How the Supreme Court Used Its Extraordinary Powers to Resolve a Complex Matrimonial Dispute
Introduction
In a significant ruling, the Supreme Court of India recently demonstrated the power of mediation and its own constitutional authority to bring a complete and amicable end to a deeply entangled matrimonial dispute.
The case of Jyotika Bhalla vs. Aman Mishra (Transfer Petition (Civil) No. 2742/2024) serves as an excellent precedent for how legal systems can facilitate holistic resolutions, moving beyond protracted litigation.
This article breaks down the key aspects of the judgement for educational purposes, highlighting the legal principles and practical outcomes.
The Supreme Court of India recently delivered an important order in Jyotika Bhalla vs. Aman Mishra, where the marriage between the parties was dissolved under Article 142 of the Constitution of India.
The judgment serves as a noteworthy example of how matrimonial disputes can be amicably resolved through mediation at the Supreme Court Mediation Centre and finalized through the Court’s extraordinary constitutional powers.
Supreme Court Judgment: Amicable Settlement and Divorce Under Article 142
Case Overview
Case Title: Jyotika Bhalla vs. Aman Mishra
Case Type: Transfer Petition (Civil) No. 2742 of 2024
Court: Supreme Court of India, Civil Original Jurisdiction
Bench: Justice J.B. Pardiwala and Justice Sandeep Mehta
Judgment Date: 29th October 2025
Background: A Marriage and a Multitude of Cases
The marriage between Jyotika Bhalla and Aman Mishra was solemnized in July 2021 but broke down irretrievably within months, with the parties separating in December 2021. What followed was a familiar, yet extreme, pattern of legal escalation:
-
Multiple Forums: The couple and their families were embroiled in a web of at least twelve separate legal proceedings across courts in Delhi and Ghaziabad.
-
Variety of Cases: These included a divorce petition, cases under the Domestic Violence Act, criminal cases (including FIRs under Sections 498A, 406 IPC), maintenance petitions, and defamation suits.
-
The parties, Ms. Jyotika Bhalla and Mr. Aman Mishra, were married on _____ as per Hindu rites in New Delhi.
-
Due to marital differences, they separated in December 2021.
-
Multiple legal proceedings followed, including cases under the Domestic Violence Act, Section 498A IPC, and divorce petitions in both Delhi and Ghaziabad family courts.
As conflicts multiplied, the petitioner approached the Supreme Court by filing a Transfer Petition (Civil) No. 2742/2024, seeking to transfer matrimonial proceedings.
Recognizing the possibility of reconciliation or settlement, the Court referred the matter to the Supreme Court Mediation Centre.
This situation perfectly illustrated how a matrimonial dispute could spill over into numerous legal battles, consuming time, resources, and emotional energy.
The Turning Point: Successful Mediation
Recognizing the futility of continued litigation, the Supreme Court, on March 20, 2025, referred the matter to the Supreme Court Mediation Centre. After several mediation sessions, the parties reached a comprehensive settlement on May 19, 2025.
The key terms of the Settlement Agreement were:
-
Financial Settlement: Mr. Mishra agreed to pay a one-time sum of ₹15,00,000 to Ms. Bhalla. This amount was designated as a full and final settlement for all her claims, including permanent alimony, stridhan, and past, present, and future maintenance.
-
Withdrawal of All Cases: Both parties agreed to withdraw all pending civil and criminal cases filed against each other and their respective family members.
-
Mutual Non-Disclosure and Non-Defamation: The parties agreed to no future contact, not to defame each other, and not to interfere in each other’s personal or professional lives. Crucially, they also agreed not to file any RTIs or other inquiries about one another.
-
Prayer for Divorce: They jointly agreed to approach the Supreme Court for a decree of divorce by mutual consent under Article 142 of the Constitution of India, citing an irretrievable breakdown of the marriage.
The Supreme Court’s Final Order: Wielding Article 142
In its order dated October 29, 2025, the Supreme Court bench comprising Justices J.B. Pardiwala and Sandeep Mehta took the following decisive actions:
-
Allowed the Application under Article 142: The Court invoked its extraordinary power under Article 142 of the Indian Constitution, which allows it to pass any decree or order necessary to “do complete justice.”
-
Dissolved the Marriage: Exercising this power, the Court dissolved the marriage between the parties by mutual consent.
-
Terminated All Proceedings: The Court ordered that all connected civil and criminal proceedings listed in the settlement agreement stand terminated.
-
Made the Settlement Binding: The terms of the settlement agreement were taken on record and made legally binding on both parties.
It was also recorded that the husband had already complied with the financial terms, paying the entire settlement amount of ₹15,00,000 to the wife.
Key Takeaways for Legal Practitioners and the Public
-
The Efficacy of Mediation: This case is a powerful testament to the effectiveness of mediation in resolving complex, multi-proceeding disputes. It offers a faster, less adversarial, and more comprehensive solution compared to fighting each case individually.
-
Article 142 – A Tool for Complete Justice: The judgement showcases the practical application of Article 142. Where the normal procedural requirements of the Hindu Marriage Act for mutual divorce (like the six-month waiting period under Section 13B) might have been impractical given the numerous cross-cases, the Supreme Court used its plenary power to achieve a final and just outcome.
-
Holistic Resolution: The settlement did not just address the divorce. It brought a definitive close to the entire ecosystem of conflict, including criminal complaints and cases involving extended family members, ensuring lasting peace.
-
Clarity in Settlements: The settlement agreement serves as a model for drafting comprehensive terms, covering financial closure, withdrawal of cases, and future conduct to prevent further litigation.
Conclusion
The Supreme Court’s decision in Jyotika Bhalla vs. Aman Mishra is a landmark for its pragmatic and humane approach to justice. By endorsing a mediated settlement and using its constitutional authority to give it full legal effect, the Court provided the parties with a clean break and a path forward.
This case will undoubtedly be cited as a leading example of promoting alternative dispute resolution (ADR) and utilizing the wide powers of the Supreme Court to ensure “complete justice” in the truest sense.
Disclaimer: This article is for informational and educational purposes only and does not constitute legal advice. Readers are advised to consult with a qualified legal professional for any specific legal matters.
