Supreme Court Quashes DV Proceedings Initiated After Mediated Settlement Agreement: Key Ruling in Matrimonial Dispute

Case Overview

Dhananjay Rathi Vs Ruchika Rathi (Supreme Court of India)

The Supreme Court of India delivered a significant ruling in a matrimonial dispute where a mediated settlement agreement had been partially performed but subsequently abandoned by one party, who then initiated fresh proceedings under the Protection of Women from Domestic Violence Act, 2005. The Court quashed the domestic violence complaint, dissolved the marriage under Article 142(1) of the Constitution of India, and issued comprehensive directions to enforce the remaining obligations under the settlement.

Background Facts

The parties were united in matrimony on 19 February 2000 under Hindu rites and customs. The marriage produced two children — a daughter born on 06 June 2003 and a son born on 01 January 2006, both of whom had attained adulthood by the time the matter was adjudicated. Marital discord began emerging around 2022–23, causing the couple to live separately.

Following the breakdown of cohabitation, the husband instituted H.M.A. No. 275/2023 before the Principal Judge, Family Court, Saket Court House, Delhi, seeking dissolution of marriage under Sections 13(1)(i-a) and 13(1)(ia) of the Hindu Marriage Act, 1955 on the grounds of cruelty and adultery.

Mediation and Settlement Agreement

The Family Court referred the dispute to mediation on 13 July 2023. After extensive negotiations conducted at the Delhi Mediation Centre, Saket Courts, the parties arrived at a comprehensive Settlement Agreement dated 16 May 2024, addressing all aspects of their matrimonial discord. The principal terms of the settlement were as follows:

  • Both parties agreed to seek dissolution of marriage through mutual consent under Sections 13B(1) and 13B(2) of the Hindu Marriage Act, 1955
  • The husband agreed to withdraw H.M.A. No. 275/2023
  • The husband committed to paying ₹1,50,00,000/- (inclusive of ₹4,77,129/- from his PPF account) in two tranches:
    • ₹75,00,000/- at the First Motion stage
    • ₹70,22,871/- at the Second Motion stage
  • The wife agreed to execute a Gift Deed for ₹2,52,38,794/- in favour of the husband to regularise amounts reflected in his business account arising from their matrimonial relationship
  • The husband agreed to pay ₹14,00,000/- towards purchase of a new vehicle for the wife
  • The husband agreed to return all jewellery specified in Appendix A to P of the settlement
  • The wife agreed to execute transfer documents for the following assets standing in her name:
    • Flat No. E-2002, Mascot GH-04B/1, Sector 16, Greater Noida (Project Manorath)
    • Flat No. 02/1704, Patel GH-03, Tech Zone, Greater Noida (Project Neo Town)
    • Flat No. D2/1705, Patel GH-03, Tech Zone, Greater Noida (Project Neo Town)
    • LIC Policy No. 117410693 and Bajaj Allianz Policy No. 0506426223
    • Shares held in Globe Capital, K.L. Rathi Steels, and Rathi Steels Ltd.
    • A jewellery account maintained in the name of their daughter
  • Both parties undertook to refrain from instituting any civil or criminal proceedings against each other or their respective family members in the future

Performance of Settlement Obligations and Subsequent Events

On 04 July 2024, the husband withdrew H.M.A. No. 275/2023 and jointly filed a petition for divorce by mutual consent under Section 13B(1) of the Hindu Marriage Act, 1955, registered as H.M.A. No. 1185/2024, accompanied by Affidavits of Undertaking dated 03 July 2024 executed by both parties.

The Family Court allowed the First Motion on 14 August 2024. In compliance with the settlement:

  • The husband paid ₹75,00,000/- as the first instalment and ₹14,00,000/- for the vehicle
  • The husband returned all jewellery as enumerated in Appendix A to P
  • The wife transferred ₹2,52,38,794/- to the husband

The Second Motion was required to be filed on or before 20 February 2025. However, before the deadline, the wife withdrew her consent to the mutual divorce.

Following withdrawal of consent, the husband filed Contempt Petition No. 07/2025 before the Principal Judge, Family Court, South District, Saket. The wife thereafter filed D.V. Complaint No. 3186 of 2025 on 16 October 2025 under Section 12 of the Protection of Women from Domestic Violence Act, 2005 against the husband and his mother before the Chief Metropolitan Magistrate, Saket Courts, Delhi. Summons were issued vide order dated 13 November 2025.

Proceedings Before the Delhi High Court

The husband withdrew the contempt petition and approached the Delhi High Court by filing Crl. M.C. No. 116 of 2026 under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 seeking quashing of D.V. Complaint No. 3186 of 2025. He also filed Contempt Case (C) No. 19 of 2026 before the High Court for breach of the Settlement Agreement.