A) ABSTRACT / HEADNOTE

The judgment in Satish Chander Ahuja v. Sneha Ahuja marks a seminal shift in the judicial understanding of shared household under the Protection of Women from Domestic Violence Act, 2005. The Supreme Court undertook an exhaustive interpretative exercise of Sections 2(s), 17, 19, and 26 of the Act while examining the maintainability of a civil suit for injunction filed by a father-in-law against his daughter-in-law. The controversy arose in the backdrop of matrimonial discord where the daughter-in-law asserted a statutory right of residence in the suit property by invoking the DV Act, while the father-in-law claimed exclusive ownership and sought her eviction through civil proceedings.

The Court decisively overruled the restrictive interpretation laid down in S.R. Batra v. Taruna Batra, holding that the definition of shared household is exhaustive yet purposive, and not confined only to properties owned or rented by the husband. The judgment clarifies that the pendency of proceedings under the DV Act does not bar civil proceedings concerning possession or injunction, and both remedies may operate concurrently under Section 26. At the same time, the Court emphasized that the right of residence under Section 17 is not indefeasible and must be balanced against the rights of aged parents.

The ruling harmonizes women’s statutory protection with civil property rights, affirms procedural fairness, and establishes that claims under the DV Act must be pleaded and proved even in civil proceedings. The judgment stands as a doctrinal correction and a guiding precedent on domestic violence jurisprudence and inter-se family property disputes.

Keywords: Shared Household, Domestic Violence Act, Right of Residence, Civil Suit Maintainability, S.R. Batra Overruled

B) CASE DETAILS

C) INTRODUCTION AND BACKGROUND OF JUDGMENT

The judgment emerges from a prolonged familial and matrimonial conflict that raised complex questions concerning women’s right to residence and the intersection of civil property law with statutory protections under the Protection of Women from Domestic Violence Act, 2005. The dispute reflects a recurring socio-legal tension between aged parents-in-law asserting ownership rights and daughters-in-law invoking protective legislation for residence security.

Prior judicial interpretation, particularly S.R. Batra v. Taruna Batra, had constrained the scope of shared household to properties owned or rented by the husband. This interpretation, though widely applied, was increasingly criticized for diluting the legislative intent of the DV Act. The present case offered the Supreme Court an opportunity to revisit this position while also clarifying procedural overlaps between civil courts and Magistrate courts exercising jurisdiction under the DV Act.

The background is also significant for its engagement with Section 26 of the DV Act, which enables aggrieved women to seek reliefs available under the Act in civil proceedings. The Court was thus required to harmonize two parallel adjudicatory regimes without allowing one to eclipse the other.

D) FACTS OF THE CASE

The appellant, Satish Chander Ahuja, purchased the suit property in 1983 and later permitted his son and daughter-in-law, Sneha Ahuja, to reside on the first floor after their marriage in 1995. Over time, serious matrimonial discord arose, leading to the husband filing a divorce petition under Section 13 of the Hindu Marriage Act, 1955. Subsequently, the daughter-in-law initiated proceedings under Section 12 of the DV Act, alleging emotional and mental abuse by her husband and in-laws.

An interim protection order was passed restraining dispossession without due process. Thereafter, the father-in-law instituted a civil suit seeking mandatory and permanent injunction to evict the daughter-in-law, asserting his exclusive ownership and alleging harassment. The Trial Court decreed the suit under Order XII Rule 6 CPC on alleged admissions. This decree was set aside by the Delhi High Court, which remanded the matter for fresh adjudication, emphasizing the need to consider statutory residence rights under the DV Act.

Aggrieved by the remand order, the father-in-law approached the Supreme Court.

E) LEGAL ISSUES RAISED

i. Whether the suit property constituted a shared household under Section 2(s) of the DV Act?
ii. Whether pendency of proceedings under the DV Act bars civil suits for eviction or injunction?
iii. Whether the right of residence under Section 17 is absolute or subject to legal process?
iv. Whether S.R. Batra v. Taruna Batra laid down correct law?
v. Whether a decree could be passed under Order XII Rule 6 CPC on alleged admissions?

F) PETITIONER / APPELLANT’S ARGUMENTS

The counsels for the appellant submitted that the suit property was his self-acquired property and never constituted a shared household. It was argued that the daughter-in-law was merely a permissive occupant and could not claim residence against the father-in-law. Heavy reliance was placed on S.R. Batra v. Taruna Batra, asserting that residence rights are limited to property owned or rented by the husband.

It was further contended that the DV Act does not confer proprietary rights and that alternative accommodation, if any, could only be claimed from the husband. The Trial Court’s decree under Order XII Rule 6 CPC was defended as valid on the basis of admissions.

G) RESPONDENT’S ARGUMENTS

The counsels for the respondent argued that the definition of shared household under Section 2(s) is wide and does not require ownership by the husband. It was emphasized that residence in a domestic relationship is the determinative factor. The restrictive interpretation in S.R. Batra was challenged as contrary to legislative intent.

Reliance was placed on Section 26, asserting that civil courts are competent to grant residence-related reliefs. It was also argued that disputed questions of fact barred summary decree under Order XII Rule 6 CPC.

H) JUDGMENT 

The Supreme Court dismissed the appeal and upheld the High Court’s remand. The Court held that the definition of shared household is exhaustive yet purposive and clarified that the use of the words “means and includes” indicates legislative intent to comprehensively define the term. The Court categorically overruled S.R. Batra v. Taruna Batra, declaring it not good law.

The Court held that pendency of DV proceedings does not bar civil proceedings and that civil courts must adjudicate residence claims under Section 26. It was further held that the right under Section 17 is not indefeasible and eviction is permissible “in accordance with procedure established by law”. The power under Order XII Rule 6 CPC was held to be discretionary and wrongly exercised in the present case.

a. RATIO DECIDENDI

The ratio of the judgment lies in its authoritative interpretation of Section 2(s) and Section 17 of the DV Act. The Court held that a shared household includes any household where the aggrieved woman lived in a domestic relationship with the respondent, irrespective of ownership. The right of residence is a statutory right but subject to lawful eviction through competent courts.

b. OBITER DICTA

The Court observed that while protecting women from domestic violence, courts must also be sensitive to the rights of aged parents-in-law. The need for balancing competing rights was emphasized, particularly in cases involving senior citizens.

c. GUIDELINES

i. Civil courts must adjudicate DV-based residence claims when raised under Section 26.
ii. Right of residence is not absolute and may be regulated by due process.
iii. Summary decrees under Order XII Rule 6 CPC must not be passed where disputed facts exist.
iv. Findings in DV proceedings are relevant but not conclusive in civil suits.

I) CONCLUSION & COMMENTS

The judgment stands as a corrective to an overly restrictive precedent and realigns the law with the protective purpose of the DV Act. By overruling S.R. Batra, the Court restored substantive content to the concept of shared household. At the same time, it preserved the sanctity of property rights by recognizing lawful eviction procedures.

The decision advances gender justice while reinforcing procedural fairness. It offers a nuanced balance between statutory protection and civil adjudication, making it a cornerstone ruling for family and property law jurisprudence in India.

J) REFERENCES

a. Important Cases Referred

• S.R. Batra v. Taruna Batra, [2006] 10 Suppl. SCR 1206 (Overruled)

• Hiral P. Harsora v. Kusum Narottamdas Harsora, [2016] 9 SCR 515

• Shanti Kumar Panda v. Shakuntala Devi, [2003] 5 Suppl. SCR 98

b. Important Statutes Referred

• Protection of Women from Domestic Violence Act, 2005

• Code of Civil Procedure, 1908

• Hindu Marriage Act, 1955