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Supreme Court of India10 April 20262026 INSC 346

Mamta Devi v. Sanjay Kumar

Bench of 2 · Justice Vikram Nath, Justice Sandeep Mehta

Why it matters

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Advocates in matrimonial matters should note that the Supreme Court, while declining to disturb concurrent factual findings on cruelty and desertion, exercised its jurisdiction to convert a one-time lump-sum maintenance award into a recurring monthly payment — a useful precedent for arguing that the form of maintenance can be restructured at the appellate stage even where the divorce decree itself is upheld.

Summary

The appellant-wife challenged, before the Supreme Court in a Civil Appeal, the concurrent decree of divorce granted to the respondent-husband by the Family Court, Bokaro and affirmed by the High Court of Jharkhand. The divorce had been granted under Sections 13(1)(ia) and 13(1)(ib) of the Hindu Marriage Act, 1955 on the grounds of cruelty and desertion. The parties were married in 2002 and have been living separately since 2018; two children were born of the marriage.

The Family Court had found, on appreciation of oral and documentary evidence, that the appellant's persistent quarrelling, abusive conduct towards the respondent's parents, and the circumstances noted by the District Welfare Committee (which directed the children to reside with their paternal grandfather) cumulatively established cruelty and desertion. The High Court affirmed those findings, additionally relying on an undertaking furnished by the appellant in 2017 to maintain cordial relations, the testimony of the parties' son supporting the cruelty allegations, and the appellant's own statement that she did not want the children to stay with her.

The Supreme Court disposed of the appeal, declining to interfere with the concurrent findings of fact, holding that no perversity had been demonstrated. The Court noted that a marriage of over two decades with separation since 2018 indicated the matrimonial bond had broken down beyond repair. However, on the question of maintenance, the Court exercised its power to do complete justice and modified the Family Court's direction of a lump-sum payment of Rs.6,00,000/- to a monthly maintenance of Rs.10,000/- payable from the date of the order, ensuring continued financial support to the appellant.

Key principle

Concurrent findings of fact by the Family Court and the High Court on cruelty and desertion under Sections 13(1)(ia) and 13(1)(ib) of the Hindu Marriage Act, 1955 will not be disturbed by the Supreme Court in the absence of demonstrated perversity; prolonged separation since 2018 in a marriage solemnised in 2002 is itself indicative that the matrimonial bond has broken down beyond repair.

Holding

Disposed of — the concurrent decree of divorce on grounds of cruelty and desertion was upheld as findings of fact warranting no interference, but the lump-sum maintenance of Rs.6,00,000/- was substituted with a monthly maintenance of Rs.10,000/- payable from the date of the Supreme Court's order.

Statutes invoked

  • Hindu Marriage Act, 1955 · 13(1)(ia)
  • Hindu Marriage Act, 1955 · 13(1)(ib)

Practice areas

family
AI-generated summary, written by Claude Sonnet 4.6 from the court's published judgment. Always verify the original before relying on the summary in court. Generated on 21 May 2026.