Reasserting Statutory Discipline in Family Courts and Rejecting Non‑Existent Grounds of Divorce: A Commentary on Suman Sankar Bhunia v. Debarati Bhunia Chakraborty, 2025 DHC 10461‑DB

I. Introduction

The Division Bench of the Delhi High Court in Suman Sankar Bhunia v. Debarati Bhunia Chakraborty (2025 DHC 10461‑DB) delivers a sharp and far‑reaching message on three fronts:

the strict separation between the Hindu Marriage Act, 1955 (“HMA”) and the Special Marriage Act, 1954 (“SMA”);
the impermissibility of courts relying on non‑existent statutory provisions or un‑notified proposals (such as “Section 28A” of SMA or irretrievable breakdown as a codified ground of divorce); and
the need for procedural fairness and evidence‑based adjudication in matrimonial disputes.

Beyond setting aside a decree of divorce granted by the Family Court, Patiala House Courts, the Bench (Anil Kshetarpal, J. and Harish Vaidyanathan Shankar, J.) directs the concerned Family Court Judge to undergo refresher training in matrimonial law. That direction itself underscores the seriousness with which the High Court views the underlying procedural and substantive lapses.

Parties and Core Dispute

Appellant-Husband: Suman Sankar Bhunia
Respondent-Wife: Debarati Bhunia Chakraborty

The parties are undisputedly married, having lived together for several years and having two children. However, they differ on:

the date and form of marriage: the husband asserts a civil marriage under the SMA on 26.09.2011, evidenced by a certificate under Section 13 SMA, followed by a social ceremony on 11.12.2011; the wife asserts a Hindu marriage according to rites on 11.12.2011;
the marital conduct, with mutual allegations of cruelty, desertion and multiple cross‑litigations in criminal, guardianship, domestic violence and maintenance proceedings; and
the applicable law and the manner in which the Family Court granted divorce.

The central legal issue in the appeal is whether a divorce petition filed under Section 13(1)(ia) HMA can be adjudicated and decreed by importing the provisions of the SMA and, more starkly, a non‑existent Section 28A SMA allegedly providing for divorce on irretrievable breakdown of marriage.

II. Summary of the Judgment

The Delhi High Court holds:

Impugned decree unsustainable: The divorce decree granted by the Family Court (HMA No. 93/2023) is set aside. The judgment is vitiated because:
- the Family Court conflated the HMA and SMA, treating them as interchangeable, despite their distinct schemes; and
- it relied on a non‑existent Section 28A of the SMA and an un‑notified legislative proposal on irretrievable breakdown of marriage.
Violation of natural justice and procedure: The Family Court:
- closed the wife’s right to lead evidence on the very first date fixed for her cross‑examination;
- proceeded to decide the petition without any oral evidence from either side; and
- still recorded findings of cruelty based solely on pleadings and assumptions.
The High Court holds this to be manifestly unfair and contrary to settled principles governing matrimonial trials.
De novo adjudication ordered: The matter is remanded to the Principal Judge, Family Court, Patiala House Courts, for fresh adjudication from the beginning, with liberty to both sides to lead oral and documentary evidence. Even the question of maintainability of an HMA petition in respect of an SMA marriage is left open for decision at the remand stage.
Strong censure of the Family Court’s approach: The Bench:
- expresses “strong disapproval” of the manner in which the Family Court Judge has repeatedly mixed distinct matrimonial statutes and used the procedural flexibility of the Family Courts Act, 1984 (“FC Act”) to side‑step substantive conditions under the HMA;
- notes a pattern of similar conduct in other appeals decided by this Bench (e.g., Upinder Kaur Malhotra, Lovely Sharma, Shweta Puri, Smita Jina, Shraddha Gupta); and
- condemns the reliance on “Section 28A SMA” and characterisation of SMA marriages as not being a “holy union”.
Direction for judicial training: The concerned Family Court Judge, Sh. Harish Kumar, is directed to undergo an “appropriate and comprehensive refresher training program in Matrimonial Laws” at the Delhi Judicial Academy before adjudicating further matrimonial matters.

III. Factual and Procedural Background

A. Relationship and Early Disputes

The marriage and subsequent breakdown can be summarised as follows:

Marriage: Parties are agreed that they are married, but dispute:
- Husband’s case: SMA registration on 26.09.2011 before the Marriage Officer, Barasat, followed by social ceremony on 11.12.2011 and a reception on 15.12.2011.
- Wife’s case: Hindu marriage on 11.12.2011 according to Hindu rites.
Breakdown: On 04.09.2018, the wife left the matrimonial home. Competing narratives emerge:
- Husband: Wife left saying she was going to work, then sent an SMS stating she was going to her parental home at Siliguri, leaving the minor son behind; on 09.09.2018, she and her family allegedly removed the child from his paternal home without court orders.
- Wife: Alleges sustained physical, verbal and mental cruelty; claims that on night of 03.09.2018, the husband accused her of an extra‑marital affair and assaulted her while she was four months pregnant, compelling her to leave on 04.09.2018 to protect herself and the foetus. She states that she returned with police and her relatives on 09.09.2018 to recover the minor son and thereafter lodged FIRs under Sections 498A/506 IPC and provisions of the DV Act.

B. Proliferation of Litigation

The parties soon became embroiled in multiple cross‑proceedings across jurisdictions:

By the husband:
- Guardianship proceedings under the Guardians and Wards Act, 1890 (GWA);
- Proceedings before the Calcutta High Court challenging removal of the child.
By the wife:
- FIR No. 04/2019 under Sections 498A/506 IPC and Sections 3/4 of the Dowry Prohibition Act;
- Complaints at Siliguri:
  - CR Case No. 202/2019 (CIS No. 10911/2019) under Sections 406/120B/34 IPC;
  - Criminal Misc. Case No. 31/2019 under the DV Act;
  - Maintenance case M.R. 939/2019 under Section 125 CrPC.
- Transfer Petitions (Civil and Criminal) before the Supreme Court seeking transfer of guardianship and criminal matters to Jodhpur, later amended to seek transfer to Delhi.

By a series of transfer orders, the Supreme Court ultimately consolidated several proceedings in Delhi, including guardianship and maintenance matters at the Family Courts, Patiala House.

C. The Divorce Petition and Transfer to Delhi

On 08.10.2021, the wife filed Matrimonial Suit No. 410/2021 at Siliguri, seeking divorce on grounds of cruelty under Section 13(1)(ia) HMA.
Issues were framed and the wife was partly cross‑examined there.
The husband then sought, via Transfer Petitions of 2022, to move the Delhi proceedings back to Siliguri; the Supreme Court, instead, directed transfer of the divorce petition from Siliguri to the Family Court, Patiala House, New Delhi, to ensure consistency and expedition.

D. Proceedings Before the Family Court, Patiala House

The High Court sets out a concise but damning chronology demonstrating how the trial went off course:

Date	Event
07.12.2022	Supreme Court orders transfer of the divorce petition from Siliguri to Delhi.
24.01.2023	First listing before Family Court, Patiala House; procedural directions.
28.02.2023	Husband files application under Order VII Rule 11 CPC, arguing HMA inapplicable because marriage was under SMA.
18.11.2023	Order VII Rule 11 application dismissed; fresh issues framed; wife directed to file evidence affidavit.
18.01.2024	On the first date fixed for cross‑examination of the wife, she is absent; the court closes her right to lead evidence without granting another opportunity. Matter posted for husband’s evidence.
27.02.2024	Husband elects not to lead evidence so long as the wife’s evidence is closed, but reserves liberty to lead evidence if she is given a future opportunity. Court closes his evidence as well. Case posted for final arguments.
02.03.2024	Final arguments heard; judgment reserved.
28.03.2024	Impugned Judgment delivered, dissolving marriage on grounds of cruelty, with reliance on SMA and a supposed Section 28A (irretrievable breakdown).

In parallel, the wife challenged the 18.01.2024 order (closing her evidence) in CM(M) 1862/2024 before the Delhi High Court. That petition was withdrawn after the divorce judgment, with liberty to raise all contentions before the appropriate forum—preserving her grievance about procedural unfairness.

IV. Precedents and Authorities Cited in the Judgment

A. On the “Holy Union” and Sacramental Nature of Hindu Marriage

The Family Court had made sweeping observations that Hindu marriages are “holy, unbreakable for seven births” but SMA marriages “cannot be termed as holy union” as they permit inter‑religious marriages and some religions treat marriage as a civil contract. The High Court firmly rejects this characterisation and draws on several Supreme Court decisions to clarify why Hindu marriage is treated as a sacrament:

Swarjya Lakshmi v. Dr. G.G. Padma Rao, (1974) 1 SCC 58
The Supreme Court described Hindu marriage as a sacrament facilitating the performance of religious duties. The High Court quotes this to show that the “holiness” arises from religious and ritual significance, not from metaphysical notions of indissolubility over “seven births”.
Anuradha Samir Vennangot v. Mohandas Samir Vennangot, (2015) 16 SCC 596
The Supreme Court noted that in a Hindu marriage, the wife is regarded as taking a “new birth” in the husband’s household, her status being transformed. The High Court invokes this to underline the unique social and spiritual character of Hindu marriage, without tying it to an unbreakable life‑long or multi‑life bond.
Beni Bai v. Raghubir Prasad (citation not fully reproduced in the judgment)
The judgment is cited for the proposition that through marriage the wife becomes part and parcel of her husband’s household and person, again reflecting the sacramental nature.
Raghubar Singh v. Gulab Singh, (1998) 6 SCC 314
The Supreme Court reiterates that a Hindu wife is “ardhangani” (half of the husband), emphasising unity of personhood in the marital bond.
Velamuri Venkata Sivaprasad v. Kothuri Venkateswarlu, (2000) 2 SCC 139
The Court emphasised the centrality of homam (fire oblation) and saptapadi (seven steps before the sacred fire) as core rituals conferring validity and sacredness on a Hindu marriage, pursuant to Section 7 HMA.

These authorities are utilized not to valorize Hindu marriage over others, but to correct the Family Court’s flawed inference that because HMA provides for divorce, the “holy union” is somehow diluted, or that SMA marriages are intrinsically less holy or dignified.

B. On Irretrievable Breakdown and Cruelty – Rakesh Raman v. Kavita

The Family Court relied heavily on Rakesh Raman v. Kavita, 2023 (17) SCC 433, wherein the Supreme Court considered prolonged separation, multiple litigations and total loss of marital consortium, and treated such circumstances as relevant to assessing cruelty and breakdown of marriage.

However, the High Court points out a crucial distinction:

In Rakesh Raman, the Supreme Court had the benefit of a full evidentiary record before arriving at its findings.
In the present case, the Family Court drew similar inferences of mutual cruelty and irretrievable breakdown without recording any evidence from either side.

Thus, while Rakesh Raman may support the doctrinal proposition that prolonged acrimonious separation can constitute cruelty, it does not authorise a trial court to:

bypass evidence; or
treat irretrievable breakdown as a separate statutory ground of divorce, especially when the legislature has not yet codified it and when subordinate courts lack the Article 142 powers vested in the Supreme Court.

C. Delhi High Court Appeals Illustrating a Pattern

The Division Bench refers to several other appeals that had come before it involving the same Family Court Judge, to demonstrate a broader pattern:

Upinder Kaur Malhotra v. Capt. Teghjeet Singh Malhotra & Anr., MAT.APP.(F.C.) 136/2025
Lovely Sharma v. Manissh Jaisani, MAT.APP.(F.C.) 166/2025
Shweta Puri v. Sanjay Puri & Anr., MAT.APP.(F.C.) 321/2024
Smita Jina v. Amit Kumar Jina, MAT.APP.(F.C.) 167/2025
Shraddha Gupta v. Sumit Jain, MAT.APP.(F.C.) 330/2023

In these matters, the same Judge allegedly:

granted decrees of divorce suo motu or under Section 13B HMA (mutual consent) without verifying statutory pre‑conditions (e.g., period of separation, joint petition, free consent); and
invoked the flexible, conciliatory ethos of the FC Act to override or dilute substantive statutory safeguards under the HMA.

While these rulings are not analysed in detail in the present judgment, they underpin the High Court’s conclusion that the errors in the instant case are not isolated but symptomatic.

V. The Court’s Legal Reasoning

1. Distinct Statutory Schemes of HMA and SMA

The High Court is categorical that the HMA and SMA are distinct, self‑contained codes with different conceptual foundations:

HMA:
- Applies to Hindus, Buddhists, Jains and Sikhs (Section 2 HMA);
- Envisions marriage as solemnised through religious rites and customs (Section 7 HMA), with validity often hinging on rituals such as saptapadi (seven steps);
- Provides exhaustive grounds for divorce under Section 13, including adultery, cruelty, desertion, conversion, mental disorder, venereal disease, renunciation, and presumption of death, along with wife‑specific grounds under Section 13(2).
SMA:
- Is a secular statute, not tied to any religion, governing marriages solemnised by a Marriage Officer;
- Validity is derived from statutory formalities and registration, not from religious ceremonies;
- Contains its own divorce provision, Section 27, with grounds similar but not identical to Section 13 HMA (e.g., imprisonment for seven years as an express ground; certain wife‑specific grounds).

The Court underscores that the choice of law (HMA vs SMA) is not a mere technicality: it affects:

who can marry under the statute;
how the marriage is solemnised and proved;
what grounds for divorce are available; and
what procedural routes can be followed for reliefs like judicial separation, restitution of conjugal rights, etc.

Therefore:

“A Judicial Officer cannot amalgamate statutory provisions from different enactments in a manner that neither reflects the text of the law nor permits such blending.”

The Family Court’s attempt to treat the SMA as an extension or variant of HMA—and to overlay an HMA divorce petition with SMA provisions—was held to be legally impermissible.

2. Impermissible Reliance on Non‑Existent “Section 28A SMA” and Un‑Notified Amendments

One of the most serious defects is the Family Court’s reliance on a purported Section 28A of the Special Marriage Act introducing irretrievable breakdown of marriage as a ground of divorce.

The Division Bench notes:

There is currently no Section 28A in the SMA as enacted and in force.
The Family Court seems to have drawn upon a proposed amendment or Bill, never enacted, gazetted or notified.
RTI information from the Rajya Sabha, Lok Sabha and Ministry of Law & Justice confirms that no such amendment has been brought into force.

On this basis, the High Court expresses astonishment that a judicial officer:

“relied upon, in the Impugned Judgement, a provision, Section 28A of the SMA, that does not exist on the statute book, and on this basis granted a decree of divorce.”

The Bench holds that:

Courts must apply existing law as enacted by the legislature, not draft Bills or policy proposals.
Administrative convenience (such as “saving judicial time” or “avoiding another round of litigation”) cannot override statutory mandates.

Thus, the Family Court’s invocation of “Section 28A” and irretrievable breakdown as if it were a codified statutory ground is a jurisdictional error that fundamentally vitiates the decree.

3. Misuse of the Family Courts Act, 1984

The High Court notes a recurring pattern in which the Family Court Judge has invoked the procedural flexibility and conciliatory mandate of the FC Act to bypass substantive matrimonial requirements under HMA and SMA.

The FC Act is meant to:

streamline procedure,
encourage settlement and counselling, and
avoid technical traps where possible,

but it does not:

create new substantive grounds for divorce;
allow a judge to ignore conditions like the statutory waiting periods, joint petitions, or evidentiary burdens under HMA or SMA; or
authorise reliance on non‑existent provisions.

By treating the FC Act as a charter for “statutory re‑engineering”, the Family Court threatened the coherence of the matrimonial law framework and justified High Court intervention.

4. Irretrievable Breakdown vs. Statutory Grounds of Divorce

While the Family Court attempted to anchor its decree partly on “irretrievable breakdown” (both through the fictional Section 28A SMA and by reading Supreme Court jurisprudence expansively), the Division Bench re‑emphasizes:

Irretrievable breakdown of marriage is not, by itself, a statutory ground of divorce under HMA or SMA.
Subordinate courts cannot create or apply such a ground in the absence of legislation.
The Supreme Court, under Article 142 of the Constitution, has on occasion dissolved marriages on the basis of irretrievable breakdown to “do complete justice”, but that is a constitutional power not shared by Family Courts or High Courts.

At the same time, the High Court does not deny that:

factors such as prolonged separation, total loss of consortium, and multiple litigations can be relevant in assessing cruelty under Section 13(1)(ia) HMA; but
such an assessment must be evidence‑based and not a substitute for the statutory grounds; nor can it be used to short‑circuit legislative policy or import non‑enacted grounds from other statutes or proposals.

5. Characterisation of SMA Marriages as “Not Holy” – A Constitutional and Normative Correction

The High Court takes particular exception to the Family Court’s statement that:

“Marriages under the Special Marriage Act, 1954 cannot be termed as holy union as it permits marriage between persons belonging to different religion and personal law of some of the religion recognizes marriage civil contract and not holy union.”

The Division Bench corrects this on several levels:

Secular framework does not reduce sanctity: The SMA is a secular statute facilitating marriages irrespective of religion. The absence of religious trappings does not render SMA marriages less solemn, dignified or worthy of respect. They remain fully valid, binding and protected under law.
Hindu marriage remains a “holy union” despite divorce provisions: The Bench clarifies that:
- the introduction of divorce provisions in HMA does not strip Hindu marriage of its sacramental character;
- its holiness is rooted in its religious and spiritual dimensions, as recognised in the Supreme Court precedents cited, not in notions of indissolubility over “seven births”.
Equality and secularism concerns: Though not articulated in constitutional terms, the judgment implicitly affirms that judicial characterisations implying that inter‑religious or civil marriages are “less holy” sit uneasily with principles of equality and secularism. Judges must avoid religiously loaded hierarchies among legally valid forms of marriage.

Thus, the High Court re‑asserts that SMA marriages carry the same legal sanctity as marriages celebrated under personal laws.

6. Procedural Fairness, Evidence and Natural Justice in Matrimonial Trials

Another critical plank of the judgment is the insistence that determinations of cruelty, breakdown and other matrimonial issues must be founded on properly led evidence.

The High Court emphasises:

“Matrimonial disputes, by their very nature, require adjudication on the basis of properly led evidence, particularly oral testimony.”
Issues like cruelty are fact‑intensive and cannot be resolved on pleadings alone.
Closing the wife’s evidence on the very first date she failed to appear for cross‑examination was “ex facie unfair and unreasonable” and contrary to principles of natural justice.

Moreover:

After the wife’s evidence was closed, the husband strategically opted not to lead evidence, yet the Court proceeded to final arguments and decree.
The finding that “each is inflicting cruelty upon the other” was made in a complete evidentiary vacuum, based mainly on the volume of litigation and assumptions about mutual animosity.

The High Court notes that the wife’s challenge to closure of her evidence (CM(M) 1862/2024) was withdrawn only after the divorce decree, with liberty reserved, so her grievance remained live. On these facts, a de novo trial is the only just course.

7. Appellate Supervision and Direction for Judicial Training

Possibly the most consequential institutional aspect of the judgment is the direction that the concerned Family Court Judge undergo comprehensive refresher training in matrimonial laws under the aegis of the Delhi Judicial Academy.

The High Court balances respect for judicial independence with the need to preserve systemic integrity:

It acknowledges the Supreme Court’s caution that High Courts should ordinarily avoid personal remarks against subordinate judicial officers.
However, it holds that the repeated pattern of statutory misapplication and disregard for basic principles of evidence and jurisdiction “threatens the integrity of the administration of justice”.
Appellate courts exist to correct errors, but they cannot allow a situation where those errors become systemic and repeated failures to follow the law.

The training direction is remedial rather than punitive. It signals:

a need for capacity‑building in complex fields like matrimonial law; and
a willingness of the High Court to intervene structurally where repeated appellate corrections have not sufficed.

8. Limited Scope of Appellate Decision – Maintainability Left Open

While the High Court’s analysis of the differences between HMA and SMA might suggest a leaning toward the conclusion that the SMA is the proper governing law for this marriage, the Bench consciously refrains from finally deciding:

whether a divorce petition under Section 13 HMA is maintainable in respect of a marriage solemnised and registered under the SMA.

Instead, it:

sets aside the decree solely on the grounds of statutory misapplication, reliance on non‑existent provisions and procedural unfairness; and
explicitly leaves maintainability to be decided by the Family Court in the remanded proceedings, “at the appropriate stage in accordance with the law.”

This cautious approach preserves the trial court’s role as the primary fact‑finder and ensures that any ruling on the HMA/SMA interface is grounded in a complete factual and legal record.

VI. Impact and Implications

A. For Family Courts and Trial Judges

The judgment sends a clear message to Family Courts:

Statutory fidelity is non‑negotiable. Procedural flexibility under the FC Act cannot be used as a vehicle for creative rewriting of substantive law.
Evidence is indispensable. Even if parties appear acrimonious and reconciliation seems impossible, findings on cruelty, breakdown or other grounds must be based on evidence, not judicial intuition alone.
No shortcuts through non‑existent law. Trial courts cannot rely on proposed or draft amendments, non‑notified provisions, or constitutional powers reserved to the Supreme Court (e.g., Article 142) to grant divorce on grounds like irretrievable breakdown.
Judicial training as a corrective. The directive for refresher training underscores that where a pattern of misapplication emerges, the answer may lie not only in appellate reversal but also in systematic capacity‑building.

B. For Litigants in Matrimonial Disputes

For parties to matrimonial disputes, the decision reinforces that:

They are entitled to a fair trial with an opportunity to present and test evidence.
Decrees of divorce cannot rest solely on pleadings, no matter how extensive the litigation history.
The applicable statute (HMA vs SMA) and its specific requirements matter greatly, especially where the marriage has been formally registered under a particular enactment.
High Courts remain vigilant guardians against procedural shortcuts that might otherwise prejudice parties’ rights.

C. For the Development of Matrimonial Law

In doctrinal terms, the judgment:

Reaffirms that HMA and SMA are not fungible. Each has its own scheme, and courts must carefully determine which applies based on the mode of marriage and the parties’ status.
Reiterates that irretrievable breakdown of marriage is not yet a codified ground for divorce in ordinary courts, despite longstanding academic and judicial discourse.
Clarifies the normative stance that SMA marriages are as solemn and dignified as marriages under personal law, and must not be treated as a lesser category.
Demonstrates how appellate courts can address systemic issues in subordinate courts through both case‑specific relief (de novo trial) and institutional measures (training directions).

VII. Complex Concepts Simplified

1. “Self‑Contained Code”

When the Court calls the SMA a “self‑contained code”, it means that:

the Act itself lays down all the rules on who can marry, how they marry, how they can divorce, etc.;
courts are not supposed to “mix and match” it with other matrimonial laws unless the statute explicitly directs such interplay.

2. Jurisdiction vs. Maintainability

Jurisdiction refers broadly to a court’s legal power to hear and decide a range of cases (e.g., the Family Court’s power to try matrimonial cases).
Maintainability concerns whether a particular petition in a particular form and under a particular statute is appropriate—for example, whether it is legally proper to seek HMA divorce in respect of an SMA marriage.

3. Irretrievable Breakdown of Marriage

“Irretrievable breakdown” means a situation where:

the marriage has completely collapsed—there is no companionship, cohabitation or mutual trust left; and
there is no realistic chance of reconciliation.

In India:

It is not yet an independent, codified ground of divorce under HMA or SMA.
The Supreme Court, using its extraordinary powers under Article 142, has occasionally granted divorce on this basis, but subordinate courts cannot do so unless Parliament amends the law.

4. De Novo Adjudication

“De novo” means “from the beginning.” When the High Court orders de novo adjudication:

the case is to be heard afresh by the Family Court;
both parties can lead evidence as if the earlier trial had not taken place; and
the earlier findings are effectively wiped out and do not bind the new trial judge.

5. Principles of Natural Justice

Key principles include:

Audi alteram partem – “hear the other side”: no one should be condemned without a fair opportunity to present their case.
Nemo judex in causa sua – “no one should be a judge in their own cause”: impartiality of the decision‑maker.

Closing the wife’s evidence the first time she was absent for cross‑examination, followed by deciding the case without any evidence, was found to violate the first principle.

VIII. Conclusion

Suman Sankar Bhunia v. Debarati Bhunia Chakraborty is more than a routine matrimonial appeal. It is a pointed reaffirmation of:

the primacy of statutory text over judicial improvisation;
the requirement of evidence‑based adjudication in matrimonial disputes, particularly on questions of cruelty and breakdown; and
the equal legal dignity of civil, inter‑religious and personal law marriages under India’s plural legal system.

By setting aside a decree founded on a non‑existent statutory provision, conflated legal regimes and a truncated trial process, the Delhi High Court restores:

the integrity of the matrimonial law framework (HMA and SMA as separate codes);
the procedural rights of both spouses to a fair trial; and
confidence that appellate scrutiny will address not only individual miscarriages of justice but also systemic misapplications of law.

The direction for refresher training in matrimonial law stands out as a rare but important institutional response. As such, this judgment is likely to be cited in future not only for its holdings on HMA–SMA interplay and irretrievable breakdown, but also as a model of appellate intervention to safeguard judicial discipline and statutory fidelity in family courts.

Reasserting Statutory Discipline in Family Courts: Commentary on Suman Sankar Bhunia v. Debarati Bhunia Chakraborty