The Supreme Court’s Clarification of “Best Interests” for Adults with Cognitive Disabilities: Supreme Court Of India

1. Introduction

The Supreme Court of India’s judgment in Sharmila Velamur v. V. Sanjay and Others (2025 INSC 299) addresses the critical question of guardianship and custody for an adult with significant intellectual and developmental challenges. The case centers on the custody of a 22-year-old man, Aadith, a United States citizen diagnosed with Ataxic Cerebral Palsy and mild intellectual disability. Although he is legally an adult, Aadith’s cognitive capacity to make independent decisions stands at the forefront of this dispute, thereby raising important issues regarding the application of the “best interests” test to an adult with special needs.

The appellant (Aadith’s mother) and the respondent no. 4 (Aadith’s father) are both US citizens. Their older son, Aadith, was born with Ataxic Cerebral Palsy; the younger son, Arjun, was later diagnosed with Autism Spectrum Disorder. The parents obtained a divorce in the United States, resulting in shared custody arrangements formulated by a US court. Eventually, Aadith’s father brought him to India, which led to complex questions regarding Aadith’s long-term residence and guardianship.

This Supreme Court judgment establishes a meaningful precedent by applying the doctrine of parens patriae even for an adult if medical evidence suggests he or she cannot make informed decisions. The Court underscores the importance of retaining or restoring a cognitively disabled adult to surroundings that promise continued specialized care, including education, medical consultation, and ongoing familial support.

2. Summary of the Judgment

The Supreme Court reversed the earlier decision of the High Court of Madras, which had disposed of the mother’s habeas corpus petition by concluding that Aadith was living in India of his own free will. Instead, the Supreme Court held that Aadith’s cognitive and physical limitations prohibited him from making legally binding, independent decisions about where he should reside.

After extensively reviewing medical records from both US-based evaluations and the thorough assessments conducted at the National Institute of Mental Health and Neuro Sciences (NIMHANS) in Bengaluru, the Court held that Aadith’s developmental level is akin to that of an 8-to-10-year-old child. Therefore, he requires guardianship support for all complex decision-making, particularly relating to financial, legal, and long-term life decisions.

Concluding that Aadith’s best interests would be served by returning him to the United States, the Court directed that Aadith be under the custody of the appellant (his mother). The Court justified this stance on several grounds, including the specialized welfare services readily available in the US, Aadith’s attachment to his younger brother (Arjun), and Aadith’s own stated wish (via medical interviews) to continue his skill development there. Further, the US courts had already conferred permanent guardianship on the mother.

3. Analysis

3.1 Precedents Cited

The Court referenced various precedents revolving around the principle of “best interests and welfare,” including cases where the Supreme Court dealt with child custody disputes when one parent took the child out of the country—even in conflict with foreign-court orders. Though Aadith is legally an adult, his mental and physical disabilities meant these child custody standards (e.g., Nithya Anand Raghavan v. State (NCT of Delhi)) were relevant by analogy, leading the Court to highlight that foreign court orders merit respectful consideration but must give way to the best interests of the individual in question.

The Court also reiterated principles from earlier landmark rulings on intellectual disability, such as Suchita Srivastava v. Chandigarh Administration, where the Supreme Court insisted on respecting the autonomy and rights of cognitively disabled adults. However, extrapolating from those rulings, the Court clarified that proper medical opinion is vital when evaluating a disabled person’s ability to make choices about residence and personal care.

3.2 Legal Reasoning

Central to the Court’s analysis was whether Aadith, despite being over 18, could independently consent to remain in India with his father. The judgment found that Aadith’s mental age (8 to 10 years) evidenced impaired capacity to comprehend the consequences of substantial life decisions.

The Court:

Examined medical and psychological evaluations from the Idaho Department of Health and Welfare, concluding Aadith needed guardianship support.
Relied heavily on the extensive multidisciplinary assessments conducted at NIMHANS, Bengaluru. These assessments reinforced that while Aadith can handle simple tasks or short-term decisions, he lacks the capacity to manage complex, long-term matters (financial, occupational, or social) without external support.
Emphasized that under the lens of parens patriae, the Court must intervene in the best interest of a cognitively disabled adult if that adult is legally incompetent to decide for himself.
Stated that the High Court had prematurely concluded that Aadith was living voluntarily in India, failing to account for his evident intellectual disability.

Conclusively, the Supreme Court found that the welfare standard applied in child custody disputes was equally apt in this adult guardianship context, given the severity of Aadith’s cognitive impairments. Reunification with his younger sibling and established US-based support systems took precedence over any alleged “consent” to remain in India.

3.3 Impact

The judgment’s most evident impact is the reinforcement that Indian courts, applying the parens patriae principle, can override an adult’s stated preference if compelling, medically recognized evidence suggests that the adult’s decision-making capacity is substantially compromised.

Future disputes involving adults with intellectual and developmental disabilities may be guided by this clarifying application of the “best interests” standard. The Court has firmly maintained that:

Medical expertise is paramount in determining the true capacity of an adult with intellectual disabilities.
Where the disability severely limits comprehension and volition, courts may treat the individual akin to a minor, ensuring that the protective mantle of the law is fully extended.
Overarching foreign court orders or guardianship decrees should be respected unless they clearly conflict with the welfare and best interests principle established under Indian law; in this particular scenario, the Idaho court’s order dovetailed with the Supreme Court’s final directions.

4. Complex Concepts Simplified

Parens Patriae: A legal doctrine empowering courts (or the State) to act as a guardian for those unable to care for themselves, including minors and persons with severe disabilities. In lay terms: if someone cannot protect their own interests due to a disability, the court steps in and decides what would benefit them most.
Guardianship: The legal authority vested in a person (the guardian) to make decisions on behalf of another (the ward) if the latter is deemed incapable of making informed decisions for themselves in specific or broad spheres of life (financial, medical, educational, etc.).
Intellectual Disability: A condition characterized by below-average IQ and limitations in adaptive behaviors such as social and practical skills, restricting a person’s day-to-day independence and decision-making abilities.
Ataxic Cerebral Palsy: A neurological condition primarily affecting muscle coordination and balance, sometimes coupled with intellectual and learning impairments.
Best Interests Standard: Commonly applied in custody and guardianship disputes. The Court looks to see what environment, placement, or arrangement serves the person’s emotional, social, developmental, and physical welfare the most.

5. Conclusion

The Supreme Court’s judgment in Sharmila Velamur v. V. Sanjay and Others (2025 INSC 299) sets a crucial precedent for individuals with significant cognitive disabilities. It reaffirms that, even past the age of majority, such persons may rightly remain under a legal guardian’s care if credible medical evidence proves they cannot make informed decisions independently. In this instance, the Court’s ultimate directive to return Aadith to the United States under his mother’s guardianship preserved his routine, specialized support network, and emotional ties to his younger brother.

More broadly, this ruling emphasizes that the doctrine of “best interests and welfare” transcends chronological age when an adult’s mental capacity is demonstrably limited. Armed with extensive input from expert bodies, the Supreme Court robustly protected the dignity and the well-being of a young adult facing lifelong challenges, thereby reinforcing that protective legal frameworks do not vanish the moment a person with significant disabilities turns 18.

The Supreme Court’s Clarification of “Best Interests” for Adults with Cognitive Disabilities