Kiran Jyot Maini vs. Anish Pramod Patel [July 15, 2024]
Citation: 2024 INSC 530; [2024] 7 S.C.R. 942; Criminal Appeal Nos. 2915-2918 of 2024
Background and Facts
Kiran Jyot Maini and Anish Pramod Patel were married on 30 April 2015. The marriage quickly deteriorated, with the couple cohabiting for less than a year and living separately for nine years. Within a year, Kiran filed an FIR alleging cruelty and dowry harassment under Sections 498A, 323, 504 of the IPC and Sections 3 and 4 of the Dowry Prohibition Act. She also sought interim maintenance under the Protection of Women from Domestic Violence Act, 2005 (PWDV Act).
Despite several mediation attempts and multiple litigations—including proceedings for interim maintenance and attachment of the respondent’s bank accounts—there was no reconciliation. The respondent’s compliance with maintenance orders was inconsistent, leading to further disputes and appeals.
Supreme Court’s Analysis and Findings
Irretrievable Breakdown of Marriage:
The Supreme Court acknowledged the complete and irretrievable breakdown of the marriage, referencing precedents such as Hitesh Bhatnagar v. Deepa Bhatnagar and Ashok Hurra v. Rupa Bipin Zaveri. The Court exercised its powers under Article 142 of the Constitution to dissolve the marriage, noting the impossibility of reunion and the unworkable nature of the relationship after nine years of separation.
Determination of Maintenance:
The Court provided a comprehensive framework for determining maintenance, considering factors such as the income and properties of both parties, their standard of living, employability, obligations, and personal needs. Drawing from Vinny Paramvir Parmar v. Paramvir Parmar and Rajnesh v. Neha, the Court stressed that maintenance must be fair, reasonable, and sufficient to enable the spouse to live with dignity.
One-Time Settlement:
Due to the contentious nature of ongoing maintenance and the parties’ financial positions, the Court ordered a one-time settlement. While the appellant demanded ₹5–7 crores and the respondent offered ₹50 lakhs, the Court fixed permanent alimony at ₹2 crores, considering all relevant circumstances, including the parties’ social and financial status and future prospects. This amount was to be paid within four months and would cover all pending and future claims.
Conclusion and Significance
The Supreme Court dissolved the marriage under Article 142, citing irretrievable breakdown as a valid ground for divorce, even where statutory grounds were absent.
The Court set aside previous orders, disposed of all pending cases, and directed the husband to pay ₹2 crores as permanent alimony, ensuring a fair and balanced resolution.
This judgment provides a significant precedent for handling matrimonial disputes involving irretrievable breakdown, interim maintenance, and permanent alimony, reinforcing the Court’s discretionary powers to do complete justice in complex family matters.
In summary: The Supreme Court granted divorce to Kiran Jyot Maini and Anish Pramod Patel on grounds of irretrievable breakdown, ordered a one-time alimony of ₹2 crores, and clarified the principles for maintenance and settlement in matrimonial disputes.
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