Supreme Court clarifies scope of 'aggrieved person' under Section 2(1)(d) of the Protection of Women from Domestic Violence Act, 2005

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Published 2 November 2026

Bottom Line Up Front (BLUF)

In A. Arun v. Varsha Sharma & Ors., the Supreme Court of India clarified that a mother-in-law cannot be considered an 'aggrieved person' under Section 2(1)(d) of the Protection of Women from Domestic Violence Act, 2005, to claim relief against her daughter-in-law. The Court held that the Act primarily protects women from violence perpetrated by male members or relatives of the male partner.

Ratio Decidendi · Legal Principle Established

A mother-in-law is not an 'aggrieved person' within the meaning of Section 2(1)(d) of the Protection of Women from Domestic Violence Act, 2005, for the purpose of seeking relief against her daughter-in-law. The Act is designed to protect women from domestic violence, primarily by male members or relatives of the male partner, and does not extend to claims by a mother-in-law against a daughter-in-law.

Practice & Procedural Impact for Advocates

Advocates representing mothers-in-law seeking protection orders against daughters-in-law under the PWDV Act should advise clients that such applications are not maintainable. Litigants should explore alternative legal remedies for disputes between a mother-in-law and daughter-in-law, as the PWDV Act is not the appropriate forum for the mother-in-law to claim relief as an 'aggrieved person' against the daughter-in-law.

Key Legal Takeaways

1The PWDV Act, 2005, primarily protects women from violence by male members or relatives of the male partner.
2A mother-in-law cannot be an 'aggrieved person' under Section 2(1)(d) of the PWDV Act against her daughter-in-law.
3The Act's scope is not intended to cover disputes where the mother-in-law is the complainant and the daughter-in-law is the respondent.

The Legal Issue The Supreme Court was called upon to interpret the definition of 'aggrieved person' under Section 2(1)(d) of the Protection of Women from Domestic Violence Act, 2005 (PWDV Act). Specifically, the question was whether a mother-in-law could be considered an 'aggrieved person' under this provision to seek relief against her daughter-in-law for alleged domestic violence.

Court's Reasoning The Supreme Court, in A. Arun v. Varsha Sharma & Ors., 2026 LiveLaw (SC) 1117, held that the PWDV Act was enacted to protect women from domestic violence, primarily at the hands of male members of the family or relatives of the male partner. The Court observed that the legislative intent behind Section 2(1)(d) was not to enable a mother-in-law to file a complaint against her daughter-in-law as an 'aggrieved person'. The definition of 'aggrieved person' must be read in consonance with the overall scheme and purpose of the Act, which is to provide a remedy to women who are victims of domestic violence, typically from the male side of the family or those associated with them. Allowing a mother-in-law to claim 'aggrieved person' status against a daughter-in-law would be contrary to the spirit and object of the PWDV Act.

What Follows The Supreme Court's clarification means that applications filed by mothers-in-law against their daughters-in-law under the PWDV Act, claiming to be 'aggrieved persons', are not maintainable. Such complainants will need to pursue other legal avenues available under general law for redressal of their grievances. This ruling limits the scope of the PWDV Act to its intended beneficiaries, primarily women facing violence from male family members or their female relatives.