The Court was called upon to decide whether, pending trial in a civil suit for injunction filed by the parents‑in‑law, the daughter‑in‑law could be directed to vacate the parents’ self‑owned farmhouse (the matrimonial home since her marriage) despite an existing protection order under the PWDV Act — and, if so, under what safeguards. The order under challenge, passed by a Single Judge, had:

• directed the appellant (daughter‑in‑law) to vacate the suit property within 60 days;
• required the parents‑in‑law to provide fully funded alternate accommodation with a rent cap of ₹2.5 lakh per month and comprehensive ancillary payments; and
• preserved maintenance for the wife and educational expenses for the minor children.

The appellant contended that this amounted to grant of final relief at the interim stage, offended her Section 17 PWDV Act residence right in a shared household, and disregarded the welfare of her minor children. The parents‑in‑law invoked their right to peaceful enjoyment of their property in their old age, especially given Respondent No.2’s Parkinson’s disease and the toxic domestic environment.

The Division Bench dismissed the appeal, affirming the Single Judge’s interim mandatory order. In doing so, it laid down (and reaffirmed, with reference to a recent Division Bench decision in Manju Arora v. Neelam Arora) important clarifications on:

• the nature and limits of the PWDV Act residence right, particularly vis‑à‑vis parents‑in‑law who are exclusive owners and senior citizens;
• when an interim eviction‑like mandatory injunction may be granted; and
• how children’s welfare and the health/dignity of senior citizens are to be weighted in such conflicts.

2. Factual and Procedural Background

2.1 Parties and Relationships

• Appellant: Sonia Mehra, daughter‑in‑law, Defendant No.2 in the original suit.
• Respondent No.3: Her husband, Defendant No.1 before the Single Judge.
• Respondent Nos.1 & 2: Husband’s parents and exclusive owners of House No. A‑20, Ansal Villas, Satbari, Chhatarpur, New Delhi (“suit property”).
• Children: Two minors — a daughter (born 2010) and a son (born 2016).

2.2 Matrimonial Discord and Parallel Proceedings

After marriage in 2009, the couple lived with Respondent Nos.1 & 2 at the suit property, a 3‑acre farmhouse with substantial amenities.

Over time, serious marital discord arose, creating a web of litigation:

1. Divorce and custody proceedings Respondent No.3 filed for divorce under Section 13(1)(i) & (ia) of the Hindu Marriage Act, along with:
   • applications for custody, visitation and
   • a request that the wife be directed to shift to alternate accommodation.
2. Domestic violence complaint and criminal proceedings The appellant lodged a complaint under the PWDV Act and at the CAW Cell, culminating in FIR No. 592/2023 under Sections 498A/406/354/506/509/377/34 IPC.
   On 22.12.2023, she obtained an ex parte interim order under the PWDV Act from the JMFC, Saket, restraining the respondents from dispossessing her from the suit property.
3. Husband moves out On 16.12.2023, the husband (Respondent No.3) left the suit property and shifted, with the children, to a rented flat at Central Park‑II, Gurugram.

2.3 The Civil Suit by Parents‑in‑Law

On 05.01.2024, Respondent Nos.1 & 2 filed CS(OS) 19/2024 before the Delhi High Court seeking:

• a mandatory injunction directing their son and daughter‑in‑law to vacate the suit property; and
• a permanent injunction restraining the daughter‑in‑law from entering the premises.

In parallel, they sought interim directions under Order XXXIX Rules 1 & 2 CPC along similar lines. During the suit:

• The matter was referred to mediation (failed in March 2024).
• A lady police officer and counsellor were deputed to visit the premises and submit confidential reports.
• The counsellor’s report (15.04.2024) described the atmosphere as toxic, with serious acrimony adversely affecting the minor children and the health of Respondent No.2 (who has Parkinson’s disease).

The appellant’s written statement alleged collusion between the parents‑in‑law and her husband and challenged the maintainability of the suit. However, she admitted that acrimony had led to emotional and aggressive conduct, including breaking objects and loud arguments.

2.4 Custody Proceedings and Residence of Children

Separately, custody matters evolved as follows:

• The Family Court initially directed the husband to return the children to the suit property (07.08.2024).
• On appeal (MAT.APP.(F.C.) 255/2024), the Delhi High Court ordered visitation at the suit property (12.09.2024).
• In May 2025, the minor daughter expressed a desire to reside with the appellant; this led to modification of arrangements, and she began residing with the appellant at the suit property.
• Ultimately, on 18.11.2025, MAT.APP.(F.C.) 255/2024 filed by the husband was dismissed, with custody of both minors being granted to the mother.

By the time the impugned interim order in the civil suit was passed, the daughter was already living with the appellant at the suit property, and the son was also directed to be with her.

2.5 The Impugned Single Judge Order (09.09.2025)

The Single Judge, relying on:

• the counsellor’s and police reports,
• medical evidence of Respondent No.2’s deteriorating condition,
• admissions by the parties about intense acrimony,

held that continued co‑residence in the single residential unit was untenable. Key components of the interim order:

• The appellant was directed to vacate the suit property within 60 days.
• Respondent Nos.1 & 2 were directed to:
  • arrange alternate accommodation for the appellant and children with:
    • rent capped at ₹2.50 lakh per month (with 10% increase every six months);
    • security deposit, brokerage, six months’ advance rent;
    • maintenance, electricity and water charges on actuals; and
    • the full cost of shifting.
  • allow the appellant to choose any apartment in Delhi or Gurugram, including the same complex where the husband resided; failing her choice within 30 days, they could select a flat in Central Park‑II, Gurugram.
• If they defaulted in paying rent etc., leading to eviction from the rented accommodation, the appellant would be entitled to return to the suit property.
• They were also restrained from creating third‑party interests in the suit property (status quo on title) pending the suit.
• They undertook to continue paying school fees and educational expenses of the grandchildren.
• The son (Respondent No.3) was recorded as already living separately and was directed not to move back into the suit property without the Court’s permission.

The appellant challenged this order in appeal as an improper grant of final relief at an interim stage, in violation of her PWDV Act rights and the best interests of the children.

3. Summary of the Division Bench Judgment

The Division Bench (Anil Kshetarpal, J. and Harish Vaidyanathan Shankar, J.) dismissed the appeal and upheld the Single Judge’s interim mandatory injunction, with the only modification that the time for compliance would run from 01.01.2026.

In essence, the Court held:

• The parents‑in‑law are undisputed exclusive owners of the suit property and senior citizens; Respondent No.2’s Parkinson’s disease had worsened due to domestic strife.
• The appellant’s Section 17 PWDV Act residence right is protective, not proprietary, and not indefeasible vis‑à‑vis premises exclusively owned by in‑laws, especially where co‑residence has become harmful to them.
• The interim arrangement — fully funded alternate accommodation with a high rental cap, plus ₹3 lakh per month maintenance from the husband and educational expenses borne by the grandparents — adequately safeguards the appellant and children.
• Given the toxic atmosphere, preserving the existing status quo would itself inflict irreparable harm on the senior citizens and the children; the Dorab Cawasji Warden standard for interim mandatory injunctions was satisfied.
• The order does not amount to final adjudication of substantive rights and is reversible (the wife can return to the suit property if the arrangement fails or if the suit is dismissed).
• The welfare of the minor children is in fact better served by removing them from a high‑conflict setting into a stable, comparable residence proximate to their school.
• Allegations of collusion between the husband and his parents are unsupported by evidence and do not undermine the independent proprietary and dignitary rights of the parents‑in‑law.
• In an interlocutory appeal, the appellate court will not substitute its own view if the Single Judge’s view is a plausible and principled exercise of discretion.

Accordingly, the interim directions in paras 42–53 of the Single Judge’s order were reiterated in full, and the suit was left to be tried on its merits, uninfluenced by these prima facie findings.

4. Precedents and Legal Framework

4.1 Protection of Women from Domestic Violence Act, 2005

Section 17 (Right to reside in a shared household):

• Confers on an “aggrieved person” (typically the wife) a right to reside in the shared household, whether or not she has any title or beneficial interest in it.
• Prohibits eviction or exclusion from the shared household save in accordance with a procedure established by law.

Section 19 (Residence orders):

• Empowers the Magistrate to pass a gamut of residence‑related orders, including:
  • restraining dispossession;
  • directing the respondent to remove himself from the shared household; or
  • directing the respondent to secure alternate accommodation (Section 19(1)(f)).

The key interpretive issue has been: does Section 17 entitle the wife to insist on residence in that specific property (e.g. parents‑in‑law’s self‑owned house), or is that right satisfied by suitable alternate accommodation?

4.2 Dorab Cawasji Warden v. Coomi Sorab Warden (1990) 2 SCC 117

This seminal Supreme Court decision sets out the test for granting interim mandatory injunctions (i.e. orders compelling a positive act at an interlocutory stage, such as directing a party to vacate premises).

The Court held that such relief can be granted where:

• the plaintiff’s case is of a high degree of assurance (a strong prima facie case);
• the balance of convenience is clearly in favour of granting the injunction; and
• refusal of relief would cause irreparable injury which cannot be compensated in damages.

The judgment stresses that interim mandatory relief is exceptional, but permissible where maintaining the existing status quo would itself perpetrate injustice.

4.3 Satish Chander Ahuja v. Sneha Ahuja (2021) 1 SCC 414

In Satish Chander Ahuja, the Supreme Court revisited earlier case law (notably S.R. Batra v. Taruna Batra) and gave a more expansive reading to “shared household” under the PWDV Act:

• A “shared household” is not confined to a property in which the husband has a legal or equitable interest; it can include premises belonging to in‑laws if they form part of the matrimonial home.
• A wife’s claim to residence in such a shared household cannot be summarily dismissed; it requires adjudication on evidence.

However, the Supreme Court also emphasized that the wife’s right is a right of residence and protection, not a right of ownership, and must be harmonized with other rights and interests.

4.4 Manju Arora v. Neelam Arora & Anr., 2025:DHC:9456‑DB

A key building block in this judgment is the Division Bench decision in Manju Arora (cited and relied upon in para 18). Manju Arora clarified, in the context of a daughter‑in‑law residing in a property owned by parents‑in‑law, that:

• The Section 17 PWDV Act residence right is:
  • protective (to prevent destitution and domestic violence),
  • not indefeasible or perpetual, and
  • does not amount to an absolute right to remain in that particular premises irrespective of the owners’ rights or their health and dignity.
• Where the premises are exclusively owned by the parents‑in‑law and continued co‑residence is demonstrably detrimental to their health and dignity, courts may:
  • direct the daughter‑in‑law to vacate; but
  • ensure that she is provided with suitable alternate accommodation under Section 19(1)(f) PWDV Act or otherwise.
• The PWDV Act does not override the autonomy and residential rights of senior citizens in their own property.

In Sonia Mehra, the Division Bench expressly applies this ratio, thereby reinforcing it as the governing norm for similar fact situations within the Delhi High Court’s jurisdiction.

5. Court’s Legal Reasoning

5.1 Balancing Competing Rights: Senior Citizen Owners vs. DV Act Residence Right

The Court starts from undisputed premises:

• Respondent Nos.1 & 2 are exclusive owners of the suit property.
• They are senior citizens; Respondent No.2 suffers from Parkinson’s disease with progressive deterioration.
• The appellant has resided there since marriage and would ordinarily claim protection as an “aggrieved person” under the PWDV Act.
• The domestic environment has become toxic — corroborated by:
  • counsellor’s and police reports,
  • medical records, and
  • admissions about breaking objects and loud quarrels.

The core reasoning is that Section 17 PWDV Act gives the wife a right of residence and non‑eviction without due process, but does not confer:

• a title in the property;
• a right to indefinite occupation of premises owned by her in‑laws, irrespective of consequences; or
• a power to override the legitimate rights of senior citizen owners to live peacefully and with dignity.

Applying Manju Arora, the Bench holds that:

• The wife’s residence right is not an entitlement to remain in that particular property if:
  • continued co‑residence causes demonstrable harm to elderly, ailing owners; and
  • adequate alternate accommodation is made available.
• The PWDV Act’s objective of protection is satisfied if the woman is not rendered homeless or destitute, and her living conditions and security are reasonably ensured elsewhere.

Thus, the Court views Section 17 rights as relational and contextual, not absolute, and explicitly prioritizes:

• the health and dignity of the senior citizen owners;
• the welfare of the minor children; and
• the continuity and adequacy of the wife’s living arrangements, over her preference to stay in that specific farmhouse.

5.2 Adequacy of Alternate Accommodation and Safeguards

A central plank of the decision is that the appellant is not being displaced into insecurity. The Court meticulously recites and endorses the Single Judge’s safeguards (paras 42–53 of the Single Judge’s order), which include:

• Alternate accommodation with:
  • rent up to ₹2.50 lakh per month, with 10% bi‑annual increase;
  • security deposit, brokerage, six months’ advance rent paid by the parents‑in‑law;
  • maintenance charges, electricity and water charges on actuals borne by them;
  • cost of shifting paid by them.
• Appellant’s freedom to select any suitable apartment within 30 days, including:
  • the same complex where the husband resides; or
  • any other complex/neighbourhood in Delhi or Gurugram.
  Only if she does not exercise this option can the parents‑in‑law choose an apartment in Central Park‑II, Gurugram.
• Continuation of:
  • ₹3,00,000 per month maintenance from the husband (as admitted in separate proceedings); and
  • school fees and all educational expenses borne by the grandparents.
• A strong fail‑safe clause: if the parents‑in‑law default in rental or related payments resulting in eviction from the rented premises, the appellant is entitled to return to the suit property.
• Status quo on title: the parents‑in‑law cannot create third‑party interests in the property pending the suit, consistent with Section 19(1)(e) PWDV Act.

The Division Bench characterizes this as a fair, proportionate and non‑illusory arrangement, designed to:

• alleviate acute distress of senior citizens living in a corrosive environment; while
• fully preserving the appellant’s residence, maintenance and her children’s stability.

5.3 Is the Interim Order a Final Relief in Disguise?

The appellant argued that:

• An order directing her to vacate at the interim stage virtually grants the final relief sought in the suit (mandatory injunction to vacate).
• Under Dorab Cawasji Warden, interim mandatory injunctions must be rare and cannot “alter” the status quo in substance.

The Court rejects this line of reasoning on two grounds:

1. Nature of status quo and irreparable harm The Court notes that the existing status quo was itself harmful:
   • continued residence of the appellant in the farmhouse was demonstrably aggravating
   • Respondent No.2’s Parkinsonian condition; and
   • the psychological environment of the children.
   Preserving such a status quo would have perpetuated irreparable harm to senior citizens and minors, contrary to equity.
2. Interim, reversible character of the order The Court emphasizes that:
   • the interim order does not determine title or permanent rights in the property;
   • the appellant’s claims under the PWDV Act remain open for adjudication in appropriate forums;
   • if the suit eventually fails, the arrangement can be revisited; and
   • a specific clause allows her to re‑enter the suit property if the alternate accommodation fails due to the respondents’ default.

In this sense, the order is protective and transitory, not dispositive. The Dorab test is satisfied because:

• there is a strong prima facie case in favour of the senior citizens (exclusive ownership, medical deterioration, corroborated toxicity);
• the balance of convenience lies in avoiding further strain on their health, especially when the wife is fully accommodated elsewhere; and
• the irreparable injury lies more on the side of the parents‑in‑law than the daughter‑in‑law in terms of health, dignity and peace.

5.4 Treatment of “Shared Household” and Section 17 PWDV Act

The appellant relied heavily on Satish Chander Ahuja to argue that the suit property was a shared household and that she could not be evicted without a full trial. The Division Bench answers this on two planes:

1. Scope of “shared household” after Ahuja The Bench acknowledges that:
   • Premises owned by in‑laws where the couple resided can indeed be “shared households” for the purposes of the PWDV Act.
   • However, Ahuja does not convert the residence right into an absolute right to remain in the same bricks and mortar irrespective of all other factors.
2. Balancing with senior citizens’ rights and adequacy of alternate accommodation The Court stresses that:
   • Section 17 is satisfied so long as the aggrieved woman:
     • is not thrown on the street;
     • continues to be housed in a dignified and reasonably comparable residential setting; and
     • is not denied the protection of the law against domestic violence.
   • The contention that “comparable” means an exact equivalent farmhouse is rejected as an overstatement of the statute.
   • The PWDV Act does not compel aged parents‑in‑law to perpetually endure a toxic environment in their own home merely to suit the convenience of the daughter‑in‑law when robust alternate arrangements are on offer.

Thus, the judgment harmonizes Satish Chander Ahuja with Manju Arora by treating the residence right as portable and relocatable, so long as the woman’s protection and dignity are practically preserved.

5.5 Feasibility of Separate Floors or “Less Disruptive” Solutions

The appellant argued that:

• the farmhouse had independent floors;
• she could occupy the first floor while the parents‑in‑law remained on the ground floor; and
• this would have minimized interference while preserving her residence right.

The Court rejects this “compartmentalization” approach based on factual assessment:

• The counsellor’s report recorded that:
  • interactions, conflicts, and outbursts were occurring in common areas — driveway, kitchen, passages;
  • physical floor separation did not prevent confrontational contact.
• The Single Judge had found, on the material before him, that the property was functionally a single residential unit with shared access, not separate, self‑contained apartments.
• The very presence of the appellant in the house had become a trigger for conflict and deterioration of the senior citizen’s health.

Accordingly, the Division Bench agrees that lesser intrusive measures, such as restricting use to different floors, would have been illusory and ineffective in resolving the conflict.

5.6 Welfare of Minor Children

Children’s welfare is recognized as “paramount”. The Court notes:

• By judicial orders in custody proceedings, the children, especially the daughter, have been placed with and wish to reside with the mother (appellant).
• Both children attend Pathways School, Gurugram.
• The alternate accommodation is contemplated in Gurugram, aligned geographically with their school.

The appellant’s argument that moving from the ancestral farmhouse to an apartment would:

• downgrade the children’s lifestyle and facilities (gym, pool, large open spaces), and
• therefore be against their best interests,

is addressed by the Court as follows:

• Physical amenities are not the sole measure of child welfare; emotional stability and a non‑toxic environment are crucial.
• A premium complex like Central Park‑II offers good security and modern facilities; the children’s education, commute, and daily routine would not be disrupted.
• The counsellor’s report established that the existing atmosphere in the suit property was psychologically harmful to the children.

Thus, the Court finds that the interim arrangement enhances, rather than undermines, the children’s welfare by removing them from a volatile environment without compromising their educational or material needs.

5.7 Balance of Convenience and Irreparable Harm

On a holistic weighing:

• Respondent Nos.1 & 2
  • are elderly;
  • Respondent No.2’s debilitating illness is worsening under stress;
  • they have a right to enjoy their property peacefully during the “evening of their lives”.
• Appellant
  • retains roof over her head in a good locality;
  • receives substantial maintenance and
  • has her children’s educational expenses borne by the respondents.

Therefore:

• The greater irreparable harm lies with the senior citizens, if forced to continue in a conflict‑ridden co‑residence.
• The appellant’s harm is significantly mitigated and compensated; no deprivation of basic security or dignity is shown.

5.8 Allegations of Collusion

The appellant alleged that the civil suit by the parents‑in‑law was a collusive device orchestrated with the husband to evict her from the matrimonial home. As “evidence”, she relied on:

• timing — the husband left the premises just before the suit was filed; and
• the use of common counsel across proceedings.

The Court finds these allegations unsupported by substantive material:

• mere coincidence of timing or shared counsel does not establish collusion in law;
• the parents‑in‑law’s cause of action is:
  • grounded in their independent proprietary rights; and
  • supported by their consistent complaints about harassment and health deterioration.

Consequently, the allegation of collusion does not undermine the bona fides of the suit or the entitlement to interim protection.

5.9 Appellate Restraint in Interlocutory Matters

Finally, the Division Bench reminds that in an appeal against an interlocutory order:

• The question is not whether the appellate court would have taken a different view, but whether the view taken by the Single Judge is:
  • a possible and reasonable one on the material; and
  • in accordance with settled legal principles.
• Where two views are possible, appellate interference is ordinarily unwarranted.

Given the detailed basis of the Single Judge’s order — documentary evidence, reports, medical records, admissions, and careful structuring of safeguards — the Division Bench finds no perversity or misdirection justifying interference. It accordingly lets the interim arrangement stand during the pendency of CS(OS) 19/2024.

6. Complex Concepts Simplified

6.1 “Shared Household”

A shared household under the PWDV Act is:

• the place where the aggrieved woman lives or has lived in a domestic relationship with the respondent(s);
• it can include property:
  • owned or rented by the husband;
  • owned or rented by the in‑laws, if it functioned as the matrimonial home.

Being a shared household does not mean the wife becomes owner or can never be asked to move if other strong legal interests (e.g. health and property rights of senior citizens) exist and she is offered adequate alternate residence.

6.2 Right of Residence vs. Ownership

• Right of residence: a legal protection to reside and not be summarily evicted; it is about possession and shelter.
• Ownership: a right to control, use, exclude others from, and dispose of property.

The PWDV Act gives an occupational right, not ownership. Courts must balance this against the owners’ rights, especially when they are elderly and infirm.

6.3 Mandatory vs. Prohibitory Injunctions

• Prohibitory injunction: restrains a party from doing something (e.g. “do not dispossess her”).
• Mandatory injunction: compels a party to do something (e.g. “vacate the premises”, “remove a structure”).

At an interim stage, mandatory injunctions are given sparingly because they may resemble final relief. However, they are permissible in exceptional circumstances where:

• the right is very clear (strong prima facie case);
• balance of convenience is one‑sided; and
• without such relief, serious injustice would result.

6.4 “Status Quo”

Courts often “maintain status quo” pending suit, meaning they:

• freeze the existing factual situation to prevent unilateral changes.

But if the “status quo” is itself unjust or harmful (e.g. a violently abusive co‑residence), courts may need to change it to prevent further harm — precisely what happened here.

6.5 Balance of Convenience and Irreparable Harm

• Balance of convenience: Which side would suffer greater hardship if interim relief is granted or refused?
• Irreparable harm: Harm that cannot be adequately compensated by money or reversed later.

In this case:

• For senior citizens: ongoing stress, health deterioration, loss of peace — harms difficult to undo.
• For the appellant: relocation to a fully funded, decent alternate home — inconvenience, but rights and lifestyle broadly protected.

6.6 “Prima Facie” Case

A prima facie case is not final proof; it means that on a preliminary look:

• the claim appears plausible and credible enough to deserve protection until the trial decides otherwise.

7. Impact and Future Significance

7.1 Clarifying the Contours of PWDV Act Residence Rights

This judgment, read with Manju Arora, significantly clarifies in Delhi:

• The wife’s Section 17 PWDV Act right is not an absolute right to remain in the in‑laws’ property forever.
• Court‑ordered alternate accommodation, if adequate and dignified, can legitimately satisfy the residence right, particularly where in‑laws are exclusive owners and senior citizens.
• The PWDV Act is a shield against destitution and abuse, not a weapon to freeze senior citizens’ enjoyment of their property in oppressive circumstances.

This will likely guide:

• Magistrates and Family Courts in fashioning Section 19 residence orders (including alternate accommodation options); and
• Civil Courts when faced with suits by parents‑in‑law against daughters‑in‑law.

7.2 Strengthening Senior Citizens’ Ability to Reclaim Peaceful Enjoyment of Property

Although the Senior Citizens Act, 2007 is not expressly analyzed in the extracted text, this judgment is consistent with the broader judicial trend (e.g. S. Vanitha v. Deputy Commissioner) balancing senior citizens’ rights with PWDV Act protections.

Key takeaways for senior citizens:

• They can sue to protect their right to peaceful residence and property, even against their own children and children‑in‑law.
• Courts will consider their age and health and may direct alternate housing arrangements for the younger generation, rather than compel the elderly to live in a toxic environment.

7.3 Guidance on Interim Mandatory Eviction Orders

The decision confirms that, in appropriate cases, courts can:

• issue interim mandatory injunctions amounting to temporary eviction from a residence;
• especially where:
  • the occupant is not rendered homeless (alternate accommodation is secured); and
  • continued co‑residence threatens health, safety, or dignity of other vulnerable occupants.

This will likely influence how trial courts frame interim orders in high‑conflict domestic disputes, particularly when elderly parties are involved.

7.4 Re‑centering Child Welfare on Emotional Climate

The judgment emphasizes that children’s welfare is not just about:

• the size or luxury of the residence; but about
• the emotional safety and psychological environment of the home.

Courts may increasingly:

• prioritize moving children out of demonstrably toxic or high‑conflict homes, even if the new residence is relatively smaller or less opulent; and
• scrutinize claims that “best interest” requires retention of a particular house when the domestic climate is corrosive.

7.5 Appellate Deference to Structured, Evidence‑Based Interim Orders

The Division Bench’s restraint underscores a broader appellate principle:

• Where a Single Judge has:
  • considered relevant material;
  • crafted a nuanced, conditional and reversible interim order; and
  • balanced competing equities with reasoned analysis,
• an appellate court will be slow to interfere.

This encourages careful, evidence‑backed interim determinations at the trial level, with a realistic expectation that they will be respected on appeal unless clearly perverse.

8. Conclusion: Key Takeaways

• The Delhi High Court affirms that a daughter‑in‑law’s right of residence under Section 17 PWDV Act is:
  • protective but not absolute;
  • subject to balancing with the property, health, and dignity rights of senior citizen parents‑in‑law who own the premises; and
  • can be effectively honoured through suitable alternate accommodation, not necessarily the same matrimonial house.
• Interim mandatory injunctions directing temporary eviction from a matrimonial home are permissible when:
  • there is a strong prima facie case for senior citizens;
  • continued co‑residence is clearly detrimental to their health and to children’s welfare; and
  • the ousted party is fully protected by alternate housing and maintenance.
• Children’s best interests are measured more by the quality of the emotional environment than by the luxury of the home; moving to a stable, adequately comfortable setting near their school can enhance their welfare.
• Allegations of collusion between spouses and in‑laws must be substantiated; mere coordination in litigation strategies does not, by itself, taint a senior citizen’s independent rights.
• Appellate courts will ordinarily defer to well‑reasoned interim orders that carefully balance competing rights and build in safeguards and reversibility.

Sonia Mehra v. Romy Mehra & Ors. thus consolidates and refines the jurisprudence on the delicate balance between protection of women from domestic violence and the autonomy and dignity of senior citizens in their self‑owned homes. It signals that, where robust, dignified alternate arrangements are possible, the law does not trap elderly parents into living indefinitely in a corrosive family environment in the name of matrimonial residence rights.