Demanding Proof Beyond Reasonable Doubt in Civil Disputes Over Stridhan Is Legally Unsustainable: Supreme Court

In a landmark decision today, the Supreme Court corrected a significant legal misstep by the Kerala High Court, affirming that the standard of proof in civil disputes, especially those involving Stridhan (woman’s marital property), is ‘preponderance of probabilities’ and not the criminal standard of ‘beyond reasonable doubt’.

The apex court highlighted the inappropriate application of the criminal standard of proof by the High Court in a civil dispute regarding Stridhan, reinforcing that civil disputes should be judged on the ‘preponderance of probabilities.’

The case revolved around Maya Gopinathan, who accused her husband, Anoop S.B., and his late brother of misappropriating her gold jewelry and a monetary gift. Although the Family Court ruled in her favor, the High Court reversed this partially, prompting the Supreme Court review.

Standard of Proof: The Supreme Court noted that the High Court erroneously demanded proof beyond reasonable doubt for a civil matter involving Stridhan. The Supreme Court reasserted the correct standard—preponderance of probabilities.

Entrustment and Misappropriation: The Supreme Court upheld the Family Court’s finding that Gopinathan entrusted her jewelry to her husband for safekeeping, which he misappropriated. The High Court’s dismissal of this finding was criticized for lacking a factual basis.

Evidence Evaluation: Criticizing the High Court’s speculative re-evaluation of evidence, the Supreme Court underscored the necessity of adhering to the factual conclusions drawn by the Family Court, particularly in the context of matrimonial trust and the dynamics of personal relationships.

Decision of the Judgment: Overturning the High Court’s decision, the Supreme Court reinstated the Family Court’s judgment with modifications, awarding Gopinathan Rs. 25,00,000 to account for the escalation in costs over time. This decision underscored the application of Article 142 of the Constitution to meet the ends of justice and equity.

Date of Decision: April 24, 2024

Maya Gopinathan vs. Anoop S.B. & Anr.