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Mediation in Family and Matrimonial Disputes

Family Institutions

Families are found in all the diverse patterns, creeds, sizes and colours and they form the heart and soul of the human society. Talking about marriage and family, they both are perhaps society’s oldest and most resilient institutions. From the very beginning of human life, people have always grouped themselves into families to strengthen and support each other emotionally and physically and for communal support as well.

One of the most important characteristics of families is that they change and they evolve. The family structures of various communities may be different around the world but it is actually the value of a family that endures because it denotes and signifies love and affection and the support that the members of a family get from each other.

What is a Marriage? What is a Family?

Family and marriage are the key structures in most of the societies. There is a very close connection between family and marriage. They have been described in different ways by different scholars or sociologists, and there is no universally accepted meaning of the terms

Marriage and Family.

Old Definition of Family:

The old definition of family was one man and one woman are married, and their children. A grandparent might also be considered to be a part of the family. However in 1950s, an ideal family consisted of a father, a mother, and two children.

New Definition of Family:

The current definition of Family is open and inclusive as compared to the old definition. A family might consist of two parents of any gender, married or unmarried, but talking specifically about India, a family consists of two parents of opposite genders, married and having children. The children can also be adopted ones.

Definition of Marriage:

According to the general idea of various sociologists, a marriage is defined as a legally recognized legal contract between two people which implies permanence of the union of the two people getting into the social contract of marriage which is traditionally based on a sexual relationship. Other variations in the definition of marriage might include whether the spouses are of opposite sexes or same sex and how the traditional expectations or concepts are understood today.

“Sociologists are occupied with the connection between the establishment of marriage and the foundation of family on the grounds that, generally, relational unions are what make a family, and families are the most essential social unit whereupon society is manufactured. Both marriage and family make status jobs that are sanctioned by the society.”[1]

“Family Institutions are the essential, primary social units in every single human network around the world, and people living in solid families are at the center of a solid society. It works to the greatest advantage of everybody to help in making a positive domain for every person who is a part of the families. This can be a work of affection for the social foundations, for example, educational institutions, businesses, human and family service agencies, religious institutions and health organizations. Fundamentally, families make the closest social condition for the general population living in a general public.”[2]

Importance of Family Institutions

The importance of family institutions has increased several manifolds in the past few decades. The benefits of living in a family have become of utmost importance because of the pressure faced by an individual due to the various duties and obligations that he is required or expected to perform towards the fellow beings. It provides all the basic needs that are essential and are required by people living in a society. It provides for the basic needs (such as, food and shelter) of all the members of a family, even those who can’t provide for themselves or who can’t afford enough to live a comfortable life. Therefore, it serves for even the most crucial needs of humans.

After basic needs, come the security needs which are followed by the love and belonging needs. These needs are also as essential as the basic needs. The security needs of a person can range from not having the fear to live alone or suffer alone, to having an access to all the requirements including for a healthy environment to live in. Love and belonging needs arise due to the affection that a person gets from his family members. Fortunately, a healthy family can effectively provide the care and affection that is desired by anybody.

A well-functioning family also provides financial security for each and every person living in that household, irrespective of the fact whether that person earns or not. The family members who work can contribute a part of their earnings to help the family financially in order to meet everyone’s needs and prosper without any hindrance. The family members also combine their resources to pay various bills and at the same time manage their money in order to ensure that financial necessities are always taken care of. This also helps the parents in teaching their children the value of relationships and the importance of managing money so that they can contribute to thrive when they move out on their own.

Living in a family means the members do everything together ranging from having everyday meals together to going out on a vacation. This is what helps the members of a society in finding satisfaction and then they start looking for new ways to spend time together with their families which ultimately leads to a strong connection and a healthy relationship. Children living in such healthy lifestyle tend to imbibe the same moral values within themselves. They are encouraged by the habits of their elders in the family. Hence, in the long run they turn out to have a healthy lifestyle of their own even in cases of nuclear families.

Kinds of Conflicts Arising in a Family

Conflicts or disputes arise when family members have different views about something or have clash of opinions regarding something. Sometimes conflicts can also occur due to misunderstandings because of which people jump to wrong conclusions and such conflicts can lead to arguments and resentment if not resolved peacefully. Conflicts are common to all marriages and the same arise because of various disagreements.

One of the reasons for conflict in marriage can be money, which basically represents control, power and trust in a marriage. It can happen when one spouse misuses the money earned by his or her partner. In worst of cases, it can even lead to breaking of trust between the couple.

Conflicts can also be related to work. A clash of opinion may arise in case the spouses of long working hours or if both or one of them has to travel a lot for work. On top of this, if the spouses or if any one of them is not able to earn enough so as to lead a comfortable lifestyle, it may give rise to fights and clashes.

One of the most sensitive areas while dealing with conflicts or disputes arising in a family, specially, in a marital relationship, is the conflicts arising with the in-laws. Strained relationship between the spouses can also be a result of conflicts between one of the spouses with the in-laws.

“Marital conflicts can be about virtually anything. Couples complain about sources of conflict ranging from verbal and physical abusiveness to personal characteristics and behaviors. Perceived inequity in a couple's division of labor is associated with marital conflict and with a tendency for the male to withdraw in response to conflict. Conflict over power is also strongly related to marital dissatisfaction.

Spouses' reports of conflict over extramarital sex, problematic drinking, or drug use predict divorce, as do wives' reports of husbands being jealous and spending money foolishly. Greater problem severity increases the likelihood of divorce. Even though it is often not reported to be a problem by couples, violence among newlyweds is a predictor of divorce, as is psychological aggression (verbal aggression and nonverbal aggressive behaviors that are not directed at the partner's body).”[3]

Matters Relating to Family and Marital Disputes

There are many reasons that would lead to a conflict and later a dispute between a couple because of the family or children. So most of the marital conflicts arise early in the marriage because when a couple is just married they are not really tolerant of each other but when there are long term marriages a couple is usually used to each other’s habits and are more tolerant of each other. Another reason for a conflict turning into a dispute could be when both husband and wife are into two different career paths and when they do not have time for each other and they have different ambitions in life.

According to some scholars it is also believed that children can also pose a stress to the marriage while some believe that it can bring stability to a married life but the fact that expenses do rise and it does bring a huge breakthrough in a marriage. Another reason for a conflict is related to household chores.

This challenge is mostly faced by females because they are assumed to handle the age-old responsibility of taking care of the family and children, it is more of a challenge for a female because when she is earning it becomes even more difficult because she is entrusted with two responsibilities that is of taking care of the house and the children and also to take care of the work and the career they have persuade.

One of the major reasons in India for the marital conflict or even dispute to arise is when a woman is married to a man and a man is married to a woman then it is not just enough that they have married just each other but they actually get married to each other’s family too. So, in India especially there is a lot of involvement of each other’s family into the marital life which can sometimes create a problem.

Another reason that can create a problem in the marital relations is dealing with each other’s habits and addictions. For example, addiction to alcohol, smoking, television and so on, or the habit of simply coming late back home. These habits might not just give a way to a conflict but can cause disputes for the same.

The major objective of this paper is to highlight what problem a woman faces or how domestic violence is a stigma to the society but it is to see how our legal system handles the above-mentioned problems with the tool called Mediation.

History of Mediation in India

Mediation is a process of resolving disputes between parties outside the court of law. The concept of mediation/conciliation received legal recognition for the first time through the Industrial Disputes Act, 1947.

The conciliators were appointed in accordance with Section 4 of this act and they were given the duty to mediate/conciliate and promote the settlement of industrial disputes through the process of mediation so as to save the time of the court and that of the parties as well. It creates a win-win situation for both the parties to the disputes and also saves their money. The act also prescribes the detailed procedure for conciliation. The process of mediation and conciliation employs the same techniques and strategies in practice.

The idea of parties settling their disputes outside the court of law, i.e. the judiciary, was very well known and prevalent in the Ancient India as well. Specifically talking about Arbitration, it was recognized as a dispute resolution process in 1879 and it was also included in the Civil Procedure Code of 1908.

The provision for arbitration that was given under Section 89 of the Civil Procedure Code was repealed when the Arbitration Act came into force and late court-annexed ADR was reintroduced by way of amendment to CPC in 2002. Further, with the enactment of the The Legal Services Authority Act, 1987, the following duties were vested with the National Legal Services Authority as a central authority with the Chief Justice of India as its chief.
  • To encourage the settlement of disputes outside the court of law by way of negotiations, arbitration and conciliation.
  • To conduct research and surveys in the field of legal services relating to the resolution of disputes through mediation.
  • To lay down policies and principles for making legal services available for everyone.
  • To conduct legal training and educational programmes in various law colleges and other institutions with affiliation to the Bar Council of India in order to spread awareness about the process of mediation so as to help them realize that going to the courts is not the only solution in case of any disputes and that there are alternatives for the same, such as, arbitration and conciliation, i.e. mediation procedure.
  • To frame out most effective schemes for the purpose of spreading awareness about the concept of mediation.

Later, the Arbitration and Conciliation Act, 1996, made much more elaborate and effective provisions for settlement of disputes arising out of a legal relationship, whether contractual or not through arbitration and conciliation. The act provided for the commencement of the conciliation proceedings, appointment of conciliators and their duties and assistance of suitable institution for the purpose of recommending and appointing conciliators, and most importantly the conciliation settlement agreement was given the status equivalent to the degree of a civil court. The act also specified the role of conciliators in assisting the parties to the dispute to arrive at an amicable settlement.

In 1999, the Civil Procedure Code Amendment of 1999 again inserted Section 89 (which was repealed earlier) providing for reference of cases pending in the courts to Alternative Dispute Resolution methods, including the process of mediation. This amendment was enforced on July 2, 2002.

Mediation in Relation with Family and Marital Disputes

In order to protect the institution of family, disputes in the family or a marital relationship which can be repaired must be mediated and settled by sewing and patchwork rather than simply cutting off ties by going to the court of law and separating from each other. In today’s era, the concept of nuclear families prevails and such families in India are plagued by evils like forced marriages, honour killings and many more.

Mediation is the most effective alternative dispute resolution strategy in cases relating to family and matrimonial disputes. What makes this method so useful is that it focuses on non-coercive and consensual process to resolve disputes between the parties. This method not only saves time but it also diminishes the probability and possibilities of any ill feeling and estranged relationships which might come out as a result in case the parties choose to go for litigation. This is the reason why the process of Mediation has been widely accepted for resolving family disputes not only in India, but also in many foreign countries like United States, Canada and England.

Family disputes, because of their unique nature are best resolved through mediation. A family dispute is not just a matter of law and facts but it is also a matter of the feelings of the parties to the dispute. Mediation, therefore, is an alternative dispute resolution method which aims to assist two parties to a dispute to reach to an agreement which is favourable to both of them and also caters to the needs of both the disputants.

The most significant feature of this process is that the disputants themselves determine and reach to an agreement rather than some third party, unknown to both of them, imposing a decision that might not even be acceptable to both or any one of the parties. Another important feature of mediation is that the mediators use appropriate skills in order to improve the dialogue between the disputants thus aiming to help the parties reach an agreement favourable to both of them. It is the role of a mediator to help the disputants talk and negotiate in a way that it leads them to the direction of a probable solution. Mediation, like equity, was conceived as justice without law.

The third party, i.e. the mediator, facilitates negotiations between the disputants and develops an environment of comfort for both the parties so as to assist them to explore and think about each other’s point of view, thereby enabling an effective settlement to a dispute.

The mediator plays the same role in a mediation process as that of a positive catalyst in a chemical reaction, i.e. the mediator only facilitates the mediation proceedings (just like a catalyst does in a chemical reaction) without taking part in the negotiations between the parties; though he can prescribe suggestions but they are not at all binding on the disputants. His role is limited to creating a sense of comfort for the parties to open up and discuss their grievances in his presence in order to recognize the areas of difference and therefore narrow it down to acceptable limits.

According to Justice Manju Goel, the strategies to be adopted by the counsellor or the mediator in resolving family disputes are:[4]

  1. Probing of facts;
  2. Identifying the real cause of dispute;
  3. Exploration of possibilities of reconciliation or divorce;
  4. Bring the parties to an agreed solution; and
  5. Shaping the solution in the legal formats.

Advantages of Mediation in Family and Marital Disputes

The legal aspects related to resolution of family disputes through mediation is given under, “Section 5 of the Family Courts Act of 1984 provides a provision for the government to require the association of Social Welfare Organization to hold the family court to arrive at a settlement. Section 6 of the Act[5] provides for appointment of permanent counselors to effect and facilitate settlement in family matters.

Moreover, Section 9 of the Family Courts Act, 1984, Section 89 and Order XXXII-A of the Civil Procedure Code, 1908 make it obligatory on part of the court to give a fair chance to a negotiated settlement before adjudication is embarked upon. Also, Section 23 of the Hindu Marriage Act, 1955 concentrates on attempting reconciliation by the judge.”[6]

In case of family and marital disputes, it becomes very difficult for the disputants to open up in front of a third party because the conflicts might be very personal to them and they might not be comfortable enough to discuss their grievances openly. Here, it becomes the duty of the mediator to make sure that the parties to the dispute gain the confidence of the mediator and speak up about their problems of whatsoever nature.

It is the role of the mediator to elicit the facts from the point of view of both the contending parties and he would reformulate them in a clearer and expressed manner to let the parties focus on the actual troublesome areas of conflict rather than simply beating around the bush, thus giving an opportunity to the parties to come up with creative solutions which might not be possible in a third party imposed legal solution.

The mediator can also talk to the contending parties individually, without the other party being in the discussion so that the parties can clearly communicate to the mediator the areas of agreement and disagreement very clearly. Mediation with regards to matrimonial disputes is completely different from mediation in commercial or property disputes because marital disputes are very much distinct from other disputes because of the presence of certain factors such as feelings, personal liabilities, responsibilities, sentiments and the institution of marriage in particular. Irrational and emotional factors play a major and a dominant role in resolving matrimonial disputes.

The mediator must make sure that he does not, by any chance overlook the emotional aspect attached to the conflicts causing that particular dispute in question. In fact, he must be concerned about the happiness and satisfaction of both the parties because cases relating to matrimonial disputes are more a matter of sentiment than of reason or fact. He cannot simply go up to both the parties suggesting them what they can do or how can they take up the suggestions put forward by the opposite parties. His objective is very clear, which is to discover a solution to the dispute/s in question causing no damage at all or minimum damage possible to the disputants.

The mediator has to play the role of a counsellor or a conciliator in order to lead the parties to an amicably acceptable solution to the dispute/s which would bring about lasting peace between the disputants. The mediator has to advice the parties and he may also have to act diplomatically to coax the parties to focus on the positives of a proposed solution. The solution to the disputes in question can be proposed by either of the two parties or by the mediator himself/herself.

The overall job of a mediator would be to continuously bridge the gaps in the proposed solutions from both the sides in order to arrive at a consensus leading to the satisfaction of both the parties to the dispute. Taking into consideration that once the issues related to emotional and social factors are dealt with, it becomes much easier to resolve the disputes further and reach to a probable solution with the satisfaction of both the disputants. Therefore, the parties become comfortable and comparatively more stable to deal with the financial and legal issues effectively.

The process of mediation might need more than one mediator to help the parties arrive at a mutually acceptable agreement. It depends upon the kind of disputes between the parties and also the emotional and mental situation of both of them.

For example, one’s emotional or social issues are best dealt by mental health mediators such as psychiatrists and psychologists; and financial issues are best understood and dealt by specially trained mediators such as financial planners and possibly lawyers as well. However, if the couple resolves their emotional and social issues then it might lead them to a united interest in which both of them wins fairly.

At every stage of the mediation procedure, each party can take the advice and suggestions of their lawyers, thus avoiding the adversarial nature of the litigation process.

Domestic Violence and Mediation

In the ten years since the Protection of Women from Domestic Violence Act (PWDVA) came into force, around 10,00,000 domestic violence cases have been registered in India. There are many reasons as to why a woman faces domestic violence in her household, be it giving fewer dowries to in laws, or male ego or woman going outside and working against the will of her husband or the in laws.

What we have to understand here is that because there is a flow of feminism, people tend to think that not much emphasis is given to the problems that a male faces, be it even when people think that men are raped or when a man faces domestic violence. Here we are talking about the age old cruelties that a woman faces and one of them is domestic violence.
As mentioned above, there are many reasons that could get women into the complex loop of domestic violence. The biggest reason for a woman getting into this loop is less dowry.

Husband and the in laws simply expect a large amount of dowry and when their expectations are not fulfilled, they get frustrated which leads to domestic violence. Another example when men are outraged and use domestic violence as a tool to succumb their anger and frustration is when they have there is a lot professional pressure or when they tend to showcase their masculinity or when they have seen domestic violence as a culture at their homes and they even feel fine about it because they think that it showcases their superiority over women.

There are many measures taken by up law in order to avoid cases of domestic violence which the women of various countries still suffer from. To safeguard women and their rights, Indian Penal Code has a provision under Section 498A which states that if husband or any relative of the husband does any kind of cruelty against the wife, then three years of imprisonment and fine shall be imposed as a punishment on that particular person. However, the Domestic Violence Act, 2005 was enacted to safeguard the interest of the women all over India, including Jammu and Kashmir as well where it came into force from 2010.

Indian Penal Code does not provide for any provision for mediation for the criminal cases, be it cases covered in Section 498A of the Indian Penal Code whereas Section 89 of the Civil Procedure Code suggests for ADR mechanism for resolution of disputes, which has been emphasized in the case of Afcons Infrastructure and Ors. v. Cherian Varkey Construction and Ors [7]. However, in certain circumstances, in the interest of the family the courts have even referred criminal cases to mediation, which can be understood from the following cases.

Brief of Cases Encouraging Mediation in Family Disputes

  1. Ramgopal and Anr. vs. State of M.P.[8]

    In this case, certain cases which were non-compoundable in Indian Penal Code like Section 498A were to be made compoundable for the easy settlement of parties between themselves and which would also shed some burden from the shoulders of the Judiciary.

  2. B.S. Joshi & Ors. vs. State of Haryana & Anr.[9]

    In this case the court held that criminal proceedings can be quashed at the discretion of the High Court by the use of the power vested in the court according to Section 482 of Criminal Procedure Code. It was an appeal petition to the Supreme Court. The wife had lodged an FIR against the husband and later, according to her, their relationship was fine and the FIR was registered without thinking and impulsively. According to the Supreme Court, courts should encourage reconciliation especially in the matrimonial disputes of such kind.

  3. Afcons Infrastructure Ltd. vs. Varkey Construction Co. Pvt. Ltd.[10]

    This is one of the most famous cases relating to mediation. It is a landmark judgement in which the court stated that results of the mediation should be showcased to the court and when the court refers the party for mediation then reason for giving the choice of mediation shall be recorded.

  4. Manas Acharya vs. State & Anr Case[11]

    In this case the court issued an even more pro mediation approach wherein it highlighted that the settlement obtained in mediation is legal and valid and the decision taken in the mediation process is binding on both the parties.

  5. Dr. Jaya Sagade vs. The State of Maharashtra[12]

    Here the circular which was passed by the Maharashtra Government stating that a party can opt for mediation without going to the court and only the cases related to domestic violence should be first filed and then the parties can go for mediation.

  6. Salem Advocates Bar Association vs. Union of India[13]

    The original case was Salem Advocates Bar Association, Tamil Nadu. v. Union of India[14] and the abovementioned case was just an aftermath of this case. It intends to reduce burden from the judiciary by reducing number of suits filed in the court every year. This case looks upon a speedy trial and administration of justice. Various rules and regulations were drafted for the smooth functioning of alternative dispute resolution by the committee set up by the court.

Mediation in Domestic Violence Cases

One has to understand the fact that domestic violence is a serious crime and should not be taken lightly. Some people believe that the courts are at fault because of one simple criterion that they are accepting domestic violence as a crime but taking a very casual approach towards it. It has given a sense of leniency and made domestic violence sound a bit more casual and free. Domestic violence being a crime, someone who has committed the crime can easily escape from the same with the simple help of the mediation.

When it comes to cases like domestic violence the court should be careful with whatever they are doing. Therefore, if the court is recommending mediation to the parties then it has to take care of two things, that is, creating a bar for such an unacceptable behaviour and second, it has to see the social aspects as well, be it institution of family and children.

When parties approach the court there is always a win-lose situation but when it comes to mediation there is always a win-win situation for both the parties. In the mediation process the interests of both the parties are seen. And when it comes to matrimonial disputes there are a lot of emotional and social concerns that are involved. Sometimes it is just out of frustration that a party might just file FIR instantaneously or it can simply be an impulsive act that both the parties might have done.

Court has to look closely that there is a clear degree of seriousness.
Another thing that the court has to look into is that if it can see any possibility of reconciliation only then they should suggest the party for mediation and if the problem doesn’t seem like one which can be solved through mediation, then it should go on for judicial proceedings.

Globally, alternative dispute resolution is slowly and steadily becoming the preferred and prescribed mode for settling disputes outside the court of law. Even many multinational corporates including large business conglomerates are seriously looking into the advantages of settling disputes through mediation and have also started considering it as an alternative to litigation because it avoids the lengthy and expensive proceedings of the courts in India. “The multiple levels of appeal also tend to exhaust both the parties and make it a burden on the system of courts. The Indian Legislature, promoting the mediation route, has also been attempting to link the bridges so as to fall in line with the evolving global jurisprudence.”[15]

The Law Commission of India has endeavoured to bridge the gap between the diverse personal laws of various religions prevalent in India atleast in the matter of resolving disputes related to family and matrimony. Even the 129th Law Commission Report has recommended that the alternative dispute resolution methods must be made obligatory on the courts after the issues have been framed.

The different alternative dispute resolution methods that are prescribed by law are arbitration, mediation, conciliation and judicial settlement. Section 89 of the Civil Procedure Code, 1908 lays down the mechanisms and procedure for these alternative modes of dispute resolution in matters of civil nature in India.

This paper mostly focuses on the disputes arising in family matters especially in matrimonial matters. It was explained as to how, for instance, domestic violence which is a crime under Section 498A of Indian Penal Code can be mediated but at the same time it can also be so leniently handled by the courts. There was also an inclusion of adultery in the paper which was earlier a crime but now has been decriminalized by the Supreme Court of India because of its gender biasness and it is just a ground for divorce and now adultery can be taken as an account for mediation. This has only widened the scope for mediation.

Further, it was also shown how conflicts that are so small can turn into disputes and then result into taking the dispute to the court. It was also mentioned how couples who are newly married tend to be less tolerant of each other’s attitude, habits and behaviour that could be another reason for disputes between them. It was also showcased how spouses following two different career paths can also cause so many problems because of lack of time for each other, lack of communication and problems in finances. Where it is believed by some scholars that children can cause stability to married life but others believe that they can create chaos in their married life and lead to various disputes among them.

Marital disputes should be considered for mediation because mediation is a very private process, the mediator simply has to send a report to the court stating that if mediation was successful or not. There is certainly no need to mention the happenings of the mediation that occurred between the parties which means that parties can state their problems without any hesitations and work on the probable solutions.

The fact that the whole mediation process is completely confidential makes the parties to the dispute/s comfortable enough to open up and talk about their problems freely without any hesitation or without even giving it a thought that the information related to personal matters might not be dealt with sensitively. It was also observed that mediation is accepted as a tool for solving disputes internationally as well.

The social obligation of the judge deciding the matter calls for a sincere attempt to be made for reconciliation and the initial part of the mediation process must be completely devoted towards securing the relationships of whatsoever nature by way of reconciliation.

It is a well understood fact that the family mediator or the counsellor himself/herself might be attached to the parties to the dispute and cannot be totally unattached as in the case of business mediation; and therefore this process demands patience on the part of both the parties and the mediator as well. In order to arrive at a decision favourable to both the parties, the mediator can also suggest a solution and even insist upon the same by making the disputants realize how it’ll be beneficial for both of them, thus creating a win-win situation for both.

The techniques to be used by the mediator vary from case to case and situation to situation. However, once the mediator is well versed with the facts of the situation and the main problem is diagnosed it may not be very difficult to arrive at a solution. The strategy adopted by the counsellor or the mediator will entirely be his own in accordance with his own perception of the problem and the solution thereof.

  1. M.A. McIntosh, Social Institutions: Family, Religion and Education (2017)
  2. John De Frain & Jeanette Friesen, Why Are Families So Important?
  3. Fincham, Marital Conflict: Correlates, Structure and Context
  4. Justice Manju Goel, Successful Mediation in Matrimonial Disputes Approaches, Resources, Strategies & Management
  5. Civil Procedure Code, 1908 Bare Act
  6. Indian Penal Code, 1860 Bare Act
  7. FamFamily Law in India by Prof. G.C.V. Subba Rao.ily Law by Dr. Paras Diwan
  8. Family Courts Act, 1956
  9. Civil Procedure Code, 1908
  10. Indian Penal Code, 1860
  11. Arbitration and Conciliation Act, 1996
  12. SCC Online
  13. Manupatra
  14. JSTOR
  1. MAMcIntosh, Social Institutions: Family, Religion, and Education (2017),
  2. John DeFrain & Jeanette Friesen, Why Are Families So Important?, 2.
  3. Marital Conflict: Correlates, Structure, and Context, ,
  4. Justice Manju Goel, Successful Mediation in Matrimonial Disputes Approaches, Resources, Strategies & Management, 10.
  5. Family Courts Act, 1984
  6. Arbitration and its relation to family laws, Lawyersclubindia,
  7. 2010(8)SCC24
  8. (2010 ) 13 SCC 540
  9. AIR (2003) SC 1386
  10. 2010 (8) SCC 24
  11. CRL.M.C. 2090/2012 & CRL.M.A. 7236/2012, 14412/2012
  12. SOM.PIL.104/2015-DB
  13. (2005) 6 SCC 344
  14. AIR 2003 SC 189
  15. Conciliation for settling family disputes - Lakshmisri, ,

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