Records bearing on a child’s welfare may be compelled in custody-modification proceedings.

The parties obtained a divorce by mutual consent on 18 April 2017, with an arrangement for shared custody and visitation concerning their minor son.

In December 2025, the husband applied to modify that arrangement, alleging, among other things, that the wife was misusing maintenance deposited into the child’s account and travelling abroad while leaving the child with her parents.

In IA No. 3 of 2026, he sought six categories of documents.

The Family Court rejected Items 1–5 and allowed Item 6, concerning the wife’s rental premises.

The husband challenged the rejection under Article 227.

The High Court’s later correction order clarified that the parties disputed whether the shared-custody arrangement had been working smoothly and corrected other typographical errors; the remaining order was unchanged.

Whether the Family Court’s rejection of the requests for the child’s bank statements and fixed-deposit details was justified, given the allegations that maintenance was being misused.

Whether the wife’s personal bank statements and employment records were necessary to decide the custody-modification application.

Whether the wife’s passport and travel history were relevant to the allegations concerning the child’s care and welfare.

The Court identified no specific statutory provision or precedent as the basis for its decision.

It proceeded on the principle that the child’s welfare and interests are paramount and that the Court, exercising parens patriae jurisdiction, may consider material relevant to those interests.

In assessing the document requests, it distinguished information directly relevant to the allegations and the child’s welfare from private financial information that would not assist in deciding the modification application.

The husband alleged that money deposited into the child’s account was being used for the wife’s personal expenses. The Court therefore considered the child’s account statements and fixed-deposit details relevant to testing that allegation and held that the wife, with whom the child was in shared custody, should produce them.

The Court found the wife’s personal bank statements and employment records unnecessary: the child’s account records could address the alleged diversion of maintenance, and the employment information would not assist in resolving the application on the material before it.

By contrast, the husband had alleged that the wife travelled abroad and left the child with her parents; in the Court’s view, the travel history could bear on the child’s care and welfare. It accordingly found the passport relevant.

The wife was directed to produce within two weeks the child’s HDFC account statements from October 2016, details of fixed deposits created from that account, and her passport showing travel history from October 2017.

The Court left undisturbed the rejection of the wife’s personal bank statements and employment records, as well as the Family Court’s order concerning Item 6.

The connected miscellaneous petition was closed, with no order as to costs.