Marriage of Ahuja CA6

California Court of Appeal·Decided August 24, 2026·No. H052683·Unpublished

Opinion

Filed 8/24/26 Marriage of Ahuja CA6 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SIXTH APPELLATE DISTRICT

In re the Marriage of RENAKA H052683 CHAINANI AHUJA and MUKESH (Santa Clara County AHUJA. Super. Ct. No. 16FL173747)

RENAKA CHAINANI AHUJA,

Plaintiff and Appellant,

v.

MUKESH AHUJA,

Defendant and Respondent.

This appeal concerns the division of property between former spouses. Renuka Chainani Ahuja (Chainani) and Mukesh Ahuja were married in 1999, and their divorce was finalized in 2018. However, Chainani, the wife, and Ahuja, the husband, continued to dispute how to divide their property. In 2022 an arbitrator ruled that the marital home was community property, and in 2024 the trial court issued an order after trial rejecting Chainani’s challenges to the arbitration award, ordering the home sold, and dividing the remaining property in dispute.

In this appeal, Chainani challenges both the arbitration award and the order after trial. She argues that the arbitration award should be vacated because she agreed to judicial arbitration, not contractual arbitration, and timely requested a trial de novo under

the Judicial Arbitration Act (Code Civ. Proc., § 1141.10 et seq.). She also argues that the trial court’s order should be vacated because the court abused its discretion in denying her motion to continue trial because an expert witness had become unavailable. As explained below, we reject both arguments.

Accordingly, the trial court’s order after trial is affirmed.

I. BACKGROUND

The parties separated in 2015, and Chainani filed for divorce in 2016. Spousal support was terminated the next year, and because the parties’ two sons were by then adults, there were no custody issues. However, the parties continued to dispute division of their property.

A. The Arbitration Order On September 21, 2017, the parties informed the trial court that they had reached an agreement to engage in arbitration before retired Judge Catherine Gallagher. The parties represented that they “agree to obtain the services of Judge Gallagher for binding arbitration.” They also informed the court that they had agreed that Chainani would pay Judge Gallagher’s retainer, that discovery would remain open, and that the parties would participate in a hearing for a minimum of four hours. Finally, the parties identified the issues to be arbitrated. After questioning the parties under oath, the trial court determined that they had reached a voluntary agreement, and it ordered Ahuja’s lawyer to prepare a written order.

The trial court signed the proposed written order on October 26, 2017. The arbitration order stated that “[t]he parties agree to work with Judge Gallagher (ADR, Inc.) and engage in binding arbitration . . . .” The order also stated that four issues would be arbitrated: “a. House owned during the marriage, its characterization, the issue of transmutation (grant deed related to house) per wife and related defenses or counter claims such as coercion, lack of consideration, breach of fiduciary duty by the husband. [¶] b. Sale/buy out of the house and credits/reimbursement as it relates to the house,

[¶] c. Property division, [¶] d. Stocks and their characterization.” The arbitration order stated as well that “[d]iscovery will remain open,” Chainani “will advance the fees and costs associated with binding arbitration with Judge Gallagher subject to re-allocation” and the parties will participate “for at least a 4-hour long binding arbitration session.”

B. The Contempt Proceedings Subsequently, Chainani refused to engage in arbitration, and Ahuja requested that she be found in contempt. Claiming that she believed that the parties agreed to mediation rather than arbitration, Chainani asked the court to clarify whether the parties had been ordered to mediation or arbitration. Ahuja acknowledged that there was a brief reference to mediation during September 21, 2017 hearing but said that this was a mistake that was quickly corrected, and the arbitration order clearly stated that the parties had agreed to binding arbitration, not mediation. Ahuja also asserted that the parties had agreed to judicial arbitration, and therefore Chainani “may still exercise her right to trial de novo against a ‘binding’ arbitration award.”

After a hearing, the trial court held Chainani in contempt. The court found that the parties had clearly agreed to binding arbitration rather than mediation, that Chainani willfully violated the order, and that she failed to cure the contempt. The court did not agree with Ahuja’s assertion that the parties had agreed to judicial arbitration. Instead, the court noted that “binding arbitration” is different from “ ‘judicial arbitration,’ ” that “contract arbitration . . . is binding,” and that the parties had stipulated to “binding arbitration.”

The trial court stayed imposition of sentence and gave Chainani 30 days to cure the contempt. In late 2019, the parties commenced arbitration. However, Chainani refused to pay the arbitration fees, and in January 2021 the trial court held her in contempt.

C. The Arbitration Award In February 2021, the arbitrator conducted a hearing on the first issue submitted to arbitration: the alleged transmutation of the family home into Chainani’s separate property. In March 2021 the arbitrator issued an interim award.

The arbitrator found that Ahuja had executed a deed transferring the family home to Chainani. However, this deed was executed as part of an agreement in which Ahuja was to transfer the home to Chainani in exchange for Chainani assuming the mortgage on the home and waiving her claims to Ahuja’s stock in various companies. Chainani failed to do either, and, applying the presumption of undue influence in Family Code section 721, the arbitrator concluded that the deed should be set aside.

After the interim award was issued, the parties informed the arbitrator that they lacked the funds to arbitrate the remaining issues submitted to arbitration. The arbitrator instructed Chainani’s counsel to inform the trial court of this development and inquire whether the court would like the arbitrator to convert the interim award into a partial final award. Counsel did so, and the trial court instructed JAMS to convert the interim award to a partial final award, which was done.

D. Subsequent Trial Court Proceedings In the trial court, Chainani requested a trial de novo under the Judicial Arbitration Act. She also moved to vacate the arbitration award under the California Arbitration Act (Code Civ. Proc., § 1280 et seq.). Nonetheless, the court scheduled a trial on the remaining property division issues beginning on June 10, 2024.

On May 28, 2024, approximately two weeks before the beginning of trial, Chainani moved for a continuance due to the hospitalization of a tax attorney that she had retained to provide expert testimony concerning characterization of Ahuja’s tax obligations as community property. The trial court denied the continuance, and the case proceeded to trial as scheduled.

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