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Landmark HMA Cases — Compendium

Topic 26 | Module 2: Hindu Marriage Act, 1955 | The Legal Bridge

For Judicial Service Aspirants: RJS | DJS | PCS-J | HJS | APO

Comprehensive Study Notes with Landmark Case Laws, Mnemonics & Exam Tips

Landmark HMA Cases — Compendium

Purpose: Consolidated quick-reference compendium of foundational and modern cases under the Hindu Marriage Act, 1955.

Priority: ESSENTIAL | Exam Relevance: Use as REVISION + case law repository for all HMA questions

1. Introduction

This topic serves as a CONSOLIDATED CASE COMPENDIUM covering the landmark cases that have shaped the Hindu Marriage Act, 1955 jurisprudence. The cases are organised THEMATICALLY — grouped by the provision or doctrine they primarily interpret — allowing quick revision before examinations and ready reference during answer-writing. This is NOT a substitute for the detailed topical coverage in Topics 8-25; rather, it is a CAPSULE REVISION tool that reinforces the most important authorities.

Each case entry includes: the FULL CITATION, the LEGAL ISSUE involved, the COURT'S RATIO, and the SIGNIFICANCE for matrimonial jurisprudence. Cases are presented in a more condensed format than in the detailed topical coverage — enough to refresh memory and confirm the essential holding, without the exhaustive discussion that each case receives in the substantive topics. Students should use this compendium in conjunction with the detailed topics for thorough preparation.

The cases are organised into THEMATIC CATEGORIES corresponding to major HMA provisions and doctrines: (1) Foundational cases; (2) Monogamy and Bigamy; (3) Cruelty; (4) Void and Voidable Marriages; (5) Restitution of Conjugal Rights; (6) Mutual Consent Divorce and Irretrievable Breakdown; (7) Custody of Children; (8) Maintenance; (9) Registration and Validity of Marriage; (10) Customary Rights. This organisation allows students to see the evolution of each area of jurisprudence. The topic concludes with a TIMELINE of key amendments to HMA and a REVISION CHECKLIST of must-know cases.

2. FOUNDATIONAL CASES

⚖️ Bhaurao Shankar Lokhande v. State of Maharashtra AIR 1965 SC 1564

Ratio: ESSENTIAL CEREMONIES for a valid Hindu marriage. Supreme Court held that for a marriage to be legally valid under S.7 HMA, essential ceremonies (particularly saptapadi if claimed) must be performed. Mere informal cohabitation is not marriage. Without proof of essential ceremonies, no bigamy conviction can be sustained against a second spouse. This case is foundational for marriage validity and prosecutions for bigamy.

⚖️ Dr. N.G. Dastane v. S. Dastane AIR 1975 SC 1534

Ratio: FOUNDATIONAL on CRUELTY and STANDARD OF PROOF. Matrimonial proceedings are CIVIL — standard of proof is PREPONDERANCE OF PROBABILITIES, not beyond reasonable doubt. Cruelty may be physical or mental; mental cruelty alone sufficient. Condonation is conditional forgiveness — revives on fresh misconduct. Applies across all matrimonial grounds.

⚖️ Bipin Chander Jaisinghbhai Shah v. Prabhawati AIR 1957 SC 176

Ratio: FOUNDATIONAL on DESERTION. Classical definition: Desertion requires both FACTUM (physical separation) and ANIMUS DESERENDI (intention to desert permanently). Constructive desertion recognised — spouse whose conduct forces other to leave is the deserter. Burden of proving both elements on petitioner. Remains authoritative seven decades later.

3. MONOGAMY AND BIGAMY CASES

⚖️ Sarla Mudgal v. Union of India AIR 1995 SC 1531

Ratio: LANDMARK on CONVERSION AND BIGAMY. A Hindu husband converting to Islam to contract a second marriage cannot escape HMA's monogamy rule. First Hindu marriage SUBSISTS until dissolved under HMA. Second marriage VOID under S.11. Husband liable for BIGAMY under S.494 IPC. Court recommended Uniform Civil Code. Reaffirmed repeatedly by later decisions.

⚖️ Lily Thomas v. Union of India (2000) 6 SCC 224

Ratio: REAFFIRMED Sarla Mudgal emphatically. Conversion does NOT automatically dissolve Hindu marriage. Second marriage after conversion is bigamous. Hindu personal law protections cannot be evaded by religious conversion. Strong defence of monogamy and women's rights.

⚖️ Yamunabai Anantrao Adhav v. Anantrao Shivram Adhav AIR 1988 SC 644

Ratio: On status of SECOND WIFE. A woman married to a man whose first marriage subsists is NOT a 'wife' within HMA or S.125 CrPC. Cannot claim maintenance as wife. Strict interpretation of 'wife' — later softened by Badshah v. Urmila (2014) for deceived women.

⚖️ Badshah v. Urmila Badshah Godse (2014) 1 SCC 188

Ratio: PROGRESSIVE reinterpretation. A woman DECEIVED into marriage (unaware of man's subsisting first marriage) CAN claim maintenance under S.125 CrPC despite the marriage being void under S.11. Man cannot escape maintenance by pleading his own fraud. Protective approach.

4. CRUELTY CASES

⚖️ Shobha Rani v. Madhukar Reddy AIR 1988 SC 121

Ratio: DOWRY HARASSMENT as cruelty. Husband's passive acceptance of his family's dowry demands amounts to cruelty. Cruelty has 'inseparable nexus with human conduct' — depends on parties' milieu, circumstances, and context. Expansive interpretation.

⚖️ V. Bhagat v. D. Bhagat (1994) 1 SCC 337

Ratio: Modern DEFINITION OF MENTAL CRUELTY. 'Mental cruelty in Section 13(1)(ia) can broadly be defined as that conduct which inflicts upon the other party such mental pain and suffering as would make it not possible for that party to live with the other.' Wife's false allegations of husband's infidelity held to be mental cruelty.

⚖️ Samar Ghosh v. Jaya Ghosh (2007) 4 SCC 511

Ratio: DEFINITIVE CASE on mental cruelty. Supreme Court enumerated SIXTEEN ILLUSTRATIVE INSTANCES of mental cruelty — unilateral refusal of sexual relations, abusive language, false allegations, excessive drinking, suicide threats, false criminal cases, etc. Provides framework for analysing mental cruelty. Most-cited case on mental cruelty. MUST-KNOW for every exam.

⚖️ Narendra v. K. Meena (2016) 9 SCC 455

Ratio: IMPORTANT — Wife's insistence that husband separate from his parents without justification, combined with suicide threats, amounts to CRUELTY. Recognises Indian cultural context — parents living with son is normal. Gender-neutral application of cruelty.

⚖️ K. Srinivas Rao v. D.A. Deepa (2013) 5 SCC 226

Ratio: FALSE CRIMINAL COMPLAINTS as cruelty. Wife making false criminal complaints against husband and his family — subsequently found baseless — amounts to serious mental cruelty. Justifies divorce.

⚖️ Raj Talreja v. Kavita Talreja (2017) 14 SCC 194

Ratio: Reinforced K. Srinivas Rao. False allegations causing prosecution and reputation damage to spouse are mental cruelty. Courts should not tolerate deliberate fabrication.

⚖️ Naveen Kohli v. Neelu Kohli (2006) 4 SCC 558

Ratio: Granted divorce in EXTREME CRUELTY case — years of false cases, public humiliation, harassment. Court strongly RECOMMENDED ADDITION of IRRETRIEVABLE BREAKDOWN as statutory divorce ground. Parliament has not yet acted.

5. VOID AND VOIDABLE MARRIAGE CASES

⚖️ Revanasiddappa v. Mallikarjun (2011) 11 SCC 1 + (2023) 13 SCC 503

Ratio: LANDMARK on CHILDREN OF VOID MARRIAGES. Children entitled to share in parents' COPARCENARY PROPERTY under S.16 HMA — not just self-acquired property. Progressive expansion of protections for such children. The 2023 three-judge bench decision clarified procedural aspects. MUST-KNOW for S.16 questions.

⚖️ Digvijay Singh v. Pratap Kumari AIR 1970 SC 137

Ratio: FOUNDATIONAL on IMPOTENCE. Impotence means INCAPACITY to consummate the marriage, NOT mere refusal. Wife's willful refusal to consummate — while physically capable — is not impotence but may be mental cruelty. Critical distinction still followed.

⚖️ Mahendra v. Sushila AIR 1965 SC 364

Ratio: LANDMARK on PRE-MARITAL PREGNANCY (S.12(1)(d)). Wife pregnant by another at time of marriage, fact concealed. Husband sought annulment. Court granted. Three conditions: husband ignorant at marriage, petition within 1 year, no intercourse after discovery. Foundational case.

⚖️ R. Lakshmi Narayan v. Santhi (2001) 4 SCC 688

Ratio: LEADING CASE on MENTAL DISORDER under S.12(1)(b)/S.13(1)(iii). Mere mental weakness insufficient. Disorder must be of such severity as to genuinely unfit the person for marriage. Medical evidence essential. Strict interpretation.

⚖️ Ram Narain Gupta v. Rameshwari Gupta AIR 1988 SC 2260

Ratio: On SCHIZOPHRENIA as matrimonial ground. Mere diagnosis insufficient. Severity, impact on marital life, and treatment prospects must be considered. Courts should not stigmatise mental illness.

6. RESTITUTION OF CONJUGAL RIGHTS (RCR) CASES

⚖️ T. Sareetha v. T. Venkata Subbaiah AIR 1983 AP 356

Ratio: Andhra Pradesh HC struck down S.9 as UNCONSTITUTIONAL. Held RCR violated Articles 14, 19, 21 — treating a spouse as chattel, forcing unwilling cohabitation, violating sexual autonomy. Historical landmark, though subsequently overruled.

⚖️ Harvinder Kaur v. Harmander Singh AIR 1984 Del 66

Ratio: Delhi HC UPHELD constitutionality of S.9, disagreeing with Sareetha. Held RCR is consent-based remedy preserving marriage. Did not force physical cohabitation — only provided framework.

⚖️ Saroj Rani v. Sudarshan Kumar AIR 1984 SC 1562

Ratio: SUPREME COURT UPHELD constitutionality of S.9. RCR is reasonable marital remedy. Either party can use S.13(1A)(ii) after 1 year non-compliance. This is the DEFINITIVE ruling on RCR constitutionality. Settles the Sareetha-Harvinder Kaur conflict in favour of constitutionality.

7. MUTUAL CONSENT AND IRRETRIEVABLE BREAKDOWN CASES

⚖️ Sureshta Devi v. Om Prakash AIR 1992 SC 1904

Ratio: LANDMARK on S.13B MUTUAL CONSENT DIVORCE. Consent must be CONTINUING — must exist at both motions. Either party can WITHDRAW consent before decree. 'Living separately' means not as husband and wife (not just physical). Foundational principles of mutual consent divorce.

⚖️ Amardeep Singh v. Harveen Kaur (2017) 8 SCC 746

Ratio: LANDMARK on WAIVER OF 6-MONTH COOLING-OFF. S.13B(2) period is DIRECTORY, not mandatory. Waivable when: long separation (1.5+ years), all settlements made, reconciliation efforts failed. Significantly facilitated faster mutual consent divorces.

⚖️ Shilpa Sailesh v. Varun Sreenivasan 2023 SCC OnLine SC 544 (5-J Bench)

Ratio: MOST RECENT LANDMARK. Constitution Bench held: SC can grant DIVORCE under ARTICLE 142 on grounds of IRRETRIEVABLE BREAKDOWN even without S.13B petition. SC can waive 6-month period. Most important recent development on matrimonial dissolution. MUST-KNOW.

⚖️ Smruti Pahariya v. Sanjay Pahariya (2009) 13 SCC 338

Ratio: Reaffirmed Sureshta Devi — withdrawal of consent before decree defeats S.13B petition. Court cannot grant divorce despite withdrawal.

⚖️ Hitesh Bhatnagar v. Deepa Bhatnagar (2011) 5 SCC 234

Ratio: Continued consent is MANDATORY at second motion. Even if one party's withdrawal seems unreasonable, court cannot grant S.13B divorce without that consent.

8. CUSTODY CASES

⚖️ Gaurav Nagpal v. Sumedha Nagpal (2009) 1 SCC 42

Ratio: LANDMARK modern custody case. Welfare of child is PARAMOUNT consideration. Overrides parental rights, personal law, custom. Tender years preference for mother exists but not absolute. Holistic welfare assessment required.

⚖️ Githa Hariharan v. Reserve Bank of India (1999) 2 SCC 228

Ratio: LANDMARK on NATURAL GUARDIANSHIP. 'After him' in S.6(a) HMGA includes father's ABSENCE — not only death. Mother can be natural guardian during father's lifetime where father is absent. Progressive interpretation promoting gender equality.

⚖️ Roxann Sharma v. Arun Sharma (2015) 8 SCC 318

Ratio: INTERNATIONAL custody disputes. Principles of 'comity of courts' and child welfare. India not Hague Convention signatory — case-by-case welfare approach with foreign orders as one factor.

⚖️ Lahari Sakhamuri v. Sobhan Kodali (2019) 7 SCC 311

Ratio: Custody across jurisdictions. Paramount consideration remains welfare. Child's views relevant at age of understanding.

9. MAINTENANCE CASES

⚖️ Rajnesh v. Neha (2021) 2 SCC 324

Ratio: LANDMARK COMPREHENSIVE GUIDELINES for maintenance across ALL statutes (HMA, HAMA, S.125 CrPC, DV Act). Standardised affidavit formats, calculation criteria, avoiding duplication, prompt disposal norms. Most important recent case on maintenance. MUST-KNOW.

⚖️ Kalyan Dey Chowdhury v. Rita Dey Chowdhury (2017) 14 SCC 200

Ratio: Indicative norm — 25% of respondent's NET INCOME as reasonable maintenance where appropriate. Not strict rule but useful benchmark. Applied as factor among others.

⚖️ Chaturbhuj v. Sita Bai (2008) 2 SCC 316

Ratio: Principles for maintenance quantum. Courts consider capacity to earn, not just actual earnings. Pragmatic approach. Applied across statutes.

⚖️ Vanamala v. H.M. Ranganatha Bhatta (1995) 5 SCC 299

Ratio: Divorced wife can claim PERMANENT ALIMONY under S.25 HMA even after divorce. Decree of divorce does not extinguish maintenance rights. S.25 allows application at or after decree.

10. REGISTRATION AND VALIDITY CASES

⚖️ Seema v. Ashwani Kumar (2006) 2 SCC 578

Ratio: LANDMARK on REGISTRATION of marriages. SC directed ALL STATES to make marriage registration COMPULSORY. Useful for: proving marriage, preventing child marriages, protecting women's rights, preventing bigamy. States have progressively implemented this through legislation and executive action.

⚖️ S. Nagalingam v. Sivagami (2001) 7 SCC 487

Ratio: For bigamy conviction, essential ceremonies of SECOND marriage must be proved. Without proof of essential ceremonies, cohabitation alone does not constitute 'marriage' for S.494 IPC purposes. Often the sticking point in bigamy prosecutions.

11. CUSTOMARY RIGHTS CASES

⚖️ Collector of Madura v. Mootoo Ramalinga (1868) 12 MIA 397 (Privy Council)

Ratio: FOUNDATIONAL (pre-HMA but influential). For custom to override general Hindu law, it must be: (1) ANCIENT; (2) CERTAIN; (3) CONTINUOUS; (4) REASONABLE; (5) NOT AGAINST PUBLIC POLICY. Remains authoritative test for customary law claims under Hindu law.

12. OTHER IMPORTANT CASES

⚖️ Hirachand Srinivas Managaonkar v. Sunanda (2001) 4 SCC 125

Ratio: S.13(1A) and S.23(1)(a). A spouse guilty of cruelty or adultery cannot obtain divorce under S.13(1A) by delaying reconciliation. Own wrongdoing obstructing reconciliation bars relief.

⚖️ Chetan Das v. Kamla Devi (2001) 4 SCC 250

Ratio: On MANDATORY RECONCILIATION under S.23(2). Courts must genuinely attempt reconciliation — not mere formality. But in extreme cases where reconciliation clearly impossible, formal minimum attempt sufficient.

⚖️ Dharmendra Kumar v. Usha Kumari AIR 1977 SC 2213

Ratio: On S.23(1)(a) — 'TAKING ADVANTAGE OF OWN WRONG.' Mere non-compliance with RCR decree is insufficient to bar divorce under S.13(1A). Positive misconduct required.

⚖️ Ashok Hurra v. Rupa Bipin Zaveri (1997) 4 SCC 226

Ratio: On mutual consent divorce and genuineness of consent under S.23(1)(bb). Consent must be free from coercion, fraud, undue influence. Any indication of pressure invalidates consent.

⚖️ Savitri Pandey v. Prem Chandra Pandey AIR 2002 SC 591

Ratio: Modern landmark on desertion. Desertion means intentional permanent abandonment without consent and reasonable cause. Both factum and animus must continue throughout the statutory period.

13. TIMELINE OF KEY HMA AMENDMENTS

14. THEMATIC SUMMARY — HOW CASES HAVE SHAPED HMA JURISPRUDENCE

14.1 Expanding Women's Rights

• Githa Hariharan (1999) — mother as natural guardian
• 2003 Amendment + Sundarajan line — wife's jurisdiction options
• Badshah v. Urmila (2014) — deceived second wife protected
• Rajnesh v. Neha (2021) — standardised maintenance framework
• Revanasiddappa (2011, 2023) — children's property rights

14.2 Modernising Matrimonial Law

• Dastane (1975) — civil standard of proof
• Samar Ghosh (2007) — comprehensive mental cruelty framework
• Amardeep Singh (2017) — waivable cooling-off period
• Shilpa Sailesh (2023) — Article 142 irretrievable breakdown

14.3 Defending Monogamy

• Sarla Mudgal (1995) — against conversion-based bigamy
• Lily Thomas (2000) — reaffirmed Sarla Mudgal
• Yamunabai (1988) — strict interpretation of 'wife'

14.4 Child Welfare Emphasis

• Gaurav Nagpal (2009) — welfare paramount
• Githa Hariharan (1999) — mother as guardian in father's absence
• Roxann Sharma (2015) — international custody
• Revanasiddappa (2023) — inheritance rights

15. MUST-KNOW CASE CHECKLIST

For judicial services examinations, candidates MUST know the following cases — these are the most heavily tested and cited authorities. Commit the case name, citation year, and ESSENTIAL RATIO to memory:

15.1 Top 10 Cases

1. Dastane v. Dastane (1975): Civil standard of proof; cruelty definition; condonation.
2. Bipin Chander v. Prabhawati (1957): Desertion — factum + animus.
3. Sarla Mudgal (1995) + Lily Thomas (2000): Conversion does not dissolve Hindu marriage.
4. Samar Ghosh (2007): Sixteen illustrations of mental cruelty.
5. Sureshta Devi (1992): Continuing consent in S.13B.
6. Amardeep Singh (2017): Waiver of cooling-off period.
7. Shilpa Sailesh (2023): Article 142 irretrievable breakdown divorce.
8. Saroj Rani (1984): S.9 RCR constitutional.
9. Rajnesh v. Neha (2021): Maintenance guidelines.
10. Gaurav Nagpal (2009): Welfare of child paramount.

15.2 Next 10 Cases

1. Digvijay Singh v. Pratap Kumari (1970): Impotence — incapacity vs. refusal.
2. Mahendra v. Sushila (1965): Pre-marital pregnancy annulment.
3. Bhaurao Lokhande (1965): Essential ceremonies.
4. Yamunabai (1988): Second wife cannot claim as 'wife'.
5. Badshah v. Urmila (2014): Deceived second wife exception.
6. Githa Hariharan (1999): 'After him' includes father's absence.
7. Revanasiddappa (2011, 2023): Children of void marriages inherit coparcenary property.
8. Seema v. Ashwani Kumar (2006): Compulsory registration of marriages.
9. V. Bhagat (1994): Mental cruelty definition.
10. Narendra v. K. Meena (2016): Wife's separation from in-laws insistence as cruelty.

16. REVISION STRATEGY FOR CASE LAW

16.1 How to Approach Case Law

• Memorise in categories: Group cases by topic (cruelty, desertion, maintenance, etc.) — easier to recall under exam pressure.
• Know the essential ratio: Not detailed facts, but the LEGAL PRINCIPLE the case establishes.
• Citation and year: Correct citation adds credibility — at minimum know the year and court.
• Link with statutory provision: Connect each case to the relevant HMA section.
• Know the EVOLUTION: Many areas have evolution of case law — Sareetha → Harvinder Kaur → Saroj Rani; or Yamunabai → Badshah.

16.2 How to Cite in Answers

When writing answers in examinations:

1. Introduce the principle first, then cite the case: 'The Supreme Court has held that cruelty includes both physical and mental forms [Dr. N.G. Dastane v. S. Dastane, AIR 1975 SC 1534].'
2. For essay questions, cite 3-5 cases per topic to show depth.
3. Mention the court level (SC, HC) for authority.
4. If uncertain of exact citation, still mention case name.
5. Recent Supreme Court cases carry particular weight — always mention year for post-2015 cases (shows currency).

16.3 Writing Technique

In essay answers, case law can be woven in several ways:

• Leading with a case: 'The landmark case of Samar Ghosh v. Jaya Ghosh (2007) 4 SCC 511 laid down sixteen illustrations of mental cruelty...'
• Supporting a statement: 'Mental cruelty is an independent ground for divorce [V. Bhagat (1994)]...'
• Comparing cases: 'Earlier in Yamunabai (1988), the Court held... but later in Badshah (2014), a more protective approach was adopted...'
• Showing evolution: 'The constitutional challenge to S.9 arose in Sareetha (1983 AP), was rejected in Harvinder Kaur (1984 Del), and conclusively settled in Saroj Rani (1984 SC).'

17. PRACTICE QUESTIONS ON CASE LAW

Q1: Discuss the evolution of the concept of mental cruelty as a ground for divorce, tracing the journey from Dastane through V. Bhagat to Samar Ghosh.

Q2: Critically analyse the Sarla Mudgal-Lily Thomas line of decisions on conversion and monogamy. What is their continuing relevance?

Q3: Explain the evolution of mutual consent divorce jurisprudence from Sureshta Devi through Amardeep Singh to Shilpa Sailesh. What principles have emerged?

Q4: Trace the constitutional debate over Section 9 HMA from T. Sareetha through Harvinder Kaur to Saroj Rani. How was the matter finally settled?

Q5: Discuss the Supreme Court's approach to 'welfare of child' in custody matters. Analyse the ratios in Gaurav Nagpal, Githa Hariharan, and Roxann Sharma.

Q6: Examine the evolution of maintenance jurisprudence culminating in Rajnesh v. Neha (2021). How has the Supreme Court rationalised the law?

Q7: 'Children of void marriages are legitimate under Section 16 HMA and entitled to a share in parents' coparcenary property.' Discuss with reference to Revanasiddappa v. Mallikarjun.

18. CONCLUSION

The cases in this compendium represent seven decades of judicial evolution under the Hindu Marriage Act, 1955. From the foundational decisions of the 1950s-70s (Bhaurao Lokhande, Bipin Chander, Dastane, Mahendra v. Sushila) to the progressive modern judgments (Shilpa Sailesh, Rajnesh v. Neha, Revanasiddappa), Indian courts have continuously refined, liberalised, and modernised matrimonial law.

Key trends visible across this jurisprudence include: (1) Progressive EXPANSION OF WOMEN'S RIGHTS — from strict interpretations to protective reinterpretations; (2) Shift from STRICT FAULT THEORY toward recognition of BREAKDOWN and BILATERAL responsibility; (3) Emphasis on CHILD WELFARE as paramount in custody matters; (4) SYSTEMATISATION of maintenance principles through Rajnesh; (5) Development of IRRETRIEVABLE BREAKDOWN doctrine through Article 142 in absence of legislative action; (6) Gender-neutral application of gender-specific provisions in appropriate cases.

For the serious student of Hindu matrimonial law, mastery of these cases is essential. They provide not only authority for specific propositions but also illuminate the BROADER EVOLUTION of the law and its CONTINUING DEVELOPMENT. As new issues arise — surrogacy, LGBTQ+ rights, technology-facilitated relationships, international dimensions — the principles established in these landmark cases will continue to provide the foundation for judicial reasoning.

🎯 EXAM TIP

Final revision tips: (1) Master the TOP 10 cases thoroughly; (2) Know citation + year + one-line ratio for next 10-20 cases; (3) Understand the EVOLUTION and CATEGORISATION of cases; (4) Always link cases to statutory provisions; (5) Cite 3-5 cases per essay question; (6) Emphasise RECENT cases (post-2015) — shows currency; (7) Don't just memorise — understand the principles.

✨ Revision Checklist

Before the exam, go through this compendium once to refresh: (a) Foundational cases — Dastane, Bipin Chander, Bhaurao Lokhande; (b) Recent Supreme Court landmarks — Samar Ghosh, Gaurav Nagpal, Amardeep Singh, Rajnesh v. Neha, Shilpa Sailesh, Revanasiddappa; (c) Category leaders — Sarla Mudgal (conversion), V. Bhagat (mental cruelty), Saroj Rani (RCR constitutionality), Githa Hariharan (guardianship). Master these and you'll be well-prepared for any case law question on HMA.