Matrimonial disputes rarely remain confined to the relationship between two spouses. Once a marriage breaks down, the dispute may enter several legal forums simultaneously. In the process, the circle of persons involved may also expand from parents to siblings and other relatives of the husband may find themselves named as accused in criminal proceedings alleging cruelty, dowry harassment, intimidation or other offences.

The same is what I came across during my internship at the chambers, several matrimonial matters where the same parties appeared before the courts in multiple proceedings arising out of the same underlying matrimonial dispute. What initially appeared to be one disagreement between a husband and wife often extended into criminal complaints, domestic violence proceedings, maintenance claims and other connected litigation. In several matters, the involvement of other members of the matrimonial family also became a recurring feature.

This practical exposure made me curious about how a matrimonial dispute can gradually develope into what may be described as a ‘matrimonial bouquet’.

The expression ‘matrimonial bouquet’ is not a statutory or technical legal term. It is a judicial expression used by the Supreme Court to describe a collection of proceedings that may be initiated against a spouse and his or her family members after matrimonial relations get messy.

The Supreme Court observed that such a ‘bouquet’ may include allegations relating to:

1. dowry demands;
2. cruelty;
3. harassment by in-laws;
4. domestic violence; and
5. other criminal allegations arising from the matrimonial relationship.

The Court was particularly concerned where family members are joined in through vague and omnibus allegations, without specific particulars concerning the role allegedly played by them.

The concern arises when criminal law is allegedly transformed from a means of obtaining justice into a tool for revenge, harassment or coercive settlement. For example, the necessary proceedings under the Protection of Women from Domestic Violence Act, 2005, maintenance proceedings and matrimonial litigation following a simple case of dissolution of marriage.

In ‘Ishwar Chand Sharma and Ors. vs. State of Uttar Pradesh and Ors. (29.05.2026 – SC) : MANU/SC/0600/2026’ the Supreme Court cautioned against the proliferation of frivolous and vexatious proceedings in matrimonial disputes, describing the resulting multiplicity of allegations as a “matrimonial bouquet.” The Court emphasised that such litigation can turn matrimonial discord into a prolonged battle, drawing family members into the conflict and undermining the very possibility of reconciliation and harmony-

“One particular offshoot or a species of vexatious and frivolous litigation is in family disputes, particularly, a ‘matrimonial bouquet’ that is presented by the estranged wife against the husband and his family out of personal animosity and spite once the relationship turns sour and rancorous and vice versa. This ‘matrimonial bouquet’ often includes claims of dowry demands; cruelty under 498A Indian Penal Code; harassment by in-laws and domestic violence, made by the complainant against her spouse and in-laws. This set of cases frequently include bogus and empty allegations and false claims of harassment, cruelty and marital hardships that, more often than not, contain little to no substance at all and are usually not backed by any material or other documentary evidence. A tell-tale sign of such vexatious cases is that often they contain vague and sweeping general allegations that are not specific in nature but rather are aimed at arraying several family members if not all of the spouse’s family, including those who are old and ailing, as Accused and consequently cast the prosecution net as wide as possible by invoking multiple provisions of law by using general, vague and omnibus allegations that are not backed either by fact or law. We say so while being mindful of the fact that although any complaint or a FIR is not an encyclopaedia of evidence and factual circumstances so as to contain all details of the alleged incident, by no means can it be a general conglomeration of statements made by the disgruntled spouse with a mala fide intent, containing little or no details of the alleged criminal acts that often lack a chronology of events. Further, sweeping allegations and vexatious claims often fail to highlight and elaborate upon how the alleged acts happened, the manner in which such acts were undertaken, the aftermath of such incidents etc.”

The question that arises is how such a bouquet of multiple litigation harms the essence of the Indian Litigation system and society created through marital ties- 

1.  Undermining the soul of marriage- Marriage, at its core, is built on trust, companionship, mutual respect, forgiveness and a shared life. These are relational values. They require spouses to be able to communicate privately, disagree without fear, compromise and, where possible, forgive. The ‘matrimonial bouquet’ represents almost the opposite dynamic. When a matrimonial dispute produces a collection of FIRs, domestic violence proceedings, maintenance claims, divorce proceedings, complaints against relatives and other connected litigation, the spouse ceases to be experienced as a companion and begins to be experienced as an adversary.
2. Dragging of families in the disputes- When a matrimonial litigation turns criminal it starts dragging the family of the opposite spouse in it. This leads to the members of a family facing social repercussions, specially aged parents, like social embarrassment, reputational damage within their community, strained relationships with relatives and neighbours, anxiety about appearing before courts, financial expenditure on legal representation and a sense of humiliation at being treated as offenders in a dispute concerning their children’s marriage.
3. Effect on children- A marriage is not just a social contract between two individuals, rather a meeting of two families. A failed marriage doesn’t only affect the individuals but everyone tied with them. The conflict passes on to the children which can make them avoidant, short- tempered and may cause psychological problems. Harvard Study of 03.12.2025 shows- (https://www.christinewaltercoaching.com/post/how-marriage-affects-your-childs-mental-health)–

187% higher risk of clinical anxiety from emotionally distant parents (no yelling required), 127% higher risk of major depression by age 18, 42% of teen behavioral disorders traced directly to marital tension observed at age 3 and Children of unhappily married parents are 3× more likely to need psychiatric medication by age 25

1. Over-burdened Judiciary- A matrimonial bouquet doesn’t only burden the person but also the judiciary that has to apply unnecessary time in these frivolous allegations. Every unnecessary proceeding includes not only the judicial time but the time of investigation that has no outcome, resources of the defendant, resources of the court, etc. that could have been easily used for the necessary disposal of genuine cases.
2. Makes your genuine case harder to identify- A list of disputes not only makes your genuine dispute hide in the limelight of vague proceedings also, when courts repeatedly encounter exaggerated or omnibus allegations, there is a danger that genuine complaints may also be approached with unnecessary suspicion.
3. Arm twisting through criminal proceedings – The essence of litigation and the justice system fails when there is a pressure of criminal proceedings, the societal aspects discussed above and the fear of investigation leads to settlement due to undue pressure by the prosecution. The Court observed that the proliferation of false and frivolous cases does not merely cause harassment to the accused. It also burdens the judicial system and diverts judicial resources from genuine cases requiring urgent attention. 

In ‘Preeti Gupta and Ors. vs. State of Jharkhand and Ors. (13.08.2010 – SC) : MANU/SC/0592/2010’ the Supreme Court cautioned against allowing matrimonial discord to proliferate into multiple criminal proceedings based on exaggerated or omnibus allegations. The Court emphasised that such litigation can transform a dispute between spouses into a wider conflict involving their families, thereby aggravating rather than resolving matrimonial discord-

Para 34. Before parting with this case, we would like to observe that a serious relook of the entire provision is warranted by the legislation. It is also a matter of common knowledge that exaggerated versions of the incident are reflected in a large number of complaints. The tendency of over implication is also reflected in a very large number of cases.

Para 35. The criminal trials lead to immense suffering for all concerned. Even ultimate acquittal in the trial may also not be able to wipe out the deep scars of suffering of ignominy. Unfortunately a large number of these complaints have not only flooded the courts but also have led to enormous social unrest affecting peace, harmony and happiness of the society.

The tragedy of the matrimonial bouquet is that the damage rarely stops at the marriage. Parents who once tried to bring the couple together may find themselves standing on opposite sides of a courtroom, siblings become witnesses instead of family and children grow up hearing two different versions of their own home. A dispute that began between two people slowly turns into a battle that leaves an entire family fractured. 

Conclusion

The above observations must not be understood as suggesting that every matrimonial complaint involving multiple legal proceedings is false. The Court expressly recognised that genuine cases of matrimonial oppression and offences against women require immediate judicial attention. The concern arises where the legal process itself becomes an instrument of retaliation

The real danger of the matrimonial bouquet is not its multiplicity alone. It is the transformation it produces. A marriage, which begins as a relationship of trust, companionship and shared life, is gradually reconstructed as a series of causes of action. The spouse becomes an opposing party; a disagreement becomes an allegation; an allegation becomes a pleading; a private conversation becomes evidence; and family members become accused or witnesses. What was once a relationship is reduced to a record of grievances. In that sense, prolonged matrimonial litigation does more than adjudicate the death of a marriage, it can become an instrument through which the remaining substance of that marriage is extinguished. 

About the author-

Authored by Vani Gupta, Fourth Year Law Student at Maharaja Agrasen Institute of Management Studies and Intern at Chambers of Manasi Bhushan.