Supreme Court of India Judgment: Mediation and Mutual Consent Divorce under Article 142
An Educational and Informational Overview of the Case — Jyotika Bhalla vs. Aman Mishra (Transfer Petition Civil No. 2742 of 2024)
Introduction
In a recent decision, the Supreme Court of India addressed a matrimonial dispute between Ms. Jyotika Bhalla and Mr. Aman Mishra, culminating in a peaceful resolution through the Supreme Court Mediation Centre.
The case, registered as Transfer Petition (Civil) No. 2742 of 2024, serves as a significant example of how complex marital disputes can be resolved amicably through mediation and finalized by invoking the Court’s constitutional powers under Article 142 of the Constitution of India.
This article is written for educational and informational purposes to help readers understand how the Supreme Court handles such cases, emphasizing the importance of mediation and mutual consent in matrimonial law.
Background of the Case
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The marriage between Ms. Jyotika Bhalla and Mr. Aman Mishra was solemnized on 15 July 2021 in New Delhi as per Hindu rites and ceremonies.
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Following marital differences, the couple began living separately from December 2021.
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Subsequently, both parties filed multiple legal proceedings, including civil and criminal cases, against each other and their family members in various courts across New Delhi and Ghaziabad.
Due to the number of ongoing matters, a Transfer Petition was filed before the Supreme Court, which later referred the matter to the Supreme Court Mediation Centre to explore the possibility of settlement.
Mediation and Settlement Process
After several mediation sessions facilitated by the Supreme Court Mediation Centre, both parties successfully reached an amicable Settlement Agreement on 19 May 2025.
Key highlights of the settlement include:
Full and Final Financial Settlement:
The respondent-husband agreed to pay the petitioner-wife ₹15,00,000 (Rupees Fifteen Lakhs Only) as a complete and final settlement. This amount covered all claims relating to alimony, maintenance (past, present, and future), Stridhan, and any other monetary rights.
Mutual Withdrawal of Cases:
Both parties agreed to withdraw all eleven ongoing civil and criminal cases filed against each other and their respective family members.
Divorce by Mutual Consent:
The parties consented to jointly apply under Article 142 of the Constitution of India for dissolution of their marriage, citing irretrievable breakdown and separation since December 2021.
Non-Interference Undertaking:
Both sides agreed not to interfere in each other’s lives, personal affairs, or professional activities, and to avoid any form of harassment, defamation, or social media communication.
Voluntary Nature of Settlement:
The agreement was executed voluntarily, without coercion, pressure, or influence, and was duly signed by both parties, their counsel, and the mediator.
Supreme Court’s Order
After reviewing the settlement, the Hon’ble Bench of Justice J.B. Pardiwala and Justice Sandeep Mehta accepted the agreement and issued the final order on 29 October 2025.
The Court observed that:
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The settlement payment of ₹15,00,000 had already been made by the husband to the wife.
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Both parties were directed to abide by all terms mentioned in the Settlement Agreement.
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The marriage was dissolved under Article 142 of the Constitution of India, ensuring complete justice.
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All civil and criminal proceedings between the parties stood terminated as per the settlement.
The Registry was instructed to draw a decree accordingly, formally concluding the matter.
Legal and Educational Insights
This judgment is significant from an educational and legal standpoint for several reasons:
Application of Article 142:
Article 142 grants the Supreme Court the power to issue any order necessary to do complete justice in any matter before it. In matrimonial disputes, this power allows the Court to dissolve marriages that are beyond reconciliation, even when statutory conditions under Section 13B(2) of the Hindu Marriage Act have not been fully satisfied.
Role of Mediation in Family Disputes:
The case underscores the growing success of court-annexed mediation, especially at the Supreme Court level. Mediation provides a neutral platform for dialogue, enabling parties to resolve disputes peacefully without prolonged litigation.
Promotion of Amicable Settlements:
The judgment promotes the concept of mutual respect and cooperation, encouraging parties to resolve disputes without adversarial confrontation, protecting emotional well-being and social harmony.
Educational Importance:
For law students and professionals, this case demonstrates how constitutional powers and mediation mechanisms work together to ensure fairness, efficiency, and closure in family law proceedings.
Conclusion
The judgment in Jyotika Bhalla vs. Aman Mishra highlights the humanitarian and equitable approach of the Supreme Court of India in dealing with sensitive family disputes. By combining mediation and judicial intervention under Article 142, the Court ensured a peaceful and legally sound conclusion for both parties.
This case serves as a valuable educational resource for understanding the intersection of family law, mediation, and constitutional authority, reinforcing the idea that true justice lies not only in legal victory but in reconciliation, dignity, and peace.
Disclaimer:
This article is intended solely for educational and informational purposes. It does not constitute legal advice. Readers seeking assistance in similar matters should consult a qualified legal professional.
