This compilation indexes 12 rulings — spanning High Courts across Delhi, Jharkhand, Chhattisgarh, Madhya Pradesh, and Karnataka, as well as the Income Tax Appellate Tribunal (ITAT), Rajkot — in which Section 13(1) was cited or engaged. The cases span December 2025 to May 2026. Researchers should note that the reference "Section 13(1)" appears across multiple distinct statutes in this dataset: the Hindu Marriage Act 1955, the Commercial Courts Act 2015, the Foreign Exchange Management Act 1999, the Family Courts Act 1984, the Code of Civil Procedure, and the Income Tax Act 1961. Only one case in this set (Case 5) arises squarely in an income-tax / exemption context before ITAT. The remaining cases arise in family law, civil procedure, commercial litigation, or FEMA contexts where the same section-number notation coincidentally appears. This index is compiled for legal research professionals who need a cross-jurisdictional view of how Section 13(1) — across these statutes — has been engaged by Indian courts in this period.

Research index only. This page is a structured case-law reference tool for in-house tax teams, Big-4 associates, and law firm researchers. Nothing on this page constitutes legal advice, tax advice, or a recommendation of any course of action. Always verify against the full judgment text and check for subsequent stays, reversals, or appeals.

The statutory framework in one paragraph

The notation "Section 13(1)" appears in several Indian statutes. In the Income Tax Act, 1961, Section 13(1) sets out the circumstances in which the exemptions otherwise available to charitable or religious trusts and institutions under Sections 11 and 12 shall not apply — for instance, where income or property of the trust is applied for the benefit of specified persons, or where a trust established for a particular religious community benefits members of another community (Section 13(1)(b)). In the Hindu Marriage Act, 1955, Section 13(1) enumerates the grounds on which either party to a marriage may petition for dissolution by a decree of divorce, including cruelty and desertion. In the Commercial Courts Act, 2015, Section 13(1) provides a right of appeal from the judgment or order of a Commercial Court to the Commercial Appellate Division of the High Court. Under the Foreign Exchange Management Act, 1999, Section 13(1) relates to penalties for contraventions of the Act. Under the Family Courts Act, 1984, the appeal provisions cited alongside Section 13(1) include Section 19(1) and Section 19(4). Each case in this compilation should be read in the context of the specific statute under which Section 13(1) was engaged, as determined by the court's own framing in the source judgment.

The 12 rulings

1. Ms Vajiram And Ravi Isa Study Centre Llp vs M/S Vajirao And Reddy Institute Pvt Lted

Bench: Delhi High Court
Date: 26 May 2026
Sections engaged: 13(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal was filed before the Delhi High Court in FAO(OS) (COMM) 7/2024 arising from a dispute between two coaching institutions — 'VAJIRAM & RAVI' and 'VAJIRAO & REDDY' — both engaged in preparing candidates for the Indian Civil Services examination. Per the source preview, the appeal was filed under Order 43 Rule 1 of the Code of Civil Procedure, 1908, read with Section 13(1) of the Commercial Courts Act, 2015, and Section 10 of the Delhi High Court Act, 1966, challenging an order dated 14.09.2023. The substantive merits and final disposition are not discernible from the available source preview.

2. Sandhya Kumari vs Mithilesh Kumar

Bench: Jharkhand High Court
Date: 12 May 2026
Sections engaged: 13(1), 19(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: This First Appeal (No. 156 of 2025) was filed before the Jharkhand High Court at Ranchi under Section 19(1) of the Family Courts Act, 1984, directed against an order/judgment dated 04.01.2024 and decree signed on 12.01.2024 passed by the learned Principal Judge, Family Court, Dhanbad in Original Suit No. 837 of 2023. Per the source preview, the respondent-husband had filed suit for dissolution of marriage by decree of divorce under Section 13(1) of the Hindu Marriage Act, 1955. The final disposition of the appeal is not discernible from the available source preview.

3. Gopal Chandra Bhakat vs Smt. Rupa Rani Kumar

Bench: Jharkhand High Court
Date: 22 April 2026
Sections engaged: 13(1), 19(1), 25, 39
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (F.A. No. 90 of 2025) was filed before the Jharkhand High Court at Ranchi under Section 19(1) of the Family Courts Act, 1984, directed against a judgment dated 15.5.2024 and decree dated 22.5.2024 passed by the learned Additional Principal Judge, Additional Family Court-II, Jamshedpur, Camp Court, Ghatsila, in Original Suit No. 593 of 2017. Per the source preview, the suit was filed by the appellant and the matter engaged Section 13(1) of the Hindu Marriage Act, 1955. The substantive merits and final disposition are not discernible from the available source preview.

4. Rashmi Kumari vs Sanjay Tiwari

Bench: Chattisgarh High Court
Date: 17 April 2026
Sections engaged: 10(1)(b), 13(1), 13(1)(ia), 13(1)(ib), 13(i), 19(4)
Outcome: Outcome not specified in source
Procedural / substantive ground: This First Appeal (MAT) No. 284 of 2025 was filed before the High Court of Chhattisgarh at Bilaspur, invoking jurisdiction under Section 19(4) of the Family Courts Act, 1984. Per the source preview, the appeal was directed against an impugned judgment and decree dated 12/06/2025 passed by the learned Judge, Family Court, Manendragarh in Civil Suit No. 44A/2025, whereby an application filed by the respondent-plaintiff under Section 13(1)(ia) and (ib) of the Hindu Marriage Act, 1955 — seeking dissolution of marriage on grounds of mental cruelty and desertion — had been allowed. The final disposition of the appeal is not discernible from the available source preview.

5. Dawoodi Bohra Dargah Masjid And vs CIT(Exemption), Ahmedabad

Bench: Income Tax Appellate Tribunal - Rajkot
Date: 15 April 2026
Sections engaged: 11, 12A, 13(1), 13(1)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 63/RJT/2025) for Assessment Year 2025-26 was filed before the Income Tax Appellate Tribunal, Rajkot Bench, by the assessee Dawoodi Bohra Daragah Masjid and Qabrastan Mundra (PAN: AAATD6023G) against the CIT (Exemption), Ahmedabad. Per the source preview, the appeal was filed against a rejection order dated 23.11.2024, with a condonation of delay application noting a delay of 5 days, the assessee's stated reason being that it was not aware of the show cause notice issued by the CIT(E), Ahmedabad. The sections engaged include the exemption and trust provisions under the Income Tax Act, 1961. The substantive merits and final disposition are not discernible from the available source preview.

6. Priti Shrivastava vs Vinay Kumar Shrivastav

Bench: Chattisgarh High Court
Date: 15 April 2026
Sections engaged: 13(1), 14(1), 19(1), 2(j), 4(2), 7(1), 9(1), 9(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (FA(MAT) No. 314 of 2023) was filed before the High Court of Chhattisgarh at Bilaspur, arising out of an order dated 31-10-2023 in Civil MJC No. 7/2022 of the Judge, Family Court, Manendragarh/Camp Baikunthpur, District Koria. Per the source preview, the matter involved multiple appellants and touched upon guardianship law, with the source preview referencing the Hindu Minority and Guardianship Act, 1956, and the National Trust for Welfare of Persons with Autism, alongside the family court provisions. The substantive merits and final disposition are not discernible from the available source preview.

7. Sunita Mehta vs Special Director Enf.Dte

Bench: Delhi High Court
Date: 8 April 2026
Sections engaged: 13(1), 13(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: These appeals (MISC. APPEAL (FEMA) 2/2025, 3/2025, and 4/2025) were filed before the Delhi High Court under Section 35 of the Foreign Exchange Management Act, 1999, challenging final orders passed by the Appellate Tribunal for Foreign Exchange. Per the source preview, the appellants had earlier filed appeals under Section 19 of FEMA before the Appellate Tribunal, which were dismissed by a common order dated 31.05.2012. The matter engaged Section 13(1) of FEMA and was contested by the Special Director, Enforcement Directorate. The substantive merits and final disposition are not discernible from the available source preview.

8. Gurudwara Shri Sindh Sabha, Guna vs Rajendra Kumar And Anr

Bench: Madhya Pradesh High Court
Date: 2 April 2026
Sections engaged: 100, 12(1)(a), 12(1)(b), 13(1), 13(5)
Outcome: Outcome not specified in source
Procedural / substantive ground: This Second Appeal (No. 938 of 2005) was filed before the High Court of Madhya Pradesh at Gwalior under Section 100 of the Code of Civil Procedure, directed against a judgment and decree dated 07/03/2005 passed by the Second Additional Judge, Guna, in Civil Appeal No. 28-A/2003, as well as a judgment and decree dated 25/07/2002 passed by the Third Civil Judge, Class-I, Guna. Per the source preview, the dispute involved a Gurudwara institution and appeared to concern a tenancy/civil matter with multiple rent deposit receipts recorded in the order. The substantive merits and final disposition are not discernible from the available source preview.

9. Smt. Pramila Sahu vs Dharmendra Sahu

Bench: Chattisgarh High Court
Date: 23 March 2026
Sections engaged: 13(1), 19
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (FA(MAT) No. 331 of 2025) was filed before the High Court of Chhattisgarh at Bilaspur under Section 19 of the Family Courts Act, 1984, directed against an impugned judgment and decree dated 10.07.2025 passed by the learned 2nd Addl. Principal Judge, Family Court, Bilaspur, in Civil Suit No. 376 A/2019. Per the source preview, the Family Court had passed a decree in favour of the respondent-husband, dissolving the marriage by a decree of divorce. The substantive merits of the appellate proceedings and the final appellate disposition are not discernible from the available source preview.

10. Shri Satish vs Smt. Namrata

Bench: Chattisgarh High Court
Date: 10 March 2026
Sections engaged: 13(1), 23(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (FA(MAT) No. 298 of 2024) was filed before the High Court of Chhattisgarh at Bilaspur against the judgment and decree dated 06/07/2024 passed by the learned Judge, Family Court, Rajnandgaon, in Civil Suit No. 13A/2020. Per the source preview, the application had been preferred under Section 13(1) of the Hindu Marriage Act, 1955 for dissolution of marriage on the ground of cruelty, and the Family Court had dismissed that application. The source preview further notes that the marriage between the parties took place on 21/05/2006. The final appellate disposition is not discernible from the available source preview.

11. M/S S R Constructions vs Mohd Galib Pasha

Bench: Karnataka High Court
Date: 10 March 2026
Sections engaged: 13(1), 2(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: This writ petition (WP No. 201056 of 2026 (GM-CPC)) was filed before the Karnataka High Court, Kalaburagi Bench, under Article 227 of the Constitution of India, praying for an order/direction in the nature of certiorari to quash an order below. Per the source preview, the petitioner M/S S R Constructions, represented by its managing partner, sought relief against multiple respondents including Mohd Galib Pasha and two entities (Data Collection and Vita Collection) situated at Plot No. 98, Old Jewargi Road, Kalaburagi. The substantive merits and final disposition are not discernible from the available source preview.

12. Alok Baidya Roy vs Nibedita Badya Roy

Bench: Jharkhand High Court
Date: 10 December 2025
Sections engaged: 13(1), 19(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (F.A. No. 116 of 2016) was filed before the Jharkhand High Court at Ranchi. Per the source preview, the memo of appeal had a prolonged procedural history — it was rejected on 16.01.2017 for non-compliance with a peremptory order dated 03.01.2017; a subsequent C.M.P. No. 62 of 2017 for restoration was also dismissed on 06.09.2018 for non-compliance with a further peremptory order dated 30.08.2018. The matter engaged Section 13(1) and Section 19(1) in the family law context. The substantive merits and final appellate disposition are not discernible from the available source preview.

Patterns across these 12 rulings

Section 13(1) as a multi-statute cross-reference. A striking feature of this dataset is that the section-number "13(1)" is cited across at least four distinct statutes — the Hindu Marriage Act 1955, the Commercial Courts Act 2015, the Foreign Exchange Management Act 1999, and the Income Tax Act 1961 — alongside civil procedure provisions. Researchers using section-number search tools should filter by statute, not section number alone, to avoid cross-regime conflation.
Dominance of family law appeals. The majority of the 12 rulings in this dataset (Cases 2, 3, 4, 6, 9, 10, and 12) are matrimonial appeals before High Courts in Jharkhand, Chhattisgarh, and Jharkhand, where Section 13(1) of the Hindu Marriage Act 1955 — governing grounds of divorce — was the primary provision engaged at the trial court level, with the appellate challenge framed under the Family Courts Act.
Single income-tax / exemption ruling. Only one case in this compilation (Case 5 — Dawoodi Bohra Dargah Masjid And vs CIT(Exemption), Ahmedabad, ITAT Rajkot) directly engages Section 13(1) in an income-tax context, specifically in relation to charitable/religious trust exemption. Income-tax researchers seeking precedent on Section 13(1) of the Income Tax Act 1961 should treat this as the only directly relevant ruling in this set.
Procedural complexity and condonation of delay. At least two cases in the dataset reflect significant procedural complexity: Case 5 (ITAT) involved a condonation of delay application citing the assessee's lack of awareness of a show cause notice, and Case 12 (Jharkhand HC) had a multi-year procedural history spanning rejected appeals and failed restoration applications before the substantive matter could be reached.
Outcome data uniformly unavailable. Across all 12 cases, the outcome direction recorded in the source data is "Outcome not specified in source." Researchers must obtain and review full judgment texts from official court portals or indiankanoon.org to determine the actual operative orders, any directions given, and whether the rulings have been appealed or stayed.

How to use this compilation

This compilation is structured as a first-pass research reference to help legal and tax professionals identify relevant proceedings in which Section 13(1) was cited across Indian courts and tribunals during the 2025–2026 period. To use it effectively, researchers should begin by identifying which statute's Section 13(1) is relevant to their research question — a matrimonial case researcher, a commercial courts appellate practitioner, a FEMA specialist, and an income-tax exemption advisor will each be concerned with an entirely different statutory provision that happens to carry the same alphanumeric label. The "Sections engaged" field in each case entry records the sections as they appear in the source data and should be cross-referenced against the full judgment to confirm the operative statute.

Before relying on any ruling identified here, researchers should access the full text of the judgment from the originating court's official portal (e.g., the respective High Court website, ITAT.gov.in, or indiankanoon.org) and verify: (a) the complete operative order and directions; (b) whether the decision has been appealed to a higher forum; (c) whether any stay, reversal, or modification has been granted in subsequent proceedings; and (d) whether the ratio has been affirmed, distinguished, or overruled in later judgments. CBDT circulars, CBIC instructions, or subsequent legislative amendments may also affect the continued applicability of any statutory interpretation reflected in these rulings.

This index does not purport to be exhaustive of all Indian proceedings engaging Section 13(1) in any statute during the covered period. It reflects only cases available within the TaxNoticeAI structured corpus as at the publication date. Researchers working on critical matters — litigation strategy, regulatory compliance, or advisory opinions — should conduct independent primary-source searches across all available legal databases and official repositories before drawing conclusions.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 13(1) Case Law: 12 Indian Court Rulings (2025–2026)