Reynold Rajamani v Union of India

AIR 1982 SC 1261Supreme Court of India1982Family Law II

Rule established

Parliament is entitled to enact different grounds of divorce for different communities; the asymmetry in S.10 IDA was upheld at that time as having a rational basis rooted in the structure of Christian matrimonial law.

Facts

A Christian petitioner challenged S.10 of the IDA on the ground of discrimination between the grounds available to the husband and the wife.

Issue

Whether the differential grounds for husband and wife under S.10 IDA violated Art.14.

Held

Upheld. The Court deferred to legislative policy, holding that different personal law communities could be treated differently in matters of marriage and divorce, and that the classification had a historical and doctrinal basis.

Ratio Decidendi

(1) Personal law legislation may treat different communities differently without violating Art.14. (2) The classification was rooted in the structure of Christian matrimonial law as inherited from English ecclesiastical law.

How to use it in an exam

Cite to illustrate the earlier judicial reluctance to interfere with personal law inequality
Contrast with Ammini EJ (1995) and Pragati Varghese (1997), which took the opposite view
The 2001 Amendment legislatively overruled this position

Source

Source: AIR 1982 SC 1261

This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.

Cited in study notes

Family Law IIDivorce Act 1869 Salient FeaturesEarlier position, effectively overruled by the 2001 Amendment