The dispute in question was between Reji Baby and Subi Mary & Ors. In the given situation, an essential issue arose regarding the consequences of a settlement agreement on the effect of matrimonial disputes where the spouse renounces the claims for monetary compensation and maintenance under a settlement but raises them again through the proceedings under the Protection of Women from Domestic Violence Act, 2005.
The brief facts of the case are that the husband and wife entered into a settlement agreement on 23.07.2016, whereby all monetary claims between them were settled and the wife agreed not to claim maintenance in future. Thereafter, they obtained a decree of divorce by mutual consent on 30.01.2017, and the wife affirmed before the Family Court that she had voluntarily relinquished her maintenance claim without coercion or undue influence. Despite the settlement and divorce, the wife initiated proceedings under the Domestic Violence Act concerning incidents predating the settlement.
The Supreme Court held that pursuing claims already settled amounted to an abuse of the process of law, particularly as the wife had neither challenged the settlement nor the divorce decree. The Supreme Court, relying upon its decision in Dhananjay Rathi v. Ruchika Rathi, reiterated that valid and knowingly executed settlements must be respected and parties cannot reopen claims already settled. However, the Court distinguished the daughter, who was not a party to the settlement agreement, holding that she could not be deemed to have waived her independent right to seek monetary relief from her father. Accordingly, the domestic violence proceedings were set aside while leaving the daughter free to pursue her independent legal remedies.
This judgment is significant for the manner in which it balances the sanctity of voluntary matrimonial settlements with the protection of independent legal rights. The Supreme Court has reaffirmed that valid matrimonial settlements cannot be casually disregarded through subsequent litigation concerning matters already settled, particularly where the validity of the settlement itself is not under challenge. At the same time, the judgment clarifies that such a settlement binds only the parties who entered into it and cannot extinguish the independent rights of third persons, such as an adult child, who neither consented to nor participated in the settlement.