The judgments, such as given in the ‘Anurag Vijaykumar Goel v. State of Maharashtra & ANR’, highlight the necessities of the legislative provisioning and institutional intervention to reduce the delays and ensure the finality of such cases. The verdict serves the dual purpose of ‘protection of the spouse’ and ‘prevention of misuse of criminal law as a tool for adversarial litigation’.
On August 5, 2025, the Supreme Court of India, in a landmark judgment, settled an eight-year-long matrimonial battle in the case of ‘Anurag Vijaykumar Goel v. State of Maharashtra & ANR’. A three-judge bench comprising Chief Justice of India B.R. Gavai, Justice N.V. Anjaria and Justice K. Vinod Chandran exercised its extraordinary powers under Article 142 of the Constitution to dissolve the marriage on grounds of irretrievable breakdown.
The judgment is significant not just for granting divorce, but for doing so despite one spouse withdrawing consent. The court not only ensured fair terms of settlement between the parties but also quashed the false criminal case registered under Section 498A, thus giving finality to prolonged litigation and preventing further multiplicity of proceedings.
The marriage in question was solemnised on July 25, 2015, but disputes began to surface within two years. In March 2017, the wife filed her first complaint, followed by a First Information Report (FIR) under Section 498A, for cruelty, in April 2018, nearly a year after the couple’s separated. In a bid to iron out their issues, the parties had a settlement mediation on September 1, 2022, where they agreed to file a mutual divorce. But the wife withdrew her consent before the second motion was filed, thus halting the case from proceeding.
Thereafter, there was a long battle in the courts involving a series of proceedings like the 498A case, domestic violence case, civil case, and contempt petitions, which went on for nearly eight years before the case was finally decided in the Supreme Court.
In the final judgement, the court reasoned that the FIR under Section 498A was made over a year post-separation. It does not constitute a robust prima facie to constitute the offence as it lacked specific incidents. The allegations were typical ‘marital squabbles blown out of proportion‘, further highlighting that such material did not warrant the continued criminal prosecution. Moreover, the bench concluded that there is ‘no realistic prospect of reconciliation‘, i.e., ‘marriage is irretrievably broken down‘, and to effect fair dissolution, the bench supported the judgment under the purview of Article 142.
Recently, a similar incident took place in Bareilly, where a husband ended his life as his wife filed a false dowry case under Section 489A, without proceeding for any preliminary inquiry or mediation. Such cases highlight the level of efficiency of ‘justice delivery’ to the contesting parties in a timeframe that is longer most times, highlighting the issue of the untimely resolution of cases. Generally, the average time taken by courts to resolve matrimonial cases ranges between 6 to 18 months. However, the process can be extremely delayed to 8-10 years depending on the complexity, backlog, and procedural delays.
Over 5.2 crore cases are pending across all levels of the judiciary in India, of which around 86,000 cases are in the Supreme Court of India itself. The family courts at the district level, of which the matrimonial cases are a constituent, have over 12 lakh cases pending, with the highest in the states of Uttar Pradesh, Kerala, Punjab, and Bihar, as of October 2024, according to the latest Family Court Dashboard of the Department of Justice.
The judgment in Anurag Vijaykumar Goel v. State of Maharashtra & ANR highlights the need for strong laws and institutional reforms. It shows why delays in matrimonial disputes must be reduced and finality ensured. The verdict ends years of harassment and repeated litigation. It sets a benchmark for courts by quashing false criminal proceedings and also stresses protecting vulnerable parties. Most importantly, it reinforces the judiciary’s readiness to deliver practical justice.
Moreover, the judgment has even flagged gaps that need to be addressed:
I. Robust safeguard mechanism before the registration of matrimonial FIRs: A preliminary inquiry by the police officers before the registration of FIR under section 498A.
II. Restrengthening the infrastructure of the family courts: Enhancing the justice delivery setup of the family court by expanding its existing resources and relying on strict timelines to avoid delays in the judgments.
III. Alternative Dispute Resolution (ADR): Adherence to the process of mediation and reconciliation before contested litigation.
IV. Dashboard on Matrimonial Cases: A dedicated data-driven dashboard displaying the state and UT-wise number of matrimonial cases in these sections: i. registered, ii. resolved, iii. pending, and iv. duration/age of the cases (0-1, 2-3, 4-5, etc.), to resolve the backlogs in the court.
V. Penalties against false complaints: By introducing strict penalties against false registered complaints, it may ensure the protection of the authentic complaint.
From a policy lens, such judgment serves the dual purpose of: ‘protection of the spouse’ and ‘prevention of misuse of criminal law as a tool for adversarial litigation‘. A smooth coordination among the institutions such as the Supreme Court of India, High Courts, Legislature (both the Parliament and the State Legislature, subject to the cases), Ministry of Justice, and Police, and systematic deployment of instruments such as judicial orders/judgments, laws and amendments, revising standard operating procedures (SOP), legal aid, awareness drives, etc. can bring positive reforms in the society. Thus, the matrimonial cases should be seen through the prism of legality and sociality to ensure justice.
(Edited by Sneha Yadav)
(Anshal Telang is an intern with TheRise.co.in)
References
Justice Clock, Supreme Court of India.
https://vjc.sci.gov.in/public/AGEWISE_PENDENCY_LISTED_TODAY.php
National Judicial Data Grid, Government of India.
Bajaj, H. How Long Does a Case Take in Indian Courts?[Complete Guide 2025]. Legal Crusader. https://thelegalcrusader.in/how-long-does-a-case-take-in-indian-courts/