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Delhi HC Dismisses Daughter-in-Law's Appeal, Upholds Mother-in-Law's Property Rights

Shivam Yadav

Delhi HC rules daughter-in-law has no right to stay in in-law’s house post-divorce, upholds Will and ownership deeds in major Rohini property dispute.

Delhi HC Dismisses Daughter-in-Law's Appeal, Upholds Mother-in-Law's Property Rights

In a significant ruling on family property disputes, the Delhi High Court has dismissed an appeal filed by X, a daughter-in-law, against her eviction from a house owned by her mother-in-law, Y. The court confirmed that the property in Rohini, Delhi, belonged exclusively to Y, and that X had “no legal right to continue staying” there after divorce.

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The division bench led by Justice Anil Kshetarpal and Justice Harish Vaidyanathan Shankar pronounced the verdict on 21 August 2025, affirming a Family Court’s earlier order directing X to vacate the premises within six months.

X had argued that since she began living in the house after her marriage in 1999, it qualified as her “matrimonial home” and therefore a “shared household” under the Domestic Violence Act. She also claimed her family had contributed financially during the purchase and construction of the property.

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The bench, however, observed: “Once the marriage has been dissolved by a decree of divorce, the domestic relationship comes to an end. In the absence of such a relationship, the right of residence under Section 17 of the PWDV Act cannot be invoked.”

The judges highlighted that the right of residence under the Act is protective in nature, but it does not give permanent ownership or automatic occupation once the marriage itself is legally over.

Y had produced a registered conveyance deed of 2011 and a Will executed in 2013 to prove ownership. The court found these documents valid and binding, rejecting X’s claim that they were fabricated. The court noted that oral claims of financial contributions without receipts or proof could not override legally registered property records.

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The bench further observed: “Once valid registered instruments demonstrating ownership are produced, the burden lies on the opposing party to prove duress or contribution. That burden was not discharged in this case.”

The judgment has wider implications for family disputes where daughters-in-law claim residence rights in in-laws’ self-acquired properties. Legal experts note that the ruling reiterates the principle that the “shared household” protection under the Domestic Violence Act is linked to the existence of a subsisting marriage or domestic relationship.

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With this decision, X has lost her long pursuit of residence rights in the disputed Rohini property, while Y’s heirs have retained exclusive ownership. The court concluded: “We find no reason to interfere with the family court’s findings. The appeal is dismissed.”

Case Title: X vs. Y 

Case Number:MAT.APP.(F.C.) 348/2024, CM APPL. 62203/2024 & CM APPL. 29620/2025

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