court reversed the decree, noting cruelty allegations were against the wife’s father, not the wife herself.
  05.03.2017: Husband remarried during pendency of the appeal.

B. Supreme Court’s Reasoning

1. Irretrievable Breakdown of Marriage:
   Parties lived separately for 15 years with "no vestige of matrimonial relationship."
   No possibility of reconciliation (mediation failed).
   Husband remarried in 2017, making revival of the marriage impractical.

2. Use of Article 142 for "Complete Justice":
   Despite the High Court’s finding that cruelty was not proven against the wife, the Supreme Court invoked Article 142 to dissolve the marriage due to its irretrievable breakdown.

3. Permanent Alimony Awarded:
   Husband had not provided financial support during separation.
   ₹1.25 crores awarded as lump-sum alimony to the wife and son, considering:
   Financial status of both parties.
   Long duration of separation.
   Wife’s responsibility toward the son.
   Payment in 5 quarterly installments (₹25 lakhs each) from Sept 2025 to Sept 2026.
   Default Consequence: Entire order recalled and paid amount forfeited if any installment is missed.

C. Key Legal Principles

• Article 142 Overrides Technicalities:
  Allows the Supreme Court to dissolve marriages on grounds of irretrievable breakdown, even if not a formal ground under the Hindu Marriage Act.

• Alimony Considerations:
  Courts assess financial needs, duration of separation, and responsibilities toward children.

• Third-Party Actions Not Attributable:
  Cruelty by in-laws (e.g., wife’s father) cannot be imputed to the spouse unless proven they acted at her behest.

D. Outcome

• Marriage dissolved effective immediately.

• High Court’s order set aside.

• Alimony decree to operate upon payment proof.

Key Takeaway:
The Supreme Court prioritized practical justice over technical grounds by dissolving a dead marriage using its constitutional powers, while ensuring financial security for the wife and child. This reflects the judiciary’s evolving approach to matrimonial disputes where relationships are beyond repair.