Madhya Pradesh High Court
Aditya Prasad vs Perena Gupta on 26 November, 2025
1 MP-6403-2025
IN THE HIGH COURT OF MADHYA PRADESH
AT JABALPUR
BEFORE
HON'BLE SHRI JUSTICE VIVEK JAIN
ON THE 26th OF NOVEMBER, 2025
MISC. PETITION No. 6403 of 2025
ADITYA PRASAD
Versus
PERENA GUPTA
Appearance:
Shri Achyut Govindam Tiwari and Shri Kaustubh Tiwari - Advocates
for petitioner.
ORDER
The present petition under Article 227 of the Constitution of India has been filed by the petitioner-husband being aggrieved by the order dated 06.10.2025 passed by the Family Court, Jabalpur, whereby application of the petitioner under Section 44-A of the Code of Civil Procedure 1908, has been rejected by the Family Court.
2. The learned counsel for the petitioner has argued before this Court that a marriage between the petitioner and the respondent was solemnised in India on 28.11.2019 and a marriage certificate was issued by the Marriage Registering Officer, Jabalpur on 02.12.2019. It is argued that both the parties i.e. petitioner-husband and respondent-wife are citizens of India but because the husband is at present domiciled in New Zealand as he is residing in New Zealand since the year 2021 and he intends to settle down in New Zealand permanently, therefore, he filed an application for divorce before the Court at Signature Not Verified Signed by: PREM SHANKAR MISHRA Signing time: 06-12-2025 16:08:40 2 MP-6403-2025 New Zealand i.e. Family Court, Auckland, New Zealand in FAM-2023-095- 005830 under Family Proceedings Act, 1980 applicable in New Zealand.
3. It is argued that on account of irreconcilable breakdown of marriage, which is a ground under Section 39 of the Family Proceedings Act 1980, applicable in New Zealand, a decree of divorce has been granted.
4. The learned counsel for the petitioner has vehemently argued before this Court that a decree of divorce cannot be physically executed but since it was not a decree passed by the Family Court situated in India but it was a divorce decree passed by Family Court situated in New Zealand and, therefore, it was a foreign decree, hence the petitioner was required to file an application under Section 44-A of CPC to get the divorce decree/order authenticated by a Court in India so that the technical position of the marriage still being subsisting to be valid in India may come to an end and the petitioner may have the fruits of divorce decree passed by the Court in New Zealand, in India also.
5. It is argued that the decree in question is a bi-parte decree and it will bind both the parties and is a decree on merits. It is further argued that New Zealand is a reciprocating territory and as per Section 13 of the Civil Procedure Code, the foreign judgment would be conclusive because it has been pronounced by a Court of competent jurisdiction on merits of the case and is founded on correct view of law and has not been obtained by fraud or on breach of any law in force in India. Therefore, the application was filed before the Family Court under Section 44A of CPC. It is further argued that a person in possession of a foreign decree of divorce can file such an Signature Not Verified Signed by: PREM SHANKAR MISHRA Signing time: 06-12-2025 16:08:40 3 MP-6403-2025 application to get the foreign decree authenticated by a Court in India in terms of Section 13 of CPC and such a course of action as well as maintainability of application under Section 44A of CPC has been upheld by two different High Courts in India i.e. Madras High Court in case of August Pedre vs. Sub Registrar Pondicherry Municipality Puducherry, reported in 2024 SCC OnLine Mad 9738 and in the case of Seethal Joseph vs. Marriage Officer, Kayamkulam Municipality , reported in 2018 SCC OnLine Ker 19269 . Therefore, it is prayed to set aside the impugned order of the Family Court and allow the petition or to remand the matter back to the Family Court to pass an order in accordance with Section 44A read with Section 13 CPC so that the decree may be got authenticated in India whenever the petitioner comes down to reside in Indian territorial limits.
6. Heard.
7. The present case raises a very interesting question that where marriage has been solemnised by between two Indian citizens in India and is a marriage in terms of provisions of the Hindu Marriage Act, 1955 and one of the parties to marriage has gone abroad and it is his case that he has gone abroad for the purpose of permanently settling in that foreign country, though he may not have been still granted citizenship of that foreign country but he is now domiciled in that foreign country, then under what circumstances, a decree of divorce granted in that foreign country, would become applicable in India.
8. Though most of the background facts have already been dealt above but some more background facts of the matter are that though the husband is Signature Not Verified Signed by: PREM SHANKAR MISHRA Signing time: 06-12-2025 16:08:40 4 MP-6403-2025 residing in New Zealand since the year 2021 and states that he has been residing in New Zealand with the intention of permanently settling in New Zealand and he claims now to have been domiciled in New Zealand, but, admittedly, the wife has never been to New Zealand and did not reside in New Zealand either on the date of presentation of divorce petition or on the date of passing of divorce decree by the Court in New Zealand and she cannot even be argued to be domiciled in New Zealand.
9. The New Zealand Court has granted decree of divorce holding the petitioner to be domiciled in New Zealand and deriving its jurisdiction from the fact of petitioner being now domiciled in New Zealand though being a Indian citizen.
10. In the opinion of this Court, the question that whether the petitioner is domiciled in New Zealand or not, despite being a citizen of India, does not arise at all in the present case because the other party to the marriage i.e. the wife is admittedly not residing in New Zealand and has never resided in New Zealand and is even not argued to be domiciled in New Zealand. Therefore, Hindu Marriage Act, 1955 would continue to apply in view of Section 1(2) thereof which reads as under:
"(2) It extends to the whole of India except the State of Jammu and Kashmir, and applies also to Hindus domiciled in the territories to which this Act extends who are outside the said territories."
11. A marriage being union between two persons as per Section 1(2) once one party to the marriage is not even argued by the other party to be domiciled in New Zealand, then the provisions of the Hindu Marriage Act, 1955 would continue to apply to the marriage union.
12. For the purpose of wriggling out of related provisions of the Hindu Signature Not Verified Signed by: PREM SHANKAR MISHRA Signing time: 06-12-2025 16:08:40 5 MP-6403-2025 Marriage Act, 1955, domicile of both the parties to the marriage would be relevant factor once the marriage was solemnised in India between two Indian citizens.
13. As per Section 13 of the Civil Procedure Code, the following provisions have been made:-
"13. When foreign judgment not conclusive .-
A foreign judgment shall be conclusive as to any matter thereby directly adjudicated upon between the same parties or between parties under whom they or any of them claim litigating under the same title except-
(a) where it has not been pronounced by a Court of competent jurisdiction;
(b) where it has not been given on the merits of the case;
(c) where it appears on the face of the proceedings to be founded on an incorrect view of international law or a refusal to recognise the law of [India] in cases in which such law is applicable;
(d) where the proceedings in which the judgment was obtained are opposed to natural justice;
(e) where it has been obtained by fraud;
(f) where it sustains a claim founded on a breach of any law in force in [India]."
14. As per Section 13 above, foreign decree would not be conclusive if there is a refusal to recognise the law of India in cases in which such law is applicable which is the situation contemplated in Section 13(c) of CPC. The divorce decree granted by the Court in New Zealand, is founded on irreconcilable breakdown of marriage and on no other ground, whereas in Indian law irreconcilable breakdown of marriage is not a valid ground of divorce but can only be a ground of divorce by mutual consent and not a ground of divorce in a contested case despite there being no consent of the other party. As per Hindu Marriage Act, 1955, a contested divorce other than a divorce by mutual consent, can only be on grounds as per Section 13 of the Hindu Marriage Act and the party has to bring its case within the four Signature Not Verified Signed by: PREM SHANKAR MISHRA Signing time: 06-12-2025 16:08:40 6 MP-6403-2025 corners of one of the grounds as per Section 13, which are as under:-
"13. Divorce.
(1) Any marriage solemnised, whether before or after the commencement of this Act, may, on a petition presented by either the husband or the wife, be dissolved by a decree of divorce on the ground that the other party-
(i) has, after the solemnisation of the marriage, had voluntary sexual intercourse with any person other than his or her spouse; or (ia) has, after the solemnisation of the marriage, treated the petitioner with cruelty; or (ib) has deserted the petitioner for a continuous period of not less than two years immediately preceding the presentation of the petition; or
(ii) has ceased to be a Hindu by conversion to another religion; or
(iii) has been incurably of unsound mind, or has been suffering continuously or intermittently from mental disorder of such a kind and to such an extent that the petitioner cannot reasonably be expected to live with the respondent.
Explanation.-- In this clause,--
(a) the expression "mental disorder" means mental illness, arrested or incomplete development of mind, psychopathic disorder or any other disorder or disability of mind and includes schizophrenia;
(b) the expression "psychopathic disorder" means a persistent disorder or disability of mind (whether or not including sub-normality of intelligence) which results in abnormally aggressive or seriously irresponsible conduct on the part of the other party, and whether or not it requires or is susceptible to medical treatment; or
(v) has *** been suffering from venereal disease in a communicable form; or
(vi) has renounced the world by entering any religious order; or
(vii) has not been heard of as being alive for a period of seven years or more by those persons who would naturally have heard of it, had that party been alive; *** Explanation.-- In this sub-section, the expression "desertion"
means the desertion of the petitioner by the other party to the marriage without reasonable cause and without the consent or against the wish of such party, and includes the wilful neglect of the petitioner by the other party to the marriage, and its grammatical variations and cognate expressions shall be construed accordingly. *** (1A) Either party to a marriage, whether solemnised before or after the commencement of this Act, may also present a petition for the dissolution of the marriage by a decree of divorce on the ground-
(i) that there has been no resumption of cohabitation as between the parties to the marriage for a period of one year or upwards after the passing of a decree for judicial separation in a proceeding Signature Not Verified Signed by: PREM SHANKAR MISHRA Signing time: 06-12-2025 16:08:40 7 MP-6403-2025 to which they were parties; or
(ii) that there has been no restitution of conjugal rights as between the parties to the marriage for a period of [one year or upwards after the passing of a decree for restitution of conjugal rights in a proceeding to which they were parties.
(2) A wife may also present a petition for the dissolution of her marriage by a decree of divorce on the ground,-
(i) in the case of any marriage solemnised before the commencement of this Act, that the husband had married again before such commencement or that any other wife of the husband married before such commencement was alive at the time of the solemnisation of the marriage of the petitioner:
Provided that in either case the other wife is alive at the time of the presentation of the petition; or
(ii) that the husband has, since the solemnisation of the marriage, been guilty of rape, sodomy or bestiality; or
(iii) that in a suit under section 18 of the Hindu Adoptions and Maintenance Act, 1956 (78 of 1956), or in a proceeding under section 125 of the Code of Criminal Procedure, 1973 (2 of 1974) or under the corresponding section 488 of the Code of Criminal Procedure, 1898 (5 of 1898), a decree or order, as the case may be, has been passed against the husband awarding maintenance to the wife notwithstanding that she was living apart and that since the passing of such decree or order, cohabitation between the parties has not been resumed for one year or upwards; or
(iv) that her marriage (whether consummated or not) was solemnised before she attained the age of fifteen years and she has repudiated the marriage after attaining that age but before attaining the age of eighteen years.
Explanation. This clause applies whether the marriage was solemnised before or after the commencement of the Marriage Laws (Amendment) Act, 1976 (68 of 1976)."
15. At this stage, learned counsel for the petitioner had argued that now the Courts in India are also recognising irreconcilable breakdown of marriage as one of the grounds of divorce in contested cases also. In Indian law, except where there is such irreconcilable breakdown of marriage that it is leading to cruelty on both the parties or on one of the parties to marriage, then it cannot be made a ground of divorce and primarily in those cases also, it will be cruelty that has to be proved that parties being forced to live in a broken down marriage, is causing mental cruelty to both or either of the parties.
Signature Not Verified Signed by: PREM SHANKAR MISHRA Signing time: 06-12-2025 16:08:408 MP-6403-2025 However, even in such cases, the primary ground to be proved would be cruelty and irreconcilable breakdown in itself is not a valid ground, like recently held in a case by a Division Bench of this Court in FA No. 789 of 2022.
16. Therefore, it appears to this Court that the foreign decree does not conform to Indian law as per Section 13(c) CPC and it falls within the exceptions as per Section 13(c). It is not even the case where the other side has given up or even consented to the foreign court's jurisdiction. The divorce decree, a copy of which is placed on record as Annexure P/3, duly mentions that the wife had appeared before the Court through video conferencing and also submitted a written application by post and she refused to be subjected to the jurisdiction of Courts in New Zealand. It is further mentioned in para 4 of the judgment of divorce granted by the Court in New Zealand that objection was raised before the Family Court in New Zealand that marriage having irrevocably broken down, is not applicable to Indian laws. Therefore, it is not a case that there has been a consent or giving up of grounds by the respondent-wife.
17. The issue of recognition to divorce decree passed by the foreign court was considered by the Hon'ble Supreme Court in the case of Satya (Smt.) vs. Teja Singh (Shri) , reported in (1975) 1 SCC 120 wherein the Hon'ble Supreme Court held the necessary ingredients to recognise the foreign divorce decree in India. In the aforesaid case, the facts were akin to the present case that the husband had proceeded to a foreign country and obtained a divorce decree in foreign country while his wife and children Signature Not Verified Signed by: PREM SHANKAR MISHRA Signing time: 06-12-2025 16:08:40 9 MP-6403-2025 were residing in India. It was held by the Hon'ble Supreme Court that recognition to be accorded to a foreign decree must depend on the rules of private international law of India and it was held that there is no system of private international law which can be claimed to have universal recognition. It was held that India cannot mechanically adopt the rules of private international law evolved by other countries and are moulded by distinctive social, political and economic conditions obtaining in different countries. It was held that questions relating to personal status of a party depend in England and North America upon the law of his domicile but in many other European countries upon the law of his nationality and it is not rare that a man and woman are husband and wife in one jurisdiction but are divorced in another jurisdiction. The Supreme Court held as under:-
" 8 . The answer to the question as regards the recognition to be accorded to the Nevada decree must depend principally on the Rules of our Private International law. It is a well recognised principle that "Private International law is not the same in all countries." [Cheshire's Private International Law, 8th Edn., (1970), p. 10] There is no system of Private International law which can claim universal recognition and that explains why Cheshire, for example, says that his book is concerned solely with that system which obtains in England, that is to say, with the Rules that guide an English court whenever it is seised of a case that contains some foreign element. The same emphasis can be seen in the works of other celebrated writers like Graveson, Dicey & Morris, and Martin Wolff. Speaking of the "English conflict of laws"
Graveson says: "Almost every country in the modern world has not only its own system of municipal law differing materially from those of its neighbours, but also its own system of conflict of laws, .... The Conflict of Laws, R.B. Graveson, 6th Edn., (1969) pp. 3, 5, 6] " According to Dicey & Morris, "The conflict of laws exists because there are different system of domestic law. But system of the conflict of laws also differ The Conflict of Laws, Dicey & Morris, 8th Edn., (1967) p. 10] ." Martin Wolff advocates the same point of view thus:
"Today undoubtedly Private International law is national law. There exists an English Private International law as distinct from a French, a German, an Italian Private International law. The Rules on the conflict of laws in the various countries Signature Not Verified Signed by: PREM SHANKAR MISHRA Signing time: 06-12-2025 16:08:40
10 MP-6403-2025 differ nearly as much from each other as do those on internal (municipal) law. [Private International Law, Martin Wolff, 2nd Edn., (1950) p. 11] "
It is thus a truism to say that whether it is a problem of municipal law or of conflict of laws, every case which comes before an Indian court must be decided in accordance with Indian law. It is another matter that the Indian conflict of laws may require that the law of a foreign country ought to be applied in a given situation for deciding a case which contains a foreign element. Such a recognition is accorded not as an act of courtesy but on considerations of justice [G. Melville Bigelow's Note to Story's Commentaries on the Conflict of Laws, 8th Edn., (1883) p. 39] . It is implicit in that process, that the foreign law must not offend against our public policy.
9. We cannot therefore adopt mechanically the Rules of Private International law evolved by other countries. These principles vary greatly and are moulded by the distinctive social, political and economic conditions obtaining in these countries. Questions relating to the personal status of a party depend in England and North America upon the law of his domicil, but in France, Italy, Spain and most of the other European countries upon the law of his nationality. Principles governing matters within the divorce jurisdiction are so conflicting in the different countries that not unoften a man and a woman are husband and wife in one jurisdiction but treated as divorced in another jurisdiction. We have before us the problem of such a limping marriage."
18. The Hon'ble Supreme Court went on to hold that determining whether a divorce decree will be recognised in another jurisdiction, as a matter of comity, public policy and good morals may be considered. It was held by the notions of a genuine divorce in India and of substantial justice and distinctive principles of public policy in India, must determine the rules of private international law in India. The Hon'ble Supreme Court went on to hold as under:-
"39. As we have stated at the outset, these principles of the American and English conflict of laws are not to be adopted blindly by Indian courts. Our notions of a genuine divorce and of substantial justice and the distinctive principles of our public policy must determine the Rules of our Private International law. But an awareness of foreign law in a parallel jurisdiction would be a useful guideline in determining these rules. We are sovereign within our territory but "it is no derogation of sovereignty to take account of foreign law" and as said by Cardozo, J. "We are not so provincial as to say that every solution of a problem is wrong because we deal with it otherwise at home"; and we shall not Signature Not Verified Signed by: PREM SHANKAR MISHRA Signing time: 06-12-2025 16:08:40 11 MP-6403-2025 brush aside foreign judicial processes unless doing so "would violate some fundamental principle of justice, some prevalent conception of good morals, some deep rooted tradition of the common weal" [Loucks v. Standard Oil Co. of New York, (1918) 224 NY 99, 111] ."
" 5 3 . Unhappily, the marriage between the appellant and respondent has to limp. They will be treated as divorced in Nevada but their bond of matrimony will remain unsnapped in India, the country of their domicile. This view, it is urged for the respondent, will lead to difficulties. It may. But "these rules of Private International law are made for men and women -- not the other way round -- and a nice tidy logical perfection can never be achieved" [Per Denovan L.J. Formosa v. Formosa, (1962) 3 All ER 419, 424]."
19. This issue was thereafter dealt with in further detail in a subsequent case decided by the Hon'ble Supreme Court in Y. Narasimha Rao v. Y. Venkata Lakshmi , reported in (1991) 3 SCC 451 . In this case, it has been conclusively held by the Hon'ble Supreme Court of India that looking to the interpretation of Section 13 of CPC, a foreign judgment is not conclusive in India as to any matter directly adjudicated upon between the parties if inter a l i a it is founded on incorrect view of international law or refusal to recognise the law of India. In the present case, the respondent-wife duly made it clear to the Court in New Zealand that irrevocable breakdown of marriage is not a ground of divorce in Indian laws but that was ignored by the Court in New Zealand. It would have been a different matter if the said Court had passed a decree of divorce on any ground which is a ground of divorce in India also. The Hon'ble Apex Court held as under:-
"8. Under Section 13 of the Code of Civil Procedure, 1908 (hereinafter referred to as the "Code"), a foreign judgment is not conclusive as to any matter thereby directly adjudicated upon between the parties if (a) it has not been pronounced by a court of competent jurisdiction; (b) it has not been given on the merits of the case; (c) it is founded on an incorrect view of international law or a refusal to recognize the law of India in cases in which such law is applicable; (d) the proceedings are opposed to natural justice; (e) it is obtained by fraud; (f) it sustains a claim founded on a breach of any law in force in India.Signature Not Verified Signed by: PREM SHANKAR MISHRA Signing time: 06-12-2025 16:08:40
12 MP-6403-2025
9. As pointed out above, the present decree dissolving the marriage passed by the foreign court is without jurisdiction according to the Act as neither the marriage was celebrated nor the parties last resided together nor the respondent resided within the jurisdiction of that court. The decree is also passed on a ground which is not available under the Act which is applicable to the marriage. What is further, the decree has been obtained by appellant 1 by stating that he was the resident of the Missouri State when the record shows that he was only a bird of passage there and was ordinarily a resident of the State of Louisiana. He had, if at all, only technically satisfied the requirement of residence of 90 days with the only purpose of obtaining the divorce. He was neither domiciled in that State nor had he an intention to make it his home. He had also no substantial connection with the forum. Appellant 1 has further brought no rules on record under which the St. Louis Court could assume jurisdiction over the matter. On the contrary, as pointed out earlier, he has in his petition made a false averment respondent 1 had refused to continue to stay with him in the State of Missouri where she had never been. In the absence of the rules of jurisdiction of that court, we are not aware whether the residence of respondent 1 within the State of Missouri was necessary to confer jurisdiction on that court, and if not, of the reasons for making the said averment.
10. Relying on a decision of this Court in Smt Satya v. Teja Singh [(1975) 1 SCC 120 : 1975 SCC (Cri) 50 : (1975) 2 SCR 197 : AIR 1975 SC 105] it is possible for us to dispose of this case on a narrow ground, viz., that the appellant played a fraud on the foreign court representing to it incorrect jurisdictional facts. For, as held in that case, residence does not mean a temporary residence for the purpose of obtaining a divorce but habitual residence or residence which is intended to be permanent for future as well. We refrain from adopting that course in the present case because there is nothing on record to assure us that the court of St. Louis does not assume jurisdiction only on the basis of a mere temporary residence of the appellant for 90 days even if such residence is for the purpose of obtaining divorce. We would, therefore, presume that the foreign court by its own rules of jurisdiction had rightly entertained the dispute and granted a valid decree of divorce according to its law. The larger question that we would like to address ourselves to is whether even in such cases, the courts in this country should recognise the foreign divorce decrees.
13. We cannot also lose sight of the fact that today more than ever in the past, the need for definitive rules for recognition of foreign judgments in personal and family matters, and particularly in matrimonial disputes has surged to the surface. Many a man and woman of this land with different personal laws have migrated and are migrating to different countries either to make their permanent Signature Not Verified Signed by: PREM SHANKAR MISHRA Signing time: 06-12-2025 16:08:40 13 MP-6403-2025 abode there or for temporary residence. Likewise there is also immigration of the nationals of other countries. The advancement in communication and transportation has also made it easier for individuals to hop from one country to another. It is also not unusual to come across cases where citizens of this country have been contracting marriages either in this country or abroad with nationals of the other countries or among themselves, or having married here, either both or one of them migrate to other countries. There are also cases where parties having married here have been either domiciled or residing separately in different foreign countries. This migration, temporary or permanent, has also been giving rise to various kinds of matrimonial disputes destroying in its turn the family and its peace. A large number of foreign decrees in matrimonial matters is becoming the order of the day. A time has, therefore, come to ensure certainty in the recognition of the foreign judgments in these matters. The minimum rules of guidance for securing the certainty need not await legislative initiative. This Court can accomplish the modest job within the framework of the present statutory provisions if they are rationally interpreted and extended to achieve the purpose. It is with this intention that we are undertaking this venture. We are aware that unaided and left solely to our resources the rules of guidance which we propose to lay down in this area may prove inadequate or miss some aspects which may not be present to us at this juncture. But a beginning has to be made as best as one can, the lacunae and the errors being left to be filled in and corrected by future judgments.
14. We believe that the relevant provisions of Section 13 of the Code are capable of being interpreted to secure the required certainty in the sphere of this branch of law in conformity with public policy, justice, equity and good conscience, and the rules so evolved will protect the sanctity of the institution of marriage and the unity of family which are the cornerstones of our societal life.
20. From the aforesaid discussion the following rule can be deduced for recognising a foreign matrimonial judgment in this country. The jurisdiction assumed by the foreign court as well as the grounds on which the relief is granted must be in accordance with the matrimonial law under which the parties are married. The exceptions to this rule may be as follows: (i) where the matrimonial action is filed in the forum where the respondent is domiciled or habitually and permanently resides and the relief is granted on a ground available in the matrimonial law under which the parties are married; (ii) where the respondent voluntarily and effectively submits to the jurisdiction of the forum as discussed above and contests the claim which is based on a ground available under the matrimonial law under which the parties are married;
(iii) where the respondent consents to the grant of the relief although the jurisdiction of the forum is not in accordance with the provisions of the matrimonial law of the parties.
Signature Not Verified Signed by: PREM SHANKAR MISHRA Signing time: 06-12-2025 16:08:4014 MP-6403-2025
22. Since with regard to the jurisdiction of the forum as well as the ground on which it is passed the foreign decree in the present case is not in accordance with the Act under which the parties were married, and the respondent had not submitted to the jurisdiction of the court or consented to its passing, it cannot be recognised by the courts in this country and is, therefore, unenforceable."
20. The aforesaid judgment in the case of Y. Narsimha Rao (surpa) has the complete answer to the dispute in the present case and the foreign decree in the present case being not based on a valid ground of divorce, which is recognised in Indian law and being based on a ground of divorce which is not recognised under Hindu Marriage Act, 1955, this Court is of the considered opinion that the petitioner is not entitled to seek any relief under Section 44A in view of the divorce decree obtained from New Zealand Court being contrary to Hindu Marriage Act and, therefore, violating Section 13(c) of CPC and is rendered ineffective in India.
21. Consequently, the petition fails and is dismissed.
(VIVEK JAIN) JUDGE psm Signature Not Verified Signed by: PREM SHANKAR MISHRA Signing time: 06-12-2025 16:08:40