Legal Review and Analysis of Baburam Gautam & Ors vs State of UP & Anr 2025 INSC 1493
Case Synopsis
Baburam Gautam & Ors. vs. State of U.P. & Anr. (2025 INSC 1493)
Synopsis: The Supreme Court, leveraging its extraordinary jurisdiction under Article 142 of the Constitution, dissolved a marriage on the ground of irretrievable breakdown to effectuate a comprehensive settlement between warring spouses, thereby quashing all interconnected litigations and granting immediate divorce by mutual consent in the interest of complete justice.
1. Heading of the Judgment
Case Name: Baburam Gautam & Others versus State of Uttar Pradesh & Another
Citation: 2025 INSC 1493
Court: Supreme Court of India
Judges: Hon’ble Mr. Justice Ahsanuddin Amanullah and Hon’ble Mr. Justice K. Vinod Chandran
Date: December 18, 2025
2. Related Laws and Sections
The judgment primarily engages with the following legal provisions:
Article 142 of the Constitution of India: Empowers the Supreme Court to pass any decree or order necessary for doing complete justice in any cause or matter.
Section 13B of the Hindu Marriage Act, 1955: Provides for divorce by mutual consent.
Section 482 of the Code of Criminal Procedure, 1973: Deals with the inherent powers of the High Court to quash proceedings to prevent abuse of process or secure ends of justice.
3. Basic Judgment Details
Facts of the Case
The appeal arose from the rejection of a petition under Section 482 Cr.P.C. seeking quashing of criminal proceedings (Case Crime No. 177 of 2023) pending before a court in Mathura. The original appellants and the second respondent (the wife) were involved in extensive matrimonial litigation. During the pendency of the appeal before the Supreme Court, the husband (the third appellant) and wife (the second respondent) informed the Court that they had reached a full and final settlement. The terms included a monetary settlement of Rs. 30,00,000 (Thirty Lakh) from the husband to the wife, mutual agreements to withdraw all pending civil and criminal cases against each other, and removal of all related content from social media.
Issues Before the Court
Whether the criminal proceedings and the myriad of interconnected cases filed by the parties against each other could be quashed in light of a comprehensive settlement?
Whether the Supreme Court, in exercise of its powers under Article 142 of the Constitution, can dissolve the marriage on the ground of irretrievable breakdown, even though the mutual consent divorce petition under Section 13B of the Hindu Marriage Act was yet to be filed in the competent court?
Ratio Decidendi (Court's Reasoning)
The Supreme Court recorded the joint application and the undertakings of the parties. It noted that the marriage had reached a point of "irretrievable breakdown" with no possibility of reconciliation. The Court emphasized that:
The parties had voluntarily and willingly settled all their disputes.
The settlement included the withdrawal of all listed cases (detailed in the order) and cleansing of social media.
Continuing the litigation would serve no purpose and would only perpetuate strife.
Therefore, to do complete justice and put a quietus to all litigation, the Court invoked its extraordinary power under Article 142 of the Constitution. It directed the closure of all enumerated cases and, crucially, dissolved the marriage between the third appellant and second respondent by granting a decree of divorce under Section 13B of the Hindu Marriage Act, 1955.
4. Core Principle of the Judgment
Title: Article 142 as a Tool for Conclusive Justice in Irretrievably Broken Marriages
Main Issue and Judgment's Core
The core issue addressed was the appropriate judicial mechanism to conclusively end protracted and acrimonious matrimonial litigation where parties have settled all disputes but multiple cases remain pending across various forums.
The Supreme Court addressed this by fusing the principles of settlement, inherent powers, and its plenary jurisdiction under Article 142. The judgment establishes that when a marriage has broken down irretrievably and the parties have reached a full and final settlement encompassing all civil, criminal, and financial aspects, the Supreme Court can:
Quash all interconnected proceedings to prevent the abuse of the legal process and waste judicial resources.
Directly dissolve the marriage by treating the settlement agreement and joint prayer before it as a substitute for the procedural steps of a mutual consent divorce petition filed in a family court. This step is taken to immediately sever the legal tie, which is the root cause of all ancillary disputes.
In-Depth Analysis
This judgment highlights the Supreme Court's proactive and pragmatic approach in matrimonial disputes. The Court moved beyond merely quashing the criminal case under appeal. By taking suo motu cognizance of the comprehensive settlement and the admitted irretrievable breakdown, it used Article 142 to achieve a final, holistic resolution. This prevents the parties from facing the protracted timeline of filing a mutual consent petition under Section 13B (which has a 6-18 months mandatory waiting period) and then separately seeking quashing of other cases. It underscores the Court's role not just as an adjudicator but as an instrument for securing lasting peace between litigants, thereby reducing the burden on the judicial system. The decree of dissolution passed by the Supreme Court itself carries the same legal sanctity as one passed by a competent family court.
5. Final Outcome
The Supreme Court
Allowed the criminal appeal.
Recorded the undertakings of the parties regarding the settlement, withdrawal of cases, and social media cleanup.
Directed that all cases/proceedings listed in the order shall be closed upon production of the certified copy.
Invoked Article 142 to dissolve the marriage between the third appellant (Vishal Gautam) and the second respondent (Kanishka Singh) under Section 13B of the Hindu Marriage Act, 1955.
Directed the Registry to draw up a decree of divorce for issuance to the parties.
6. MCQ Questions Based on the Judgment
Question 1: In Baburam Gautam vs. State of U.P. (2025 INSC 1493), what was the primary constitutional provision invoked by the Supreme Court to dissolve the marriage?
A) Article 32 of the Constitution
B) Article 136 of the Constitution
C) Article 142 of the Constitution
D) Article 226 of the Constitution
Question 2: As per the final settlement in the aforementioned case, what was the total monetary amount agreed to be paid by the husband to the wife?
A) Rs. 15,00,000
B) Rs. 20,00,000
C) Rs. 25,00,000
D) Rs. 30,00,000