Introduction

In the landmark case of Anurag Vijaykumar Goel v. State of Maharashtra & Anr. (Criminal Appeal No. 5277 of 2024, decided on August 5, 2025), the Supreme Court of India examined a prolonged matrimonial dispute involving domestic violence allegations, criminal proceedings, and a failed mutual consent divorce.

The key issues revolved around whether the marriage had irretrievably broken down and the appropriate terms for divorce and alimony. The Court held that alimony received by the wife from her first marriage is irrelevant when deciding alimony for the second marriage.

It further emphasized that, given the complete breakdown of the relationship and prolonged acrimony, the marriage should be dissolved in the present criminal appeal along with an application under Article 142 of the Constitution of India, subject to a fair settlement regarding property and maintenance..

Background of the Case

After a brief second marriage, the couple was embroiled in legal disputes for over eight years, including cases under Section 498A of the Indian Penal Code (IPC) and the Protection of Women from Domestic Violence Act, 2005.

The appellant (husband) and respondent (wife), both previously divorced, married on July 25, 2015. Their marriage lasted just 1 year and 9 months. Due to marital discord, the husband left the matrimonial home in April 2017 and moved to Faridabad to care for his autistic child and aged parents. The wife filed an FIR under Section 498A IPC in April 2018, along with proceedings under the Domestic Violence Act.

The husband initially filed for divorce in Delhi, and both parties entered into a settlement agreement on September 1, 2022, agreeing to mutual consent divorce and transfer of the Mumbai flat (their residence) to the wife. After the first motion, the wife withdrew consent before the second motion, alleging coercion and fraud.

The husband sought quashing of criminal cases and filed contempt proceedings, which were rejected by the High Courts of Delhi and Bombay. He then approached the Supreme Court under Article 142 of the Constitution, seeking divorce on grounds of irretrievable breakdown. The Supreme Court found the marriage emotionally dead and unworkable, held that Section 498A IPC allegations were vague and delayed, invoked Article 142 to grant divorce, quash criminal proceedings, direct the transfer of the Mumbai flat to the wife, and bar both parties from initiating further litigation related to the marriage.

Husband’s Defence & High Court Findings

The husband claimed the wife’s behavior forced him to quit his job and leave home to care for his family. He offered to transfer the apartment as settlement and argued that the wife had already received significant alimony from her first marriage, making her fresh demand for ₹12 crore unreasonable. The wife denied his financial claims and alleged coercion. The High Court refused to dismiss criminal cases and stated that alimony from the first marriage is irrelevant for the second.

Apex Court View

The Supreme Court held that the marriage had irretrievably broken down and granted divorce under Article 142. It clarified that alimony from the wife's first divorce does not influence entitlements in the second marriage. The husband was ordered to transfer the encumbrance-free apartment to the wife and pay all pending maintenance charges. The Court quashed the Section 498A case, describing the allegations as vague and exaggerated, and prohibited any future proceedings related to the marriage.

Conclusion

The Supreme Court reaffirmed that alimony from a previous marriage does not impact entitlement to alimony in a subsequent marriage. The judgment upholds the wife’s right to maintenance and property while protecting the husband from unfounded criminal allegations. This decision promotes fairness by ensuring justice is based solely on the facts and circumstances of the Current Case.