Landmark judgment sets precedent for fraud-based annulment and revises permanent alimony to Rs. 50 lakhs
In a significant judgment, the Jharkhand High Court has annulled the marriage between Priyanka Sahi and Siddarth Rao, citing fraud and concealment of material facts, including the respondent's prior live-in relationship. The division bench, comprising Justice Sujit Narayan Prasad and Justice Gautam Kumar Choudhary, delivered the verdict on January 21, 2026.
The case revolved around the annulment of marriage under Section 12(1)(C) of the Hindu Marriage Act, 1955, which allows for voidable marriages if consent was obtained through fraud or misrepresentation. Priyanka Sahi alleged that Siddarth Rao concealed his previous live-in relationship with another woman, Meeruta Sharma, which vitiated her consent to the marriage. The court upheld this argument, declaring the marriage void.
In addition to the annulment, the court addressed the issue of permanent alimony under Section 25 of the Hindu Marriage Act. Initially, the Family Court had awarded Rs. 30 lakhs as alimony, which Priyanka Sahi challenged for being inadequately calculated. Considering the respondent's financial capacity, the High Court revised the amount to Rs. 50 lakhs as a one-time settlement, payable in five monthly installments.
The judgment emphasized that the determination of alimony requires an equitable balance of multiple factors, including the income and assets of both parties, the standard of living during the marriage, and the inability of the petitioner to sustain herself independently. The court also recognized the irretrievable breakdown of the marriage, terming it a "deadwood marriage" due to the long period of separation.
The judgment references several cases, including the Supreme Court's decision in Rajnesh v. Neha, which laid down guidelines for assessing alimony. This verdict reaffirms the court's commitment to ensuring fair and just settlements in matrimonial disputes, particularly when fraud and concealment are involved.
Bottom Line:
Hindu Marriage Act, 1955 - Annulment of marriage under Section 12(1)(C) allowed on grounds of fraud and concealment of facts, including prior live-in relationship of the respondent with another woman. Permanent alimony enhanced to Rs. 50,00,000/- as one-time settlement, considering the respondent's income and appellant's circumstances.
Statutory provision(s): Hindu Marriage Act, 1955 Section 12(1)(C), Section 25
Priyanka Sahi v. Siddarth Rao, (Jharkhand)(DB) : Law Finder Doc id # 2842436
