The Supreme Court of India, in the landmark judgment of Dhananjay Rathi v. Ruchika Rathi, Criminal Appeal No. 1924 of 2026, decided on 13 April 2026, emphasizing the importance of mediation settlements in matrimonial disputes. The Court held that when both the party voluntarily enter into a settlement and act upon it, they cannot later back out/ resile without a valid reason. The judgment serves as a significant precedent in matrimonial disputes where one party attempts to resile from a voluntarily executed settlement after getting benefits from it.
Facts
The Parties were married in the year 2000. Due to differences and disputes, they started living separately since 2022-2023. Over time, several legal cases were filed between them, including divorce proceedings and other matrimonial disputes.
To resolve differences, the parties participated in mediation before the Delhi High Court Mediation Centre. In mediation, they reached a comprehensive settlement. Under the settlement terms the husband will pay an amount of Rs. 1,50,00,000/-, all the jewellery as mentioned by the wife along with the PPF and other funds Both parties voluntarily signed the settlement and acted upon it.
However, after receiving the benefits of the settlement, the wife withdrew her consent for mutual divorce and initiated proceedings under the Protection of Women from Domestic Violence Act, 2005, against the husband and his mother. This led to fresh litigation between the parties.
The husband challenged these proceedings before the Delhi High Court, and eventually approached the Supreme Court under the Criminal appeal No. 1924 OF 2026.
The Supreme Court framed issues
- Whether the proceedings initiated by the Respondent Wife under the DV Act should be quashed?
- Whether any party can back out from the Settlement Agreement arrived at in the mediation proceedings? If yes, in what situation?
- Whether this Court, in the case in hand, can exercise its powers under Article 142(1) of the Constitution of India to grant a decree of divorce to the parties herein on the ground of irretrievable breakdown of marriage, upon an application filed by the Appellant-Husband? If yes, then on what terms and conditions?
Supreme Court’s observation
The Court categorically reiterated that mediation settlements are not mere informal understandings but solemn agreements voluntarily entered into by parties. Once parties have acted upon such a settlement and received benefits thereunder, they cannot arbitrarily backout from its terms unless there is proof of fraud, coercion, misrepresentation, or non-performance by the opposite party.
Also, it is observed that permitting parties to withdraw from mediated settlements without justification would undermine the entire Alternative Dispute Resolution (ADR) framework and discourage amicable settlement of disputes among the parties.
Abuse of Process Through Subsequent Litigation:
The Supreme Court examined the domestic violence complaint of the respondent-wife which was filed 8 months subsequently withdrawing the consent from mutual divorce even signing the settlement. The allegations were largely general and lacked specific particulars. The Court found that initiation of fresh proceedings after voluntarily entering into a settlement and accepting benefits thereunder amounted to misuse of legal process in the peculiar facts of the case.
Exercise of Powers Under Article 142
The Court observed that the marriage had completely broken down and there was no possibility of reconciliation between the parties. They had been living separately since 2022 and were involved in continuous litigation. To put an end to the dispute and ensure complete justice, the Court exercised its extraordinary powers under Article 142 of the Constitution and dissolved the marriage.
Quashing of Proceedings
The Court quashed the domestic violence proceedings and other litigations arising out of the matrimonial dispute, stating that continuation of such proceedings would amount to abuse of the process of law in light of the comprehensive settlement already arrived at between the parties.
Legal Significance of the Judgment
- Strengthening Mediation in India
- Protection Against Frivolous Matrimonial Litigation
- Expansion of Article 142 Jurisprudence
- Encouragement of Finality in Family Disputes
The decision will serve as an important precedent for future cases involving mediation settlements, matrimonial disputes, and the exercise of powers under Article 142 of the Constitution.
