The Orissa High Court has reinforced that disputes concerning the marital status of individuals fall exclusively within the jurisdiction of Family Courts established under the Family Courts Act, 1984. This clarification emerged during the adjudication of a case where the marital status of a deceased individual was contested by two claimants.
Case Background
Following the death of Srimukha Naik on July 25, 2021, a legal dispute arose between the respondent and the appellant, both asserting themselves as his legally wedded wives, thereby claiming entitlement to family pension benefits. The respondent initiated a civil suit seeking a declaration that the appellant was not legally married to the deceased. In response, the appellant contended that she was the first wife, alleging that the respondent had merely an illicit relationship with the deceased. The Civil Judge (Senior Division) of Deogarh dismissed the respondent's suit. However, upon appeal, the District Judge of Deogarh reversed this decision, declaring the respondent as the legally wedded wife and negating the appellant's marital claims.
High Court's Observations
Justice Sashikanta Mishra, presiding over the second appeal, scrutinized the jurisdictional competence of the lower courts in entertaining the suit and subsequent appeal. The High Court highlighted that, following the establishment of Family Courts, any dispute pertaining to marital status should be exclusively adjudicated by these specialized courts, as mandated by Section 7 of the Family Courts Act, 1984. The Court expressed surprise that both the trial and appellate courts proceeded with the case despite lacking proper jurisdiction, emphasizing that such matters are beyond the purview of ordinary civil courts.
Legal Precedents
The High Court's stance aligns with the Supreme Court's interpretation in Balram Yadav v. Fulmaniya Yadav, where it was affirmed that suits seeking declarations regarding the validity of a marriage and the matrimonial status of individuals fall exclusively within the jurisdiction of Family Courts. This precedent underscores that any dispute on matrimonial status must be addressed solely before the Family Court, irrespective of whether the relief sought is affirmative or negative.
Implications of the Judgment
This ruling reiterates the specialized role of Family Courts in adjudicating matrimonial disputes, ensuring that such matters are handled by courts equipped with the requisite expertise. It also serves as a cautionary reminder to litigants and legal practitioners about the importance of approaching the appropriate judicial forum to avoid jurisdictional conflicts and ensure the proper administration of justice.
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