mehnat "Did you do it for love?
Did you do it for money?
Did you do it for spite?
Did you think you had to, honey?"
— The Eagles –The Long Run
Statistical trend of 3 cases and impact of the said trend
Top of PageWe will now discuss a still emerging phenomenon –that of wives filing 3 cases against their husbands– and also try to examine its statistical aspect.
A growing trend of wives filing this number of cases combined with husbands’ habit of filing divorce cases has led to a nationwide situation in which the average number of cases in (all) litigations (taken together) between husbands and wives is now inching towards a total of 4.
Many instances wherein this total is less than 4 continue to arise fairly frequently in our courts –and we have already examined a few such situations earlier on in this write-up– but here we are talking about the average total, the current average total.
Note that there are litigations on the other side of the average (which is being hypothesised here) too. The total number of cases is more than 4 in those situations and some of them (i.e. some of those litigations) are worth looking at in detail.
But let us not get ahead of ourselves. For the moment we will limit ourselves to looking at examples of only such litigations in which 3 cases have been filed by wife against husband.
Examples of litigations consisting of 3 cases filed by wife against husband
Top of PageLet us look at a few examples of such legal attacks.
Ekta Bhatnagar vs Ashutosh Bhatnagar
Top of PageDetails of our first example of this class of matrimonial litigation can be seen in Ekta Bhatnagar vs Ashutosh Bhatnagar [1][2] (2025). Ekta Bhatnagar filed a DV complaint, a dowry case U/s 498a, 323 (Punishment for causing simple hurt), 504 and 506 of the IPC, and a petition for maintenance under CrPC Section 125 against her husband. (She followed up her maintenance petition with one more maintenance petition under the same legal provision. These two petitions are being counted as one by this writer because the objective and the end result of a pair of CrPC 125 petitions are the same as those of a single petition of the said type.) Ekta took time off between filing each case and filing each subsequent case. She filed her complaints, petitions and appeals at the rate of one fresh legal attack per year in the years 2017, 2020, 2022, and 2023. Her husband took things easy and did not bother to file a divorce petition right up till 2024.
Sandhya Ashish Lohar vs Ashish Dhansing Lohar
Top of PageIn Sandhya Ashish Lohar vs Ashish Dhansing Lohar [3] [4] (2024-2025), the wife had filed a vanilla dowry case, 1 maintenance case (under CrPC Section 125), and 1 DV complaint against her husband –a total of 3 cases. The husband had filed 1 petition for restitution of conjugal rights (commonly called an RCR petition) in Surat. The wife then filed a transfer petition in the Supreme Court to move the husband’s case from Surat to Aurangabad, whereafter the Supreme Court dissolved their marriage.
Jitender ＠ Chinku vs Babli ＠ Manvi and Another
Top of PageBabli in Jitender ＠ Chinku vs Babli ＠ Manvi and Another [5] [6] (2024-2025) was noted to have filed 3 cases against her husband. These were a maintenance petition under Section 125 CrPC, a DV complaint under Section 12 of the Protection of Women from Domestic Violence Act, and an FIR under Sections 498a / 406 / 34 IPC.
Sri Chandan Kumar Sahoo and Others vs Smt. Putul Sahoo
Top of PageSri Chandan Kumar Sahoo and Others vs Smt. Putul Sahoo [7] [8] (2018-2019) is identical to the foregoing case insofar as the number and type of cases filed by the wife against her husband is concerned. Putul Sahoo was slower than even Ekta Bhatnagar (supra). She took 8 whole years to unload her magazine. She filed her first case –being a dowry case under various sections of the IPC including Section 498a– against Chandan Kumar Sahoo in 2010. She followed it up by filing a maintenance petition under CrPC Section 125 in 2011 and a DV complaint seven years later, in 2018.
A major commonality in instances of wives filing 3 cases against their husbands
Top of PageA notable and the most important commonality in all the above examples and in innumerable litigations throughout India is that wives who file 3 cases against their husbands file 1 dowry case under IPC Section 498a, 1 DV case under PWDVA 2005, and 1 maintenance case under CrPC Section 125.
Why do wive file 3 cases against their husbands?
Top of PageNow it is time to try to understand the reason(s) for an aggrieved / disaffected wife to file 3 cases against her husband.
First off let it be clarified that usually there is no single reason why such a situation arises. But the answer is short and simple if you don’t want to understand the issue comprehensively. Wives do it because of being misguided and having ill-will against their husbands.
However if you want to know all the possible reasons behind this phenomenon, then read on.
Whenever any misguided or genuinely aggrieved wife goes to a lawyer, she is invariably informed that she can file either a suit for divorce or a dowry complaint or a DV complaint or a maintenance application –these being the four most common options in marital litigation. It is needless to say that she is also informed that she can file one, two, three, or all four cases –in any permutation of the number chosen by her– if she chooses to do so.
George Mallory famously replied to the question of why he wanted to climb Mount Everest by saying “because it’s there.” A lot of such women choose to file all 3 cases which they can file (their husbands having usually already filed a divorce case) for the rather brainless reason that an option to do so exists. Here it is worth noting that even George Mallory’s reasoning had pushed him in a foolhardy direction, as things later turned out.
A different and very large set of women do so for the main (although not the sole) reason that they can do so. This reason is less a reason and more a justification, and a poor justification at that. It is in fact one and the same as a tyrant’s justification for committing atrocities.
Another reason for wives choosing to file 3 cases is that more is almost universally considered to be merrier.
Getting into wives’ motivations for filing all the various individual cases in the mix is also worth our while. Filing criminal cases against people who they hate has various possible psychological causes, not the least of which are jealousy, greed, and a need for revenge. The last of these is usually nothing more than a perceived need. A desire for getting hold of something to do, and a similar desire for finding a direction in life are two other possible motivations in the case of unemployed women, women who suffer from psychiatric disorders, and women who are prone to substance abuse. These latter two are subconscious motivations, being motivations which are invariably not known to the person getting motivated.
Dowry cases allow women to imprison –or at the very least potentially imprison– their husbands and in-laws. They also get the opportunity to enjoy the plight of their husbands as they are forced to search for a good lawyer and to attend CAW cell dates, bail hearings, and court dates. In addition they get money when the case gets settled.
Maintenance cases hold prospects of getting regular incomes. Additional enjoyment is gained from seeing courts make people who they hate (i.e. their husbands) pay them.
DV cases allow them to torment their husbands and in-laws and to potentially get them punished by courts. A potential to start getting a regular income also exists in them. Last but not the least is the possibility of gaining control over property which exists for wives pursuing such court cases.
In sum, prospects are inviting in each of the three varieties of criminal cases. Now, some people don't give in to temptations, and some other people do. Shakespeare knew this fact, and he was not far off the mark when he wrote Hamlet’s immortal words: “Frailty, thy name is woman!” It is not surprising therefore that wives choose to take all the 3 options presented to them.
References:
Top of Page1)Ekta Bhatnagar vs Ashutosh Bhatnagar, Transfer Petition (Civil) No. 405 / 2025 (Supreme Court of India, 24 July 2025), Indiankanoon.org; Delhi; Undated; Retrieved on 08th September 2025
2)Ekta Bhatnagar vs Ashutosh Bhatnagar, Transfer Petition (Civil) No. 405 / 2025 (Supreme Court of India, 24 July 2025), sci.gov.in; Delhi; Undated; Retrieved on 08th September 2025
3) Sandhya Ashish Lohar vs Ashish Dhansing Lohar, Transfer Petition (Civil) No. 2459 / 2024 (Supreme Court of India, 12 August 2025), Indiankanoon.org; Delhi; Undated; Retrieved on 08th September 2025
4) Sandhya Ashish Lohar vs Ashish Dhansing Lohar, Transfer Petition (Civil) No. 2459 / 2024 (Supreme Court of India, 12 August 2025), sci.gov.in; Delhi; Undated; Retrieved on 08th September 2025
5)Jitender @ Chinku vs Babli @ Manvi and Another, Criminal Revision Petition 636 / 2024, 2025 DHC 3690 (Delhi High Court, 08 April 2025), Indiankanoon.org; Delhi; Undated; Retrieved on 08th September 2025
6)Jitender @ Chinku vs Babli @ Manvi and Another, Criminal Revision Petition 636 / 2024, 2025 DHC 3690 (Delhi High Court, 08 April 2025), delhihighcourt.nic.in; Delhi; Undated; Retrieved on 08th September 2025
7)Sri Chandan Kumar Sahoo and Others vs Smt. Putul Sahoo, Criminal Revision 2981 / 2018, (Calcutta High Court, 22 January 2019), Indiankanoon.org; Delhi; Undated; Retrieved on 08th September 2025
8)Sri Chandan Kumar Sahoo and Others vs Smt. Putul Sahoo, Criminal Revision 2981 / 2018, (Calcutta High Court, 22 January 2019), calcuttahighcourt.gov.in; Delhi; Undated; Retrieved on 08th September 2025