In which case, the Supreme Court has exhorted the Union of India to seriously consider and amend the…

Naveen Kohli expressly recommended that the Union consider amending the HMA to incorporate irretrievable breakdown as a divorce ground. The recommendation and its relief on the facts must be distinguished from Parliament having enacted that general ground.

Current law: Shilpa Sailesh (2023) confirms the Supreme Court’s discretionary Article 142 power in suitable irretrievable-breakdown cases. That power does not convert the 2006 recommendation into a general statutory ground for ordinary matrimonial courts.