Irretrievable Breakdown, Section 498A IPC, and Article 142: Anurag Vijaykumar Goel v. State of Maharashtra (2025 INSC 926)

The Supreme Court on Section 498A IPC, Settlement Failures, and Irretrievable Breakdown of Marriage: Anurag Vijaykumar Goel v. State of Maharashtra (2025 INSC 926)

In Anurag Vijaykumar Goel v. State of Maharashtra1, the Supreme Court was once again confronted with the complex intersection of criminal law, matrimonial disputes, and equitable relief under Article 142 of the Constitution. The case arose from a failed marriage that had already traversed multiple fora—criminal courts, family courts, and the High Court—before reaching the apex court. It presented not only the question of whether vague allegations of cruelty under Section 498A of the Indian Penal Code (IPC) could sustain criminal prosecution, but also whether the Court’s plenary powers could be invoked to dissolve a marriage that had become, in the Court’s words, “emotionally dead and beyond salvation.”

The decision, reported as 2025 INSC 926, stands at the crossroads of two streams of jurisprudence: first, the quashing of criminal proceedings under Section 482 of the Code of Criminal Procedure (CrPC) in light of the Bhajan Lal guidelines; and second, the invocation of irretrievable breakdown of marriage as a ground for divorce under Article 142, a principle reaffirmed in Shilpa Sailesh v. Varun Sreenivas

Factual Background

The appellant-husband and the respondent-wife were married on 25 July 2015 according to Hindu rites. Within less than two years, discord arose. By March 2017, quarrels and accusations surfaced, culminating in the husband leaving the matrimonial home on 6 April 2017 to take up work in Faridabad. What followed was a spiral of litigation that is emblematic of modern matrimonial disputes in India.

The wife lodged an FIR in 2018 alleging cruelty and misappropriation of stridhan under Sections 498A and 406 IPC. Parallel proceedings under the Protection of Women from Domestic Violence Act, 2005 were also initiated, as well as a civil suit concerning property and a petition for divorce. In 2022, after years of hostility, the parties entered into a settlement agreement dated 1 September 2022. Under this arrangement, the husband agreed to transfer ownership of a valuable apartment in Mumbai’s Kalpataru Habitat complex to the wife, while both parties would pursue a divorce by mutual consent under Section 13B of the Hindu Marriage Act. The first motion under Section 13B succeeded. However, before the second motion could be heard, the wife withdrew her consent, alleging coercion and fraud.

This volte-face reignited the litigation. Contempt proceedings followed, given that interim directions concerning the flat’s mortgage dues were allegedly not complied with. The High Court declined to quash the criminal proceedings, leaving the husband to approach the Supreme Court by way of special leave.

Legal Issues

The case raised three interrelated issues:

1. Whether the FIR and charge-sheet disclosed a prima facie offence under Section 498A IPC or whether the proceedings were liable to be quashed as an abuse of process.

2. Whether the wife’s withdrawal from the mutual consent divorce vitiated the settlement agreement, and what effect this had on property and financial arrangements between the parties.

3. Whether the marriage had irretrievably broken down, thereby justifying the exercise of the Court’s plenary powers under Article 142 to dissolve the marriage notwithstanding the statutory scheme.

IV. Court’s Analysis

A. On the Allegations under Section 498A IPC

The Court scrutinized the FIR and the charge-sheet with care. It observed that the allegations against the husband were general, unspecific, and reflective of ordinary wear and tear of marital life rather than conduct amounting to “cruelty” within the meaning of Section 498A IPC. The FIR lacked concrete particulars of time, place, or manner of alleged harassment. The Court recalled its oft-repeated caution, articulated most famously in State of Haryana v. Bhajan Lal2, that criminal proceedings which fail to disclose the essential ingredients of an offence must be quashed under Section 482 CrPC to prevent abuse of process.

The judgment also echoed the Court’s concern in Preeti Gupta v. State of Jharkhand4 and Arnesh Kumar v. State of Bihar regarding the misuse of Section 498A IPC. It reiterated that while the provision was enacted as a shield against genuine cruelty, it must not be wielded as a sword to settle personal scores.

B. On the Settlement Agreement and Withdrawal from Consent

The Court acknowledged the wife’s statutory right to withdraw consent before the second motion under Section 13B of the Hindu Marriage Act, as laid down in Sureshta Devi v. Om Prakash. However, it noted that the respondent had fully participated in the earlier settlement—paying off substantial dues to the housing society, receiving interim reliefs, and benefiting from the arrangement—before choosing to resile. Her allegations of coercion, fraud, and misrepresentation were deemed unsubstantiated and tactical.

The Court thus held that while her withdrawal from the second motion prevented statutory dissolution of marriage under Section 13B, her conduct was a relevant factor in moulding equitable relief under Article 142.

C. Irretrievable Breakdown of Marriage and Article 142

The Court devoted significant attention to the doctrine of irretrievable breakdown of marriage, a principle judicially recognized though not statutorily codified. Citing Shilpa Sailesh v. Varun Sreenivasan, the bench reaffirmed that Article 142 empowers the Court to dissolve marriages that are “emotionally dead” and where continuation would only prolong agony.

The Court emphasized that the present marriage, subsisting legally for nearly a decade, had been consumed by litigation for eight years. The parties had initiated multiple criminal and civil proceedings against each other. There was no attempt at reconciliation, and no possibility of the couple resuming cohabitation. In such circumstances, compelling the parties to remain legally bound would be inequitable and contrary to the ends of justice.

D. Equitable Directions

To balance equities, the Court directed:

• The husband must execute a gift deed transferring the Mumbai apartment (A-52, Kalpataru Habitat, with two car parking spaces) to the wife.

• He must clear arrears of maintenance charges amounting to ₹25.9 lakh as of January 2025.

• In return, the wife would have no further claim for permanent alimony or maintenance, given her educational qualifications, prior employment, and possession of the apartment.
  

The Court made it clear that the divorce decree would only take effect upon compliance with these condition

Holding

The Supreme Court allowed the appeal, quashed the FIR and charge-sheet under Sections 498A and 406 IPC, and dissolved the marriage under Article 142 on the ground of irretrievable breakdown. It further directed the husband to transfer the Mumbai apartment and pay outstanding charges as part of the equitable settlement. All pending proceedings between the parties stood terminated.

Significance

The judgment carries considerable doctrinal significance. First, it reaffirms the Bhajan Lal principle that vague, omnibus allegations cannot sustain criminal prosecution under Section 498A IPC. Second, it reinforces the growing body of jurisprudence treating irretrievable breakdown as a valid ground for divorce under Article 142, even though Parliament has yet to formally amend the Hindu Marriage Act. Third, it demonstrates that settlement agreements, even when one party withdraws from statutory divorce proceedings, may still guide equitable relief under Article 142, preventing tactical abuse of process.

By combining criminal quashing jurisprudence with matrimonial equity, the Court continues to chart a pragmatic course—protecting women from genuine cruelty while curbing misuse of penal provisions, and simultaneously ensuring that dead marriages are not kept alive merely as a matter of form.

References

1. Anurag Vijaykumar Goel v. State of Maharashtra & Anr., 2025 INSC 926 (5 August 2025).

2. State of Haryana v. Bhajan Lal, 1992 Supp (1) SCC 335.

3. Shilpa Sailesh v. Varun Sreenivasan, (2023) 14 SCC 231.

4. Preeti Gupta v. State of Jharkhand, (2010) 7 SCC 667.

5. Arnesh Kumar v. State of Bihar, (2014) 8 SCC 273.

6. Sureshta Devi v. Om Prakash, (1991) 2 SCC 25.