Introduction:

The Karnataka High Court, in a significant ruling, held that any suit concerning the declaration of a person’s matrimonial status falls within the jurisdiction of the Family Court under Section 7 of the Family Courts Act, 1984. The decision came in an appeal filed by Arjun Ranappa Hatgundi, challenging the Family Court’s order that had returned his plaint seeking a declaration that the respondents were not his wife and children. A division bench comprising Justice S Sunil Dutt Yadav and Justice Rajesh Rai K ruled that such suits are maintainable before the Family Court, thereby setting aside the previous ruling. The judgment reaffirmed the settled position of law that disputes regarding the marital status of individuals—whether affirmative or negative—must be adjudicated by the Family Court.

Arguments of Both Sides:

The appellant, Arjun Ranappa Hatgundi, contended that defendant No.1, Sushilabai, had previously married one Bhagavantharaya Kalshetty, and defendants Nos.2 and 3 were children born from that marriage. Subsequently, the marriage between Sushilabai and Bhagavantharaya was dissolved by a decree of consent. However, Sushilabai later claimed that she had married the plaintiff on October 10, 1987 and that defendants Nos.2 and 3 were born from this alleged marriage. The appellant sought a declaration from the Family Court that the respondents were not his wife and children. The Family Court, relying on the precedent set in Bhuvaneshwari vs. Revappa @ Ranisiddaramappa Kolli (2012), held that a negative declaration was impermissible and returned the plaint on the ground of lack of jurisdiction. The appellant challenged this decision before the Karnataka High Court, asserting that the Family Court misinterpreted the scope of Section 7 of the Family Courts Act.

On the other hand, the respondents, represented by Advocate B.K. Hiremath argued that the Family Court had rightly declined jurisdiction as the relief sought was not like a matrimonial dispute but a declaratory relief. They relied on past judgments to support their contention that negative declarations were beyond the scope of the Family Court’s jurisdiction. However, they failed to counter the argument that the suit fundamentally pertained to the plaintiff’s marital status, which was squarely within the purview of the Family Court.

Court’s Judgment:

The Karnataka High Court, after examining the pleadings and legal provisions, ruled in favour of the appellant. The bench observed that the prayers in the plaint pertained to the legal matrimonial status of the plaintiff and defendant No.1. Referring to Explanation (b) to Section 7 of the Family Courts Act, the Court emphasized that any suit relating to a person’s matrimonial status falls under the Family Court’s jurisdiction. The bench also relied on the Supreme Court’s ruling in Balram Yadav vs. Fulmaniya Yadav (Civil Appeal No. 4500/2016), which held that disputes concerning a person’s matrimonial status—whether seeking affirmative or negative relief—must be adjudicated by the Family Court. The Court found that the Family Court erred in holding that it lacked jurisdiction and set aside its order. The appeal was accordingly allowed, reinforcing the principle that any suit determining the existence or non-existence of a marital relationship falls within the exclusive jurisdiction of the Family court.