The Karnataka High Court has ruled that the jurisdiction of a family court cannot be extended to resolve civil suits, particularly those involving property disputes and inheritance claims. Justice K Manmadha Rao, in an order dated April 28, quashed a previous order by a Bengaluru family court that had asserted jurisdiction over a suit challenging the marital status of a woman and her children to facilitate claims over the estate of a deceased man.
Background of the Case
The case originated from a suit filed in 2017 by Parvathamma, wife of late JP Narayana Swamy. She sought a declaration that the petitioner woman was not the legally wedded wife of Narayana Swamy and that her two children were not his. She also sought a permanent injunction restraining them from claiming any rights in the estate. However, Parvathamma died on February 24, 2020, and two of her relatives joined the litigation in her place.
The woman and her two children challenged the family court's order dated February 25, 2020, which held that it had jurisdiction to entertain the suit. They argued that the family court lacked jurisdiction to try a suit pertaining to a property dispute.
High Court's Observations
Justice Manmadha Rao noted that the Family Courts Act is a specialized statute designed to provide a simplified, conciliation-based forum for family-related grievances. He emphasized that extending the family court's jurisdiction to every title suit involving a challenge to a pedigree would dilute its specialized focus and overlap with the settled functions of the civil court under the Specific Relief Act.
The judge also pointed out that since both Parvathamma and Narayana Swamy are deceased, the validity of the marriage of the petitioner woman cannot be examined in such a scenario. The challenge was not aimed at resolving marital friction between spouses but at determining the status of individuals to facilitate claims over the estate, which takes on the character of complex civil litigation best suited for a civil court.
Nuanced Distinction
Justice Rao observed that a nuanced distinction must be drawn between a matrimonial case seeking the preservation or dissolution of a marriage and a suit for declaration of legal character intended to settle rights over an estate. Accordingly, the high court quashed the family court's order, but granted liberty to the two respondents to file a fresh suit before the competent civil court if they have any grievance.
