INTRODUCTION-

Ramanuj Kumar v. Priyanka decided on April 22, 2025, is a landmark judgementby the Supreme Court of India about the dissolution of marriage on the grounds of irretrievable breakdown of marriage by the bench led by Justice VikramNath in the year 2025.

In this present case of Ramanuj Kumar v. Priyanka the appellant (Ramanuj Kumar) filed a petition for divorce in Ranchi Family court by alleging his wife (Priyanka) under sections 13(1)(ia) and (iii)of the Hindu Marriage Act 1995. However, the petition for divorce was dismissed by the Ranchi family court and aggrieved by the dismissal appellant (Ramanuj Kumar ) moved to the High Court by filing the first appeal.After considering all the facts and circumstances, the Hon’ble High Court also upheld the dismissal of the Ranchi family court and dismissed the appeal.

Dissatisfied by the decision of both the family court and High Court,appellant (Ramanuj) approached the Supreme Court and appealed before the Supreme Court of India for the dissolution of marriage on the ground of the irremediable breakdown of the marriage.

After hearing both the parties Supreme Court found that the marriage had broken down beyond repair and all reconciliation efforts had failed, so despite of the fact that the ground for getting divorce filed by the appellant were not proved in the lower Court, Hon’ble Supreme Court by using its extraordinary powers under Article 142 of the constitution granted the decree of divorce to do complete justice. By the Hon’ble Court set the example that even if the ground of getting divorce is not proven and the parties are living separately for a long time and all the attempts of reconciliation havefailed, the Court may grant divorce on the ground of irretrievable breakdown of marriage in order to do complete justice.

FACTS OF THE CASE-

Ramanuj Kumar and Priyanka were married on November 24th, 2012. Priyanka is employed as an agriculture coordinator inthe Government of Bihar, and from this marriage the couple had two children.First, a daughter was born on August 17th , 2013 and Priyanka was pregnant with their second child, but meanwhile on March 6th,2024, appellant (Ramanuj) filed a petition before the family court of Ranchi seeking dissolution of marriage by a alleging the respondent (Priyanka) under section 13(1)(ia)and (iii)of Hindu Marriage Act 1995 These provisions deals with divorce on the grounds of cruelty and mental disorder,respectively.

In response, the respondent (Priyanka) filed case against the Ramanuj Kumar and his parents by alleging them for mental and physical cruelty under section 498A of IPC and she also accused them for demanding dowry under section 3 and 4 of dowry Prohibition Act which criminalize the giving and demanding of dowry.

Meanwhile all of these legal disputes, on November 13th, 2014 Priyanka gave birth to their second child, who was unfortunately diagnosed with a serious disease called cerebral palsy. Priyanka took sole responsibility for the care and treatment the second child simultaneously discharging her duties as a government servant. But unfortunately after sometime the child passed away because of the said disease. Meanwhile the custody of first child remained with the appellant (Ramanuj).

After by hearing both the parties and considering all the facts and evidences nearly after seven years on 2th July 2019 the family court of Ranchi dismissed the appellant petition for divorce and aggrieved with this dismissal applicant filed an appeal before the High Court.

On June 28, 2023,the High Court by considering all the facts and argument,state that it is evident by the birth of the second child on November 30, 2014 that the parties cohabitation until the month of March 2014. These allegations of cruelty and mental disorder to that time were deemed baseless, so thehigh court upheld the dismissal of the family court and dismissed the appeal.

Ultimately dissatisfied with the findings and decision of both the family court and high court appellant approached the Supreme Court by filing an appeal before the Supreme court seeking to dissolve the marriage on the grounds of irremediable breakdown of marriage by asserting that the couple had been living separately for at least 11 years and the marriage had broken down beyond repair.

With regard to custody of first child, the appellant contented that despite of such a long separation of around 11 years the responded never claim custody of first child in any Court and appellant had taken sole responsibility for the child upbringing and education for over years. So the custody is lawful and must remain with him.

In response, the respondent argued that she lacked the time and emotional capability to claim the custody of the first child because she is fully occupied with the care and treatment of the second child , while also discharging her duties as a government servant.Considering all the arguments and facts of the case, three major issues comes before the court-

ISSUES-

1. Whether the marriage between the parties has irretrievable broken down beyond repair?

2. Whether the Supreme Court can dissolve marriage by using its power given under Article 142 of the Constitution in the interest of complete Justice?

3. Whether the respondent is entitled to visitation right with her daughter?

JUDGEMENT-

After analyzing all the facts, argument of both the parties, and circumstances of the case Hon’ble Supreme Court found that the marital relationship between the parties had broken down irretrievably and all the reconciliation efforts had failed since both the parties had been living separately from 11 years. Moreover neither parties showed willingness to continue the marriage therefore any effort by court to sustain this marriage would result unnecessary suffering or hardship for both the parties. Despite of the fact that the ground filed by Appellant for divorce under section 13(1)(ia) and (iii) were not proved before Lower court, Hon’ble Supreme court invoked powersunder Article 142 of the constitution (which empowers Supreme Court to pass degree or order to ensure complete justice )exercising this power court allowed dissolution of the marriage on the ground of irretrievable breakdown of marriage.

Additionally the Hon’ble court also held that despite of the fact that respondent neither file for custody or nor for vegetation right in long separation but denying her access to her child will not only emotionally affect the mother but also negatively impact the child well-being. Therefore in the interest of Justice and welfare of the child the Honb’le Court held that the respondent is entitled to vegetation right twice in a month at the residence of appellant. It was also directed that all the expenses of vegetation should be incurred by applicant and court said that further parties have any dispute regarding custody of child they may move to the competent court.

IMPACT OF THE CASE-

I believe that, this landmark judgment delivered by the Hon’ble Supreme Court has a significant impact on the Indian justice system, particularlythose who are stuck in unworkable marriages and has been trying for years to get divorce. Traditionally, the Indian legal frameworks always try to preserving the institution of marriage through reconciliation efforts. But even when the marriage is obviously irreparably damaged and neither parties are willing to stay together in such situations continuing marriage is nothing just unnecessary suffering and hardship for the parties. With this ruling, the Supreme Court has made it very evident that when a marriage has irretrievably failed, the parties should be granted a divorce rather than being forced to put up with needless emotional suffering and protracted legal proceedings. By granting a divorce based on an irretrievable breakdown of the marriage, Article 142 of the Constitution ensure complete justice for the parties.

CONCLUSION –

Overall the Supreme Court judgement in Ramanuj Kumar v. Priyanka 2025 makes a significant stape forward in the resolution of matrimonial dispute. By affirmed the importance and validity of irretrievable breakdown of marriage as a ground of divorce. Despite of that the ground of divorce filed by one of the spouse is not proved before Lower court. It recognized that when parties have been living separately for a long period of time without any possibility of reconciliationforcing them to continue the marriage results nothing just unnecessary hardship for both the parties.

This judgement prioritizes the mental and emotional well-being of both the parties over the formal continuation of the marriage. Additionally by granting vegetation right to the respondent for her daughter Hon’ble Court protect and ensure the Justice and welfare of both mother as well as child.

In essence, by using Article 142 of the Constitution to dissolve the marriage and ensure complete justice, the Supreme Court has taken a progressive approach to matrimonial law.

CITATIONS-

Primary Sources-

1. Hindu Marriage Act, No. 25 of 1955, §§ 13(1)(ia), 13(1)(iii) (India).

2. Indian Penal Code, No. 45 of 1860, § 498A (India).

3. INDIA CONST. art142

4. Dowry Prohibition Act, No. 28 of 1961, §§ 3–4 (India).

Secondary sources-

1.[Supreme Court of India],[https://www.sci.gov.in/],[15/05/2025

[1] Ramanuj Kumar v. Priyanka ,2025 INSC 543.