Sandhu v. Sandhu, 2015 Ohio 90

Parambir Sandhu (Husband) married Anna Sandhu (Wife) in India in 2009; Husband and Wife later lived in Ohio with Husband’s parents (Appellant: Mandip and Balwinder Sandhu).
Wife filed for divorce in Ohio and named Husband and his father (Dr. Mandip Sandhu) as defendants; Dr. Sandhu counterclaimed seeking return of medical/financial records and wedding jewelry.
Wife testified the wedding jewelry was given to her as gifts (before/during/after the wedding) and that she retained possession; Husband and Dr. Sandhu testified the jewelry was not intended as a gift and was returned to the parents.
At trial Wife introduced, on rebuttal, two documents concerning Indian law (Dowry Prohibition Act and Stridhan principles) and testified about Indian customs; Dr. Sandhu objected to late disclosure and hearsay.
The trial court found Dr. Sandhu not credible, concluded the jewelry had been given to Wife, and awarded the jewelry to Wife; the court also remarked Indian law would characterize the jewelry as Wife’s separate property.
Dr. Sandhu appealed, asserting (1) improper consideration of Indian law due to nondisclosure, (2) misapplication of Indian law (Dowry Act), and (3) that the gift finding was against the manifest weight of the evidence.

Issue	Plaintiff's Argument (Wife)	Defendant's Argument (Dr. Sandhu)	Held
Admissibility/use of Indian law evidence	Wife argued Indian-law exhibits rebutted Sandhu’s claim about custom and were probative; she presented them on rebuttal.	Dr. Sandhu argued Civ.R. 44.1(b) required prior notice and that the exhibits were undisclosed and hearsay.	Trial court acted within discretion to admit exhibits; appellate court found no abuse and overruled this assignment.
Whether the jewelry was an inter vivos gift (manifest weight)	Wife testified she was given and accepted the jewelry and retained possession; this supported donor intent and delivery.	Dr. Sandhu and his wife testified the jewelry was not intended as a gift and was returned to them after the wedding; contested credibility.	Appellate court upheld trial court’s finding the jewelry was a gift, deferring to credibility determinations; no manifest miscarriage of justice.
Whether the trial court misapplied Indian law (Dowry Prohibition/Stridhan)	Wife used Indian-law materials to show Indian law/custom supports Wife’s ownership and separate-property characterization.	Dr. Sandhu argued the court applied Indian law improperly to the gift/intent question and misinterpreted the statutes.	Court ruled it did not rely on Indian law to decide whether a gift occurred; Indian law was referenced only for separate-property classification; assignment overruled.

Eastley v. Volkman, 132 Ohio St.3d 328, 2012-Ohio-2179 (Ohio 2012) (standard for reviewing manifest weight of the evidence in civil cases)