Sharan Srinivasan, Vijay Gupta, Harsha Honnappa
The variational formulation of nonlinear filtering due to Mitter and Newton characterizes the filtering distribution as the unique minimizer of a free energy functional involving the relative entropy with respect to the prior and an expected energy. This formulation rests on an absolute continuity condition between the joint path measure and a product reference measure. We prove that this condition necessarily fails whenever the signal and observation diffusions share a common noise source. Specifically we show that the joint and product measures are mutually singular, so no choice of reference measure can salvage the formulation. We then introduce a conditional variational principle that replaces the prior with a reference measure that preserves the noise correlation structure. This generalization recovers the Mitter--Newton formulation as a special case when the noises are independent, and yields an explicit free energy characterization of the filter in the linear correlated-noise setting.