Christian lawDivorce act 1869Supreme Court of India

Reynold Rajamani v Union of India

AIR 1982 SC 126119821 min read
The case in brief30-second read
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.
Principle
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

  1. 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.

Exam use

How to use it in an answer

  • 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

Cite this

Citation

Reynold Rajamani v Union of India AIR 1982 SC 1261

Reported: AIR 1982 SC 1261. This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.