Marital Relationship-Based Property Disputes Fall Within the Exclusive Jurisdiction of Family Courts Regardless of Pecuniary Value

The Plaintiff (wife) and Defendant No. 1 (husband) were married on December 2, 2009

Following marital disputes and allegations of cruelty regarding dowry, the Plaintiff alleged that the Defendants utilized her income to purchase several properties in Delhi in their names without her consent

A Settlement Deed was executed in 2021 for Rs. 2,75,00,000/-, but the Defendants allegedly defaulted after paying only Rs. 10,00,000/-

The Plaintiff filed the current suit for partition, permanent injunction, and appointment of a Local Commissioner

The Defendants filed an application under Order VII Rule 10 of the CPC seeking the return of the plaint, arguing that the High Court lacks jurisdiction as the matter exclusively falls within the domain of the Family Court

1. Whether a suit for partition and injunction regarding properties purchased during a marriage falls within the exclusive jurisdiction of the Family Court under Section 7(1) Explanation (c) of the Family Courts Act, 1984

2. Whether the Delhi High Court, while exercising its Ordinary Original Civil Jurisdiction, is barred from entertaining family-related property disputes when the suit valuation exceeds the High Court's pecuniary threshold (Rs. 2 Crores)

The court primarily applied Section 7 and Section 8 of the Family Courts Act, 1984, which vest exclusive jurisdiction in Family Courts for suits between parties to a marriage regarding property

It relied on the Division Bench ruling in Geeta Anand v. Tanya Arjun (2024), which established the "functional test" to determine if a dispute has an "intrinsic nexus" with a marital relationship

Furthermore, the court applied the precedent from Amina Bharatram v. Sumant Bharatram (2016), which held that "District Court" under the Act includes the High Court exercising original jurisdiction, thereby ousting the High Court's jurisdiction regardless of the suit's pecuniary value

Consequently, the High Court’s Practice Directions dated 23.12.2026 (pursuant to Amina Bharatram) mandate the transfer of such matters to Family Courts

The court determined that the foundation of the Plaintiff's claim was inextricably linked to her marital relationship. The properties were allegedly purchased using her funds by her husband during the subsistence of the marriage, and the disputes arose from alleged dowry-related cruelty

Applying the "direct nexus" test from Geeta Anand, the court found that but for the marital relationship, the dispute would not have arisen

Regarding the pecuniary limit, the court reasoned that the Family Courts Act is a special statute intended forconciliatory adjudication; allowing the High Court to retain jurisdiction based solely on high pecuniary value would defeat the Act's social objectives and create an appellate vacuum, as Section 19 of the Act designates the High Court as the appellate forum for Family Court orders

The application under Order VII Rule 10 of the CPC was allowed, and the plaint was returned to the Plaintiff for filing before the competent Family Court