Jurisdiction of Family Courts in Matrimonial Status Declarations

The Supreme Court of India in Civil Appeal No. 4500 of 2016 addressed the issue of whether the Family Court had jurisdiction to decide on a declaration that a person is not legally married. The case involved Balram Yadav (Petitioner) and Fulmaniya Yadav (Respondent), where the petitioner sought a declaration that the respondent was not his legally wedded wife.

The Family Court at Ambikapur, Sarguja, Chhattisgarh, ruled in favor of the petitioner on December 28, 2013. However, the respondent challenged this ruling before the High Court of Chhattisgarh, which set aside the Family Court’s decision, holding that a negative declaration regarding marriage was outside the jurisdiction of the Family Court.

Petitioner’s Arguments

The petitioner contended that:

• Section 7(1)(b) of the Family Courts Act, 1984, provides exclusive jurisdiction to the Family Court to determine the validity of a marriage or the matrimonial status of a person.
• Since the Act overrides other laws, the Family Court was the appropriate forum for such a declaration.
• The High Court’s decision was erroneous as it disregarded the provisions of the Family Courts Act.

Respondent’s Arguments

The respondent argued that:

• The Family Court lacked jurisdiction to grant a negative declaration that she was not legally married to the petitioner.
• The High Court correctly held that such declarations should be handled by Civil Courts.
• The Family Courts Act does not explicitly mention granting negative declarations regarding marital status.

Judgment

The Supreme Court analyzed the provisions of the Family Courts Act and made the following observations:

“Under Section 7(1) Explanation (b), a suit or a proceeding for a declaration as to the validity of both marriage and matrimonial status of a person is within the exclusive jurisdiction of the Family Court.”

The Court further emphasized that the distinction between affirmative and negative declarations was irrelevant, as the law intends for Family Courts to handle all matters related to marriage and matrimonial status.

The Supreme Court set aside the High Court’s ruling and remitted the matter back to the High Court for reconsideration on merits, directing it to dispose of the case within six months.

Key Takeaways

• Family Courts have jurisdiction over cases related to the validity of marriage and matrimonial status, including both affirmative and negative declarations.
• The Family Courts Act, 1984, overrides conflicting laws, ensuring exclusive jurisdiction in matrimonial matters.
• The case clarifies that negative declarations regarding marriage also fall within the purview of Family Courts.

This ruling reaffirms the legislative intent behind the Family Courts Act, providing clarity on jurisdictional issues related to marriage declarations.

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Download Judgment: Balram Yadav vs Fulmaniya Yadav Supreme Court of India Judgment Dated 27-04-2016-1741854737941.pdf