Supreme Court Quashes DV Proceedings and Grants Divorce Under Article 142 for Breach of Mediated Settlement

Case Name: Dhananjay Rathi v. Ruchika Rathi
Citation: 2026 INSC 360
Date of Judgment/Order: April 13, 2026
Bench: Justice Vijay Bishnoi and Justice Rajesh Bindal

Held: The Supreme Court held that once parties enter into a mediated settlement resolving matrimonial disputes, a party cannot resile from its terms without establishing fraud, coercion, or non-performance by the other side, and any such unjustified withdrawal constitutes abuse of process. The Court further held that where matrimonial litigation continues despite a concluded settlement and the relationship has irretrievably broken down, it is appropriate to exercise powers under Article 142 to dissolve the marriage and quash subsequent criminal proceedings, including those under the Domestic Violence Act, if they are found to be vexatious and lacking specific allegations.

Summary: The dispute arose from matrimonial discord between the parties, who entered into a mediated settlement resolving all disputes and agreeing to divorce by mutual consent with financial and property arrangements. The first motion for divorce was completed and substantial compliance of the settlement occurred, including payment of ₹89 lakh, transfer of funds, and return of jewellery. However, the wife withdrew consent before the second motion and initiated domestic violence proceedings alleging additional claims not part of the settlement. The High Court permitted continuation of DV proceedings subject to deposit of ₹89 lakh. The husband challenged this before the Supreme Court, contending abuse of process and seeking divorce under Article 142. The Court examined the binding nature of mediated settlements, noting that deviation is permissible only in cases of fraud, coercion, or breach, none of which were established. It found the wife’s allegations regarding additional jewellery and gold to be unsubstantiated and an afterthought, and held that the DV complaint lacked specific allegations of violence and was filed belatedly as a litigation tactic. Considering the prolonged separation, completed settlement steps, and hostile litigation, the Court concluded that the marriage had irretrievably broken down.

Decision: The Supreme Court allowed the appeal, quashed the DV proceedings, set aside the High Court’s order, and dissolved the marriage under Article 142 on grounds of irretrievable breakdown, subject to compliance with remaining settlement obligations including payment of balance alimony and execution of property transfers, while directing refund of deposited amounts and closure of all pending proceedings between the parties.