Shreya Gupta
On March 6, 2025, the Indore Bench of the Madhya Pradesh High Court, while granting divorce to a woman, held that compelling a wife to discontinue her studies or placing her in a position where she is unable to continue her education amounts to mental cruelty. The court ruled that such an act constitutes a valid ground for divorce under Section 13(1)(ia) of the Hindu Marriage Act, 1955. It observed that the Family Court had failed to recognize that the woman was not taking advantage of her own fault but was rather sacrificing her dreams and career due to marital obligations. The court referred to the Supreme Court’s decision in Mohini Jain vs. State of Karnataka & Others (1992), which recognized that education is an essential facet of life and is considered an integral part of the right to life under Article 21 of the Constitution of India. This acknowledgment reinforced that access to education is crucial for living a life with dignity.
A Division-Bench comprising Justice Vivek Rusia and Justice Gajendra Singh stated that forcing a wife to discontinue her studies or creating an atmosphere where she is unable to pursue her education is equivalent to destroying her dreams at the very beginning of her marital life. Additionally, compelling her to live with a person who is neither educated nor willing to improve himself amounts to mental cruelty, thereby justifying divorce under Section 13(1)(ia) of the Hindu Marriage Act, 1955. The court criticized the findings of the Principal Judge, Family Court, Shajapur, in RCS HM No.62/2016, stating that the trial court erred in concluding that the wife was withdrawing from the husband’s company without reasonable cause. Instead, the High Court found that the wife’s withdrawal from the marriage was justified due to the cruelty inflicted upon her. Consequently, the trial court’s findings on issues No. 1 & 2 were set aside, and it was held that the husband had indeed subjected the wife to mental cruelty, giving her a valid reason to live separately.
The case arose from an appeal filed by the wife against a judgment that had dismissed her divorce petition based on cruelty under Section 13(1)(ia) of the Hindu Marriage Act, 1955, while simultaneously granting the husband’s petition for restitution of conjugal rights under Section 9 of the Act. The marriage between the appellant and the respondent was solemnized in 2015. At the time, the wife had passed her 12th standard examination and expressed her desire to continue her education, to which her parents and in-laws had initially agreed. She was taken to her matrimonial home for two days with the assurance that she would be allowed to return to her maternal home. However, when she later requested to return, her in-laws informed her that she could not continue her studies and was required to reside at her matrimonial home.
During her brief stay in her matrimonial home, the petitioner was subjected to harassment due to dowry demands. Additionally, she alleged that she was forced into unnatural sexual intercourse and that her life was endangered by her husband’s excessive drinking. As a result, she filed a case under the Protection of Women from Domestic Violence Act, 2005, along with a petition for divorce on the ground of cruelty. In response, the husband and his family denied these allegations, asserting that they had no objections to her continuing her studies. They claimed to have even borne the expenses for her B.Sc. course and assured her that they would support her further education.
Despite these claims, the Principal Judge of the Family Court concluded that the wife had withdrawn from the marital relationship without a reasonable excuse. The court, therefore, dismissed her divorce petition and allowed the husband’s plea for restitution of conjugal rights. Upon re-examining the evidence, however, the High Court found that the husband was uneducated, only capable of signing his name, while the wife, having completed her 12th standard, aspired to pursue higher education. It was also noted that, contrary to his claims, the husband admitted that he did not pay for her studies. The court further observed that upon her first arrival at the matrimonial home, the husband took her on a trip along with his relatives for 2-3 days, failing to maintain the privacy of the newly married couple. The wife’s allegations of unwelcoming behavior from her husband during the trip were also taken into account.
The court noted that for nearly 10 years since the marriage in 2015, the couple had only lived together for three days in July 2016. The wife’s experience during this brief period was described as a nightmare, and they had not been in each other’s company since. The court quoted American philosopher John Dewey, who stated that “Education is not just about preparing for life, but it is life itself.” Based on this, the court concluded that the case represented an irretrievable breakdown of marriage. Given that the couple had been living separately since July 2016, the court determined that there was no possibility of reconciliation. Consequently, the Family Court’s order was set aside, and the marriage between the appellant and respondent was dissolved on the ground of mental cruelty under Section 13(1)(ia) of the Hindu Marriage Act, 1955.
Case Title: XXX v. YYY
Case Number: First Appeal No. 388 of 2020
Bench: Justice Vivek Rusia and Justice Gajendra Singh
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