Chhattisgarh High Court

Transfer petition disposed of following amicable settlement of matrimonial dispute through court-ordered mediation.

TILOCHANI SAHU vs SANT KUMAR SAHU

Chhattisgarh High CourtJUDGMENT: March 25, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Petitioner-wife filed a transfer petition seeking to transfer Civil Suit No. 58-A/2024 (a divorce proceeding initiated by the Respondent-husband) from the District Court, Sarangarh to the Family Court, Raipur

Source reference: para 1

The marriage was solemnized on 10.04.2022

Source reference: Compromise Deed, para 1

Following marital discord, the husband sought divorce on grounds of desertion and mental cruelty [Compromise Deed, para 2], while the wife initiated proceedings under the Protection of Women from Domestic Violence Act, 2005, in Raipur

Source reference: Compromise Deed, para 3

On 26.02.2026, the High Court referred the matter to its Mediation and Conciliation Centre

Source reference: para 2

On 23.03.2026, the parties executed a compromise deed agreeing to resume their marital life and respect one another

Source reference: para 3; Compromise Deed, para 5
02

Issues

1. Whether the matrimonial suit pending before the District Judge, Sarangarh should be transferred to Raipur

Source reference: para 1

2. Whether the transfer petition can be disposed of based on an amicable settlement reached during court-annexed mediation

Source reference: paras 3, 5
03

Law Applied

The Court applied the principles of alternative dispute resolution (ADR) and the legal validity of mediated settlements in matrimonial litigation.

Source reference: para 5

It recognized that where parties voluntarily resolve their disputes through a compromise deed without coercion or undue influence, the Court may dispose of the litigation in terms of such settlement

Source reference: para 5

The Court ensured the finality of the mediation process by directing that the terms of the compromise deed remain binding on both parties

Source reference: para 6
04

Reasoning

The Court examined the mediation report and the annexed compromise deed dated 23.03.2026, which indicated a total resolution of the dispute

Source reference: paras 3-4

Under the terms of the settlement, the parties agreed to cohabit, and both agreed to withdraw their respective litigations: the wife committed to withdrawing the domestic violence case in Raipur [Compromise Deed, para 6], and the husband committed to withdrawing the divorce suit in Sarangarh [Compromise Deed, para 7].

Source reference: paras 3-4

The Court analyzed the voluntariness of the agreement and satisfied itself that the deed was executed without any coercion or undue influence

Source reference: para 5

By incorporating the compromise deed into the court record, the Court linked the resolution of the transfer petition directly to the parties' mutual agreement to terminate all underlying litigation

Source reference: para 5
05

Holding

The High Court disposed of the transfer petition in terms of the mediation report and compromise deed dated 23.03.2026

The Court held that the compromise deed shall form an integral part of the judicial record and ordered that both parties remain bound by the terms and conditions contained therein

Source reference: paras 5-6

The prayer for transfer was rendered moot by the parties' agreement to withdraw the underlying suits

Source reference: para 5
Chhattisgarh High Court

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TILOCHANI SAHUvsSANT KUMAR SAHU

Chhattisgarh High Court · March 25, 2026

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