Educational Article: Understanding the Supreme Court Judgment in the Case of Jyotika Bhalla vs. Aman Mishra (Transfer Petition Civil No. 2742/2024)
Introduction
The Supreme Court of India plays a vital role in ensuring that justice is delivered not only through legal interpretation but also through human understanding and equitable solutions. A recent judgment in the case of Jyotika Bhalla vs. Aman Mishra is a noteworthy example of how matrimonial disputes can be effectively resolved through mediation and mutual agreement under the guidance of the Supreme Court.
This case provides valuable educational insight into how mediation, settlement agreements, and constitutional powers under Article 142 are applied in family law matters to bring about complete justice.
Background of the Case
The petitioner, Ms. Jyotika Bhalla, and the respondent, Mr. Aman Mishra, were married on 15 July 2021 according to Hindu rites and customs. However, due to marital discord, the couple began living separately from December 2021.
Following the separation, both parties initiated multiple civil and criminal cases against each other and their respective family members. These cases included proceedings under the Hindu Marriage Act, Domestic Violence Act, and Sections 498A, 406, and 34 of the Indian Penal Code (IPC).
Given the multiplicity of proceedings and the continued strain between the families, a Transfer Petition (Civil No. 2742 of 2024) was filed before the Supreme Court of India, seeking to consolidate or transfer ongoing matrimonial cases.
Mediation and Settlement
Recognizing the scope for reconciliation or amicable resolution, the Supreme Court referred the matter to the Supreme Court Mediation Centre. Through a series of mediation sessions, both parties were able to resolve their disputes and arrive at a Settlement Agreement dated 19th May 2025.
The settlement was comprehensive and included the following key terms:
Financial Settlement:
The husband agreed to pay the wife a sum of ₹15,00,000 (Rupees Fifteen Lakhs Only) as a full and final settlement. This payment covered all claims relating to alimony, maintenance (past, present, and future), Stridhan, and any other financial obligations.
Withdrawal of Legal Proceedings:
Both parties mutually agreed to withdraw all eleven pending civil and criminal cases filed against each other and their family members in various courts across New Delhi and Ghaziabad.
Divorce by Mutual Consent:
The parties agreed to seek dissolution of marriage by mutual consent through an application under Article 142 of the Constitution of India, acknowledging that they had been living separately for more than three years and that the marriage had irretrievably broken down.
Non-Interference Undertaking:
Both parties undertook not to interfere in each other’s personal or professional lives and to refrain from any conduct that could harm the reputation or privacy of the other party or their families.
Finality of Agreement:
The settlement was reached voluntarily, without coercion, and both parties confirmed that they had no further claims or demands against each other.
Supreme Court’s Order
Upon reviewing the Settlement Agreement, the Hon’ble Supreme Court Bench comprising Justice J.B. Pardiwala and Justice Sandeep Mehta recorded that:
-
The payment of ₹15,00,000 had already been made by the husband to the wife.
-
Both parties agreed to abide by all terms of the settlement.
-
All pending cases and proceedings between them were to be treated as terminated.
-
The marriage was dissolved under Article 142 of the Constitution of India.
The Court directed that the original Settlement Agreement be kept on record and ordered the Registry to draw a formal decree of divorce.
Legal and Educational Significance
This case holds educational importance for students, practitioners, and researchers of law, as it demonstrates multiple key principles in Indian jurisprudence:
Power of Article 142:
Article 142 of the Constitution empowers the Supreme Court to pass any order necessary to do “complete justice” in any matter before it. In matrimonial cases, this allows the Court to dissolve marriages that are clearly beyond reconciliation, even if procedural formalities under Section 13B of the Hindu Marriage Act are pending.
Role of Mediation in Family Law:
The success of the Supreme Court Mediation Centre in facilitating a voluntary and amicable settlement highlights the growing importance of alternative dispute resolution (ADR) methods in matrimonial disputes.
Holistic Approach to Justice:
The judgment reflects how the Court balances legal principles with humane considerations, prioritizing closure, peace, and mutual respect over prolonged adversarial litigation.
Conclusion
The Supreme Court’s judgment in Jyotika Bhalla vs. Aman Mishra is an important educational example of how the highest court of the land applies constitutional powers, mediation, and consent to resolve deeply personal disputes.
It serves as a learning model for legal education and awareness — demonstrating that justice is not only about law but also about fairness, empathy, and resolution. The case reinforces the message that mediation and mutual consent can lead to peaceful closure, ensuring dignity and respect for both parties involved.
