Supreme Court of India Judgment: Divorce by Mutual Consent under Article 142
Introduction
The Supreme Court of India recently delivered an important judgment in the case of Jyotika Bhalla vs. Aman Mishra (Transfer Petition Civil No. 2742 of 2024), showcasing how mediation and mutual consent can effectively resolve matrimonial disputes.
This case stands as an educational example for students, legal professionals, and readers interested in understanding how the Supreme Court uses its constitutional powers under Article 142 to deliver complete justice in family matters.
Background of the Case
The petitioner, Ms. Jyotika Bhalla, and the respondent, Mr. Aman Mishra, were married on 15 July 2021 as per Hindu rites in New Delhi. The couple began living separately from December 2021, leading to several legal disputes across multiple courts.
A total of eleven cases, both civil and criminal, were pending between the parties and their family members — including petitions under the Hindu Marriage Act, Domestic Violence Act, and criminal complaints under Sections 498A, 406, and 34 of the IPC.
To consolidate the proceedings, the petitioner approached the Supreme Court of India through a Transfer Petition (Civil No. 2742/2024). Recognizing the potential for resolution, the Hon’ble Court referred the matter to the Supreme Court Mediation Centre.
Mediation and Settlement
After a series of detailed mediation sessions, both parties successfully reached a Settlement Agreement on 19 May 2025, duly signed by the parties, their counsel, and the mediator.
Full and Final Settlement:
The husband agreed to pay the wife ₹15,00,000 (Rupees Fifteen Lakhs Only) as a full and final settlement covering all claims — including alimony, maintenance (past, present, and future), and Stridhan.
Withdrawal of Pending Cases:
Both parties agreed to withdraw all eleven ongoing civil and criminal cases filed against each other and their family members.
Mutual Consent Divorce:
The parties jointly applied under Article 142 of the Constitution of India for dissolution of marriage, acknowledging the irretrievable breakdown of the relationship and their separation since December 2021.
Non-Interference Clause:
Each party agreed not to interfere in the other’s personal or professional life, to avoid defamation, and to maintain mutual respect and privacy.
Voluntary and Binding Agreement:
Both parties affirmed that the settlement was made voluntarily, without pressure or coercion, and that they would not initiate any future legal action concerning the marriage.
Supreme Court’s Judgment
The case was heard by the Bench of Hon’ble Justice J.B. Pardiwala and Hon’ble Justice Sandeep Mehta, who accepted the Settlement Agreement and passed a final order on 29 October 2025.
The Supreme Court:
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Confirmed that the payment of ₹15,00,000 had already been made by the husband to the wife.
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Directed both parties to abide by all terms of the agreement.
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Dissolved the marriage under Article 142 of the Constitution of India.
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Ordered that all civil and criminal proceedings mentioned in the settlement stand terminated.
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Directed the Registry to draw a formal decree of divorce.
This judgment reaffirmed the Supreme Court’s authority to ensure complete justice, even when procedural stages under the Hindu Marriage Act, 1955 have not been fully completed.
Legal and Educational Significance
Use of Article 142 for Complete Justice:
Article 142 empowers the Supreme Court to pass any order necessary for complete justice in any case before it. In matrimonial disputes, this power allows the Court to dissolve marriages that are clearly beyond reconciliation — a doctrine often referred to as irretrievable breakdown of marriage.
Promoting Mediation as a Resolution Tool:
This case demonstrates the efficiency and value of mediation in resolving sensitive family matters. Mediation offers privacy, emotional closure, and mutual respect, often absent in prolonged litigation.
Importance of Mutual Consent:
The judgment reinforces the legal and social significance of mutual consent divorces, emphasizing that amicable settlements protect both parties from further distress and unnecessary litigation.
Educational Relevance:
For law students, legal researchers, and professionals, this case serves as a model for understanding how constitutional powers, family law principles, and alternative dispute resolution mechanisms work cohesively in the Indian judicial system.
Conclusion
The Supreme Court’s decision in Jyotika Bhalla vs. Aman Mishra stands as a powerful reminder that justice in family law is not merely about legal victory — it is about fairness, closure, and human dignity.
Through mediation and the Court’s equitable powers under Article 142, the dispute was resolved peacefully, demonstrating that legal remedies can coexist with compassion and understanding.
This case continues to serve as an educational example of how the Indian judiciary promotes harmony, mutual respect, and lasting resolution in matrimonial disputes.
Disclaimer
This article is intended solely for educational and informational purposes. It does not constitute legal advice. For professional guidance in similar matters, please consult a qualified legal practitioner or reach out to Legal Light Consulting (LLC Lawyer).
