Summary and Analysis of Anurag Vijaykumar Goel Vs State Of Maharashtra & Anr. (Criminal Appeal No. 5277 Of 2024)
1. Heading of the Judgment
Supreme Court Quashes Criminal Proceedings and Dissolves Marriage on Grounds of Irretrievable Breakdown Under Article 142
2. Related Laws and Sections
The judgment involves the following legal provisions:
Section 498-A, Indian Penal Code (IPC): Allegations of cruelty against the husband.
Section 482, Code of Criminal Procedure (CrPC): Powers of the High Court to quash criminal proceedings.
Section 13B, Hindu Marriage Act, 1955: Divorce by mutual consent.
Article 142 of the Constitution of India: Supreme Court’s power to pass any order for "complete justice."
Domestic Violence Act, 2005: Criminal proceedings initiated by the wife.
3. Basic Judgment Details
AspectDetailsPartiesAppellant (Husband): Anurag Vijaykumar Goel
Respondents: State of Maharashtra & Wife (2nd Respondent)CourtSupreme Court of IndiaJudgesJustices B.R. Gavai, K. Vinod Chandran, and N.V. AnjariaKey Dates- Marriage: 25 July 2015
- Separation: 6 April 2017
Settlement Agreement (Annexure P-10): 1 September 2022
Judgment: 5 August 2025Core DisputeCriminal proceedings under Section 498-A IPC and divorce settlement.Outcome- Criminal proceedings quashed.
- Marriage dissolved under Article 142.
- Wife granted Mumbai apartment as settlement.
4. Explanation of the Judgment
Background of the Case
The husband (appellant) and wife (2nd respondent) married on 25 July 2015 but separated on 6 April 2017 after marital disputes.
Both had prior divorces. The husband had an autistic child from his first marriage.
The wife filed criminal cases:
FIR under Section 498-A IPC (cruelty) in 2018.
Case under Domestic Violence Act (2017).During divorce proceedings in 2022, both parties signed a settlement agreement (Annexure P-10), where the husband agreed to gift his Mumbai apartment (valued at ~₹4 crores) to the wife.
The wife later withdrew from the settlement and demanded ₹12 crores as permanent alimony.
Supreme Court’s Analysis
(a) Validity of Criminal Proceedings (Section 498-A IPC)
The Court examined the wife’s allegations (Annexure P-3 FIR) and found them "common-place, banal, and vague" with no specific instances of cruelty.
The FIR was filed one year after separation, indicating exaggeration of marital disputes.
Citing State of Haryana v. Bhajan Lal (1992), the Court held that criminal proceedings can be quashed if allegations do not prima facie constitute an offence.
Decision: The FIR and all criminal proceedings under Section 498-A were quashed.
(b) Settlement Agreement (Annexure P-10)
The wife claimed the settlement was signed under "coercion and fraud."
The Court rejected this:
She had paid ₹9.91 lakhs to clear the apartment loan in 2022.
She resided in the apartment with her parents since separation.Her demand for ₹12 crores was deemed an afterthought to coerce the husband.
(c) Irretrievable Breakdown of Marriage (Article 142)
The Court noted 8 years of litigation and "acrimonious relations" with no scope for reconciliation.
Relying on Shilpa Sailesh v. Varun Sreenivasan (2023), the Court invoked Article 142 to dissolve the marriage, holding it "emotionally dead and beyond salvation."
(d) Financial Settlement
The wife, a qualified engineer with an MBA, was employed at the time of separation.
The husband, currently unemployed, had income reduced from ₹2.5 crores (2016) to ₹17.7 lakhs (2022).
Settlement Terms:
Wife gets the Mumbai apartment (A-52, Kalpataru Habitat) + 2 parking spaces (free of encumbrances).
Husband pays ₹25.9 lakhs as pending apartment maintenance.
No additional alimony granted to the wife.
Final Directions
Criminal Proceedings: Quashed.
Divorce: Granted under Article 142.
Property Transfer:
Husband to pay maintenance dues (₹25.9 lakhs) by 1 September 2025.
Husband to execute a gift deed for the apartment by 30 August 2025.No Future Cases: All civil/criminal cases between parties stand closed.
Conclusion
The Supreme Court prioritized "complete justice" by:
Ending prolonged litigation through Article 142.
Quashing criminal proceedings due to lack of evidence under Section 498-A IPC.
Enforcing the original settlement (gift of apartment) as fair compensation.
Denying the wife’s demand for ₹12 crores, noting her financial independence and the husband’s reduced income.
Key Quote:
"The marriage has been rendered totally unworkable, emotionally dead, and beyond salvation... the parties must go their separate ways." [Paragraph 16]