PANKAJ JAIN Vs. PARUL JAIN

JUDGEMENT

(1.) The present Appeal has been filed under Sec. 28 of the Hindu Marriage Act, 1955 [hereinafter referred to as 'HMA"] read with Sec. 19 of the Family Courts Act, 1984 seeking to challenge the Order dtd. 29/3/2025 [hereinafter referred to as 'Impugned Order"] passed by the learned Judge, Family Court-01, West District, Tis Hazari Courts, Delhi [hereinafter referred to as the 'Family Court"] in HMA No. 1089/2018 titled Parul Jain v. Pankaj Jain, whereby the Appellant's application dtd. 17/8/2021 under Sec. 22 of the Hindu Marriage Act, 1955 seeking injunctive relief against the Respondent, her brother, and her employer from disclosing or disseminating details of the matrimonial litigation and related custody proceedings, was dismissed.

(2.) The brief facts in which the present Appeal arises pertain to the marriage between the parties, solemnized on 22/4/2006 according to the Hindu rites and ceremonies in Delhi. Out of the said wedlock, a girl child was born on 11/2/2013. Thereafter, matrimonial discord arose between the parties, and multiple proceedings came to be instituted, including the institution of HMA No. 1089/2018 by the Respondent-wife seeking dissolution of marriage.

(3.) During the pendency of the said proceedings, the Appellant filed four separate applications dtd. 17/8/2021, 5/12/2022, 10/9/2023, and 30/5/2024 under Sec. 22 of the HMA. In these applications, the Appellant alleged that the Respondent, her brother, and her employer had disclosed confidential details relating to the ongoing matrimonial proceedings and related custody disputes to third parties, including in collateral civil and criminal litigations, thereby infringing the confidentiality mandated under Sec. 22 of the HMA. It was, inter alia, contended that such disclosures were made to the Respondent's employer, who subsequently referred to them in a civil suit pending before this Court, and to authorities and institutions such as police officials, schools attended by the minor child, and also formed part of a complaint filed under the POCSO Act. The Appellant, therefore, sought injunctive directions against the Respondent and the aforementioned individuals from further circulating or relying upon any part of the matrimonial record.