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Satish Chander Ahuja v. Sneha Ahuja

Civil Appeal · 2020 INSC 599Decided 15 Oct 2020
Civil Appeal No. 2483 of 2020
Justice Ashok Bhushan · Justice R. Subhash Reddy · Justice M.R. Shah

Background

A father-in-law, Satish Chander Ahuja, owned a house in New Delhi where his son and daughter-in-law, Sneha Ahuja, lived after their marriage. After the marriage broke down and the son moved out, the father-in-law sued his daughter-in-law for a mandatory and permanent injunction to make her vacate the property, claiming it was his exclusive self-acquired property. The trial court decreed in his favour, but the Delhi High Court set that aside and sent the matter back for fresh trial, holding that the daughter-in-law's claim to a "shared household" under the Domestic Violence Act needed to be examined. The father-in-law appealed to the Supreme Court.

Decision Breakdown

The Supreme Court used this case to clarify the definition of "shared household" under Section 2(s) of the Protection of Women from Domestic Violence Act, 2005. It held that a shared household is not limited to a house owned or rented by the husband or belonging to his joint family: it can also include a house owned exclusively by the husband's relatives (such as his parents), provided the wife actually lived there in a domestic relationship with some degree of permanency. In doing so, the Court narrowed the earlier, more restrictive view taken in S.R. Batra v. Taruna Batra. However, on the facts of this specific case, the Court agreed with the High Court that the dispute over whether this particular property was a "shared household" needed to be decided on evidence at trial, and therefore dismissed the appeal, upholding the remand to the trial court.

Lesson Learnt

A daughter-in-law's right of residence under the Domestic Violence Act can extend even to a house that is the self-acquired, exclusive property of her in-laws, not just a house owned by her husband, but whether that right actually applies still depends on the specific facts of how and where the couple lived.

Official source (sci.gov.in)View Judgment (PDF)

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