Family Courts Cannot Be Exclusive Arbiters in Property Disputes Merely Indicating Matrimonial Links: Delhi High Court Clarifies Jurisdiction
In a significant judgment addressing the scope of the Family Courts’ jurisdiction, the Delhi High Court clarified that property disputes involving in-laws and daughters-in-law, where the cause of action is independent of the marital relationship, do not exclusively fall under the Family Court’s purview.
The bench of Hon’ble Mr. Justice Yashwant Varma and Hon’ble Mr. Justice Dharmesh Sharma delivered the judgment in the case of ABC vs XYZ, which centered on whether Family Courts have jurisdiction over suits for possession or injunction filed by in-laws claiming exclusive ownership of property involving daughters-in-law.
Facts and Legal Issues:
The matter arose from a dispute between a mother-in-law (plaintiff) and her daughter-in-law (defendant) concerning the right to stay in a property exclusively owned by the plaintiff. The central legal question was whether such suits should be tried exclusively by Family Courts, thus barring Civil Court’s jurisdiction.
Court’s Assessment and Conclusion:
The Court held that disputes merely indicating matrimonial relationships, such as the one in question, do not fall exclusively under Family Court jurisdiction. The rights to property are independent of matrimonial relationships, thereby allowing Civil Courts to retain jurisdiction.
Justice Sharma, writing for the bench, emphasized that mere existence of a matrimonial relationship between parties is not sufficient to confer jurisdiction upon Family Courts. The cause of action must have a direct and intrinsic connection with the marital relationship. Furthermore, the impleadment or non-impleadment of the husband in such cases does not influence the jurisdiction determination.
Overruling of Previous Judgments:
The Court overruled the judgment in Avneet Kaur, which held that jurisdiction of Family Courts is not limited to disputes between husband and wife and encompassed broader circumstances arising out of marital relationships. Instead, the Court aligned with the views in Manita Khurana and Meena Kapoor, focusing on the intrinsic link of the dispute with the marital relationship.
Impact and Future Implications:
This landmark judgment clarifies the jurisdictional boundaries between Family and Civil Courts, ensuring that property disputes, unless inherently connected to matrimonial issues, are adjudicated in the appropriate forum. It establishes a clear criterion for jurisdiction based on the cause of action’s foundation in the marital relationship.
Date of Decision: April 1, 2024
ABC vs XYZ
