Disposed¶22

Sonia Dhawan v. Manish Dhawan

Delhi HC1 Aug 2025MAT.APP.(F.C.)/276/2025

Case brief

AI extract

What is this about?

cross-examination time limit; additional opportunity to appellant's counsel (young advocate); last indulgence; cost Rs. 10,000/- Delhi High Court Bar Association; deemed conclusion of cross-examination; Section 19 Family Courts Act 1984 appeal; G.P. No. 16 of 2023; MAT.APP.(F.C.) 276/2025; CM APPL. 46516/2025 condonation of 31-day filing delay; PW-1 cross-examination.

What did the court decide?

Another (final) opportunity granted to the counsel for the Appellant to complete the cross-examination of the Respondent (PW1) within one hour on the next date of hearing (02.08.2025) before the learned Family Court, the Respondent having agreed to attend the proceedings; subject to payment of Rs. 10,000/- cost to the Delhi High Court Bar Association; failing conclusion within the hour, the cross-examination stands deemed concluded. ¶22

Sonia Dhawan Vs Manish Dhawan — Matrimonial and Divorce | Delhi HC (2025)

What the court decided

AI extract

Outcome

¶22

Issue for consideration

Whether the Appellant should be granted a further opportunity (additional time) to complete the cross-examination of the Respondent (PW-1) in G.P. No. 16 of 2023, notwithstanding that sufficient opportunities had already been afforded to her counsel.

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Court's answer

Learned counsel appearing for the Appellant had already been granted sufficient opportunities.

¶12

Ratio / Principle

Keeping in view that learned counsel for the Appellant is a young advocate, the Court granted another opportunity to the counsel for the Appellant to complete the cross-examination of the Respondent (PW1) within one hour on the next date of hearing (02.08.2025) before the learned Family Court.

¶17

Key takeaways

This is expressly declared to be the last indulgence granted to the Appellant, subject to payment of the cost of Rs. 10,000/- before the Delhi High Court Bar Association.ratio¶19
If the cross-examination is not concluded within the allotted hour, the cross-examination shall be deemed to have been concluded.ratio¶20
The cross-examination of the witnesses has to be focused and precise (general observation accompanying the imposition of the one-hour limit).

Detailed headnote1 paragraphs

Delhi HC (MAT.APP.(F.C.) 276/2025; Anil Kshetarpal & Harish Vaidyanathan Shankar, JJ.; 01.08.2025): Appeal under Section 19, Family Courts Act, 1984 against the Family Court's order dated 20.05.2025 (G.P. No. 16 of 2023) refusing two additional hours to conclude the cross-examination of the Respondent (PW-1). Acknowledging counsel had already received 'sufficient opportunities' but noting he is a young advocate, the bench granted one final hour on 02.08.2025, subject to a cost of Rs. 10,000/- payable to the Delhi High Court Bar Association; if the cross-examination is not concluded within the hour it shall be deemed concluded. Appeal, with pending applications, disposed of in these terms.

¶1

$~13

¶2

* IN THE HIGH COURT OF DELHI AT NEW DELHI

¶3

- MAT.APP.(F.C.) 276/2025 & CM APPL. 46516/2025 (For Delay of 31 days in filing appeal)

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SONIA DHAWAN .....Appellant

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Through: Mr. Kunal Madan, Mr. Ayush Srivastava & Ms. Simran Khan, Advs.

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versus

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MANISH DHAWAN .....Respondent Through: Mr. Sunil Mittal, Sr. Adv. with Ms. Seema Seth, Ms. Muskaan Deswal, Mr. Saurabh Kumar, Mr. Sanjeev Saluja & Ms. Harshita Ranjan, Advs.

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CORAM:

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HON'BLE MR. JUSTICE ANIL KSHETARPAL HON'BLE MR. JUSTICE HARISH VAIDYANATHAN SHANKAR

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O R D E R % 01.08.2025

¶11

The Appellant, by way of the present Appeal under Section 19 of the Family Courts Act, 1984, calls in question the correctness of the Order dated 20.05.2025 passed by the learned Family Court in G.P. No. 16 of 2023, wherein the learned Family Court refused to grant an additional two hours for concluding the cross-examination of the Respondent, who appeared as PW-1 therein.

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Undoubtedly, learned counsel appearing for the Appellant had been granted sufficient opportunities.

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The cross-examination of the witnesses has to be focused and

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This is a digitally signed order.

¶15

The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 02/08/2025 at 13:17:49

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precise.

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However, keeping in view the fact that learned counsel appearing for the Appellant is a young advocate, it is considered appropriate to grant another opportunity to the counsel for the Appellant to complete the cross-examination of the Respondent (PW1 therein) within one hour on the next date of hearing i.e., 02.08.2025, before the learned Family Court.

¶18

The Respondent, who has virtually joined the proceedings, has graciously agreed to attend the proceedings.

¶19

It is made clear that this will be the last indulgence granted to the Appellant, subject to a payment of the cost of Rs. 10,000/-before the Delhi High Court Bar Association.

¶20

It is further made clear that if the cross-examination is not concluded within an hour, the cross-examination shall be deemed to have been concluded.

¶21

Copy of the order to be given dasti to learned counsel appearing for the parties under the signature of the Court Master.

¶22

The present appeal, alongwith the pending application(s), if any, is disposed of in the above terms.

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ANIL KSHETARPAL, J.

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HARISH VAIDYANATHAN SHANKAR, J. AUGUST 1, 2025/ v/ va

¶25

This is a digitally signed order.

¶26

The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 02/08/2025 at 13:17:49

Sonia Dhawan v. Manish Dhawan

Case brief

What is this about?

What did the court decide?

Sonia Dhawan v. Manish Dhawan

Case brief

What is this about?

What did the court decide?

Why is it important?

What the court decided

Issues for consideration

Statutes considered

Procedural history

Parties & counsel

Coram

Case details

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