Dhananjay Rathi vs Ruchika Rathi - 2026 Supreme(SC) 389

Judicial Analysis Court Copy Headnote Facts Arguments Court observation

2026 Supreme(SC) 389

RAJESH BINDAL, VIJAY BISHNOI
Dhananjay Rathi – Appellant
Versus
Ruchika Rathi – Respondent

Advocates appeared:
For the Petitioner(s): Mr. Prabhjit Jauhar, Adv. Mr. Sehaj Kataria, Adv. Ms. Rosemary Raju, Adv. Ms. Anupama Kaul, Adv. Ms. Chahat Raghav, Adv. Ms. Shreya Narayan, Adv. Ms. Shreyangana Bag, Adv. Ms. Tanay Kalia, Adv. Ms. Misha Thakur, Adv. Mr. S. S. Jauhar, AOR
For the Respondent(s): Mr. Prashant Mendiratta, Adv. (Through V.C.) Mr. T. V. S. Raghavendra Sreyas, AOR

Judgement Key Points

Key Points: - The DV proceedings against the Appellant-Husband were quashed and the settlement terms were upheld, with divorce granted under Article 142(1) subject to conditions. (!) (!) (!) - Whether a settlement agreement arrived via mediation can be repudiated by a party, and under what circumstances, including whether irretrievable breakdown or coercion/fraud justifies resiling. (!) (!) (!) (!) - Exercise of Article 142(1) to dissolve a marriage on irretrievable breakdown, including the factors and standards applied by the Supreme Court in such cases. (!) (!) (!) (!) (!)

Question 1?

Question 2?

Question 3?

Table of Content
1. factual background of matrimonial dispute (Para 2 , 3 , 4 , 5 , 6)
2. contentions from appellant regarding breach of settlement (Para 11 , 12 , 13 , 16 , 17)
3. court's view on irretrievable breakdown of marriage (Para 22 , 23 , 24 , 26 , 27)
4. application of article 142 in divorce case (Para 28 , 29 , 50)
5. final directions and conclusion of the case (Para 55 , 56)

JUDGMENT :

VIJAY BISHNOI, J.

Leave granted.

2. This appeal has been preferred by the Appellant-Husband challenging the order dated 07.01.2026 (hereinafter referred to as “Impugned Order”) passed in Crl. M.C. No. 116 of 2026 by the High Court of Delhi at New Delhi (hereinafter referred to as “the High Court”) wherein the High Court issued notice and granted an interim order directing that the proceedings initiated in DV Complaint No. 3186 of 2025 (hereinafter referred to as “DV Proceedings”) under the Protection of Women from Domestic Violence Act, 2005 (hereinafter referred to as “the DV Act”) by the Respondent-Wife against the Appellant-Husband and his mother (motherin-law of the Respondent-Wife) shall proceed, subject to deposit of Rs.89,00,000/- by the Respondent-Wife before the Registrar General of the

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Judicial Analysis

Rinku Baheti VS Sandesh Sharda - 2025 4 Supreme 176: States affirmative Supreme Court power under Article 142(1) to dissolve marriage on irretrievable breakdown; describes Hindu marriage as sacrament and guidelines for permanent alimony. No negative treatment keywords; presents as valid precedent.

Shilpa Sailesh VS Varun Sreenivasan - 2023 3 Supreme 257: Affirms Supreme Court discretion under Article 142(1) to dissolve marriage by mutual consent without second motion for 'complete justice'; notes limits on Article 32 writs. No negative treatment; presented as authoritative.

Mohd. Shamim VS Nahid Begum - 2005 1 Supreme 59: Holds that settlement in 406/498A case with substantial payment renders continuance an abuse of process. Labeled "Important point"; no negative indicators.

SMRUTI PAHARIYA VS SANJAY PAHARIYA - 2009 0 Supreme(SC) 1059: Rules that court proceedings cannot favor one party (abuse of process) and u/s 13B requires mutual consent at both stages; ex parte decree invalid. No negative treatment.

Anurag Vijaykumar Goel VS State of Maharashtra - 2025 6 Supreme 309: States "A dead marriage must be given a decent quietus." Concise affirmative principle; no negative keywords.

Gimpex Private Limited VS Manoj Goel - 2021 7 Supreme 305: Holds settlement agreement subsumes original cheque dishonour complaint, barring dual proceedings until set aside by decree. No negative treatment.

Ruchi Agarwal VS Amit Kumar Agrawal - 2004 8 Supreme 525: Finds 498A/323/506 complaint post-compromise in divorce is abuse of process, warranting quashing. No negative indicators.

Hitesh Bhatnagar VS Deepa Bhatnagar - 2011 3 Supreme 268: Permits irretrievable breakdown as divorce ground only if no chance of survival. Conditional affirmative holding; no negative treatment.

Vineet Taneja VS Ritu Johari - 2024 0 Supreme(SC) 1367: Describes Supreme Court use of Article 142 to dissolve irretrievably broken marriage and quash proceedings. No negative keywords.

Trisha Singh VS Anurag Kumar - 2024 5 Supreme 63: Reiterates "A dead marriage must be given a decent quietus" in mutual consent context. Echoes Anurag Vijaykumar Goel VS State of Maharashtra - 2025 6 Supreme 309; positive reinforcement implied, no negative treatment.

Neha Lal VS Abhishek Kumar - 2026 2 Supreme 350: Advocates dissolution if marriage beyond salvage, prioritizes mediation over police in disputes. Balanced affirmative policy; no negative indicators.

Vishal Shah VS Monalisha Gupta - 2025 0 Supreme(SC) 380: Notes court exercise of jurisdiction for dissolution on breakdown amid no cohabitation/disputes. Affirmative use of power; no negative treatment.