Liberal construction of Family Courts Act extends jurisdiction to property disputes between divorced spouses and defeats a narrow reading.

Section 7 of the Family Courts Act, 1984 was construed liberally to advance the statute's objective of conciliatory and speedy resolution of family disputes, so Explanation (c) was held to cover disputes concerning the property of spouses or either of them. That construction is not confined to disputes arising during a subsisting marriage and extends to property claims between divorced spouses. A narrower reading was rejected as inconsistent with legislative purpose, and earlier authorities under the Muslim Women (Protection of Rights on Divorce) Act, 1986 and Section 125 CrPC were treated as inapplicable. The Family Court therefore had jurisdiction over the property dispute, and the maintainability objection failed.

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Issues: Whether a Family Court has jurisdiction under Section 7 of the Family Courts Act, 1984 to adjudicate a dispute relating to property claimed by one spouse against the other after divorce.

Analysis: The expression used in the Family Courts Act for matters concerning marriage and family affairs was construed broadly in light of the object of the legislation, which is to secure conciliatory and speedy settlement of family disputes. Explanation (c) to Section 7 was read as extending to disputes concerning the property of the spouses or either of them, and not as being confined only to disputes between parties to a subsisting marriage. A narrow interpretation was held to defeat the legislative purpose. Earlier decisions dealing with claims under Section 3 of the Muslim Women (Protection of Rights on Divorce) Act, 1986 and proceedings under Section 125 of the Code of Criminal Procedure, 1973 were treated as inapplicable to the present dispute.

Conclusion: The Family Court had jurisdiction to decide the property dispute between the divorced parties, and the objection to maintainability failed.

Ratio Decidendi: Section 7 of the Family Courts Act, 1984 must receive a liberal construction so as to include disputes concerning the property of spouses or either of them, even where the marriage has ended in divorce.

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