In Srinwati Mukherji v. State of Maharashtra, the Bombay High Court on July 4, 2025, ruled that an under-construction flat, where neither spouse has ever resided, does not qualify as a “shared household” under Section 2(s) of the Protection of Women from Domestic Violence Act, 2005. The wife sought relief under Sections 19(d) and 19(e), requesting the husband to pay pending instalments for a ₹3.52 crore flat in Malad West, Mumbai. However, the Court held that a “shared household” requires actual residence by either party at some point. Since the flat was still under construction and uninhabited, it did not meet the statutory requirement. The Court dismissed the petition, clarifying that the DV Act is a welfare statute intended to prevent dispossession from existing residences, not to enforce obligations related to incomplete property transactions or compel financial contributions toward future homes.