Supreme Court Dissolves Marriage on Grounds of Irretrievable Breakdown: R. Annamalai vs. Lalitha Subanam (2025)

Date of the Judgment: April 16, 2025

Citation: 2025 INSC 513

Judges: Sanjiv Khanna, CJI, and Sanjay Kumar, J.

Can a marriage be dissolved if it has irretrievably broken down, even if neither party is at fault? The Supreme Court of India addressed this critical question in the case of R. Annamalai vs. Lalitha Subanam. The court, exercising its powers under Article 142 of the Constitution of India, dissolved the marriage, emphasizing the lack of emotional connection between the parties. The judgment was delivered by a bench comprising Justice Sanjiv Khanna and Justice Sanjay Kumar.

Case Background

R. Annamalai and Lalitha Subanam entered into matrimony on February 14, 2000. Coincidentally, Annamalai’s sister and Subanam’s brother were married on the same day. Unfortunately, due to various reasons, Lalitha Subanam began living separately in 2006. This separation led to legal proceedings, with R. Annamalai initially filing a petition under Section 9 and later under Section 13 of the Hindu Marriage Act, 1955. However, these petitions were eventually withdrawn.

It also came to light that disputes arose between Annamalai’s sister and Subanam’s brother, resulting in litigation between them. However, the Supreme Court was informed that they are currently living together. Annamalai and Subanam also attempted to reconcile and lived together for a period after their initial separation but eventually separated again and were not residing together at the time of the judgment.

Timeline

Course of Proceedings

In 2012, R. Annamalai initiated divorce proceedings by filing H.M.O.P. No. 361/2012 before the Family Court, Madurai. The Family Court granted a decree of divorce on June 24, 2015. Aggrieved by this decision, Lalitha Subanam appealed. The appellate court allowed the appeal through a judgment dated April 1, 2019, thereby setting aside the decree of divorce granted by the Family Court.

Legal Framework

This judgment primarily involves the invocation of Article 142 of the Constitution of India, which empowers the Supreme Court to pass orders necessary for doing complete justice in any cause or matter pending before it. The original divorce petition was filed under Section 13 of the Hindu Marriage Act, 1955, which outlines the grounds for divorce.

• Article 142 of the Constitution of India: This article grants the Supreme Court unique powers to ensure justice is served fully and effectively.
• Section 13 of the Hindu Marriage Act, 1955:  Deals with divorce and specifies the grounds on which a marriage can be dissolved.

Arguments

The judgment does not explicitly detail the arguments presented by both sides. However, it can be inferred that the appellant, R. Annamalai, argued for the dissolution of the marriage based on the grounds presented in his divorce petition. Conversely, the respondent, Lalitha Subanam, likely contested the divorce, leading to the initial decree being set aside by the appellate court.

Issues Framed by the Supreme Court

1. Whether the marriage between the appellant and the respondent should be dissolved on the ground of irretrievable breakdown, considering their prolonged separation and lack of emotional connection.

Treatment of the Issue by the Court

Authorities

The judgment does not explicitly cite specific cases or legal provisions beyond Article 142 of the Constitution of India and Section 13 of the Hindu Marriage Act, 1955. However, the invocation of Article 142 suggests reliance on precedents where the Supreme Court has used this power to dissolve marriages on the ground of irretrievable breakdown.

Judgment

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the following factors:

• The prolonged separation of the parties.
• The evident lack of emotional connection between R. Annamalai and Lalitha Subanam.
• The failure of mediation attempts to reconcile the parties.

Key Takeaways

• The Supreme Court can dissolve a marriage under Article 142 if it concludes that the marriage has irretrievably broken down.
• Prolonged separation and lack of emotional connection are key factors in determining irretrievable breakdown.
• This judgment reinforces the court’s willingness to prioritize the well-being of the parties involved when a marriage is beyond repair.

Directions

The appellant, R. Annamalai, was directed to pay ₹25,00,000 (Rupees twenty-five lakhs only) to the respondent, Lalitha Subanam, as a settlement. This amount is to be deposited before the Family Court, Madurai, within 8 weeks from the date of the order. Failure to deposit the amount within the specified time will result in an interest of 7% per annum, compounded annually, from the date of the order until the payment is made.

Development of Law

The ratio decidendi of this case is that the Supreme Court, in exercising its powers under Article 142 of the Constitution of India, can dissolve a marriage on the ground of irretrievable breakdown, especially when there is prolonged separation and a lack of emotional connection between the parties. This reinforces the court’s role in ensuring complete justice and prioritizing the well-being of the individuals involved.

Conclusion

In R. Annamalai vs. Lalitha Subanam, the Supreme Court of India dissolved the marriage between the parties, citing irretrievable breakdown as the primary reason. Exercising its powers under Article 142 of the Constitution, the Court emphasized the prolonged separation and lack of emotional connection between the parties. The appellant was directed to pay ₹25,00,000 to the respondent as a final settlement, ensuring a just resolution in light of the circumstances.