Even if the father is the natural guardian under Indian law. Legal guardianship cannot automatically override the child's welfare.

In a notable case, the Madhya Pradesh High Court granted custody of a 2.5-year-old child to her father solely on the grounds that he was the natural guardian under the law. The Supreme Court of India, on August 28, 2024, strongly disapproved of this decision, stating that it represented a "completely erroneous approach."

Facts of the Case:

- After the mother's death, the child had been living with her maternal relatives.

- The father filed a petition for custody, which the Madhya Pradesh High Court granted, citing his status as the natural guardian.

- The decision did not thoroughly assess the child's welfare or emotional needs but focused on the father's legal rights.

Legal Points Considered by the Supreme Court:

1. Welfare of the Child is Paramount:

   
   The Supreme Court criticized the High Court for failing to consider the child's best interests, stating that custody decisions must be based on the child’s emotional and developmental needs, rather than simply on the father's guardianship rights.

   
   The Court noted that treating a child like "movable property" or focusing solely on legal guardianship is inappropriate.
   

2. Best Interest Principle:

   The judgment reiterated the principle that the child's welfare should always be the primary consideration in custody cases, even if the father is the natural guardian under Indian law. Legal guardianship cannot automatically override the child's welfare.

3. Need for Comprehensive Inquiry:

   
   The Supreme Court emphasized that such custody issues require a detailed inquiry into the child’s best interests and cannot be decided under a simple habeas corpus petition, as used by the father. The case needed to be handled under specific custody laws, such as the Guardians and Wards Act, which focus on a more in-depth analysis of the child's needs.

   
   The Supreme Court's ruling sends a clear message that the best interests of the child should always prevail over legal technicalities regarding guardianship, ensuring that emotional and psychological factors are given due weight in custody matters