Forcing her to live with a person who is neither educated nor eager to improve himself certainly amounts to mental cruelty, it ruled.
The Madhya Pradesh High Court on Thursday held that forcing a wife to abandon her studies amounts to mental cruelty, making it a valid ground for divorce under the Hindu Marriage Act.
A Bench comprising Justice Vivek Rusia and Justice Gajendra Singh granted divorce to a woman (appellant) whose husband and in-laws had barred her from pursuing education beyond Class XII.
The Court noted that the Supreme Court has recognized education as a fundamental aspect of life, considering it an integral part of the right to life under Article 21 of the Indian Constitution. This implies that access to education is crucial for leading a life with dignity.
“Compelling the wife to discontinue her studies or creating such an atmosphere that she is put in a position not to continue her studies is equivalent to destroy her dreams in the beginning of their marital life and forcing her to live with a person who is neither educated nor eager to improve himself certainly amounts to mental cruelty and we hold that it constitutes a ground of divorce under section 13(1)(ia) of the Hindu Marriage Act, 1955,” it said.
Compelling the wife to discontinue her studies, forcing her to live with a person who is neither educated nor eager to improve amounts to cruelty.
Madhya Pradesh High Court
The Court was hearing the wife’s appeal against the rejection of her divorce petition and the grant of a decree for the restitution of conjugal rights in favor of her estranged husband.
In this case, the couple married in 2015. At the time, the wife had completed Class XII and wished to continue her education. However, her in-laws allegedly prohibited her from studying and subjected her to harassment over dowry.
The husband, on the other hand, denied any opposition to her education, claiming that the necessary expenses were provided for her to pursue a BSc course. He also refuted the allegations of dowry demands and domestic violence.
In 2020, the Family Court ruled in favor of the husband, concluding that the wife had left him without a valid reason. She then appealed the decision before the High Court.
However, the High Court observed that the husband, who is uneducated, had himself admitted that he did not cover the expenses for his wife’s education.
The Court also considered a witness statement indicating that the wife had experienced unwelcoming behavior from her husband and that he had failed to respect her privacy during a trip.
“It is also a fact that during the period of 10 years from the solemnization of marriage on 01.05.2015 petitioner and respondent were together only for a period of 3 days in the month of July, 2016 and that experience of the wife was a nightmare and thereafter they never came in the company of each other,” the Court further found.
Disagreeing with the trial court’s findings, the High Court further stated,
“This is not a case where she was taking advantage of her own fault but this is a case where wife was putting to sacrifice her dreams, career in the name of marital obligations.”
Consequently, the Court overturned the Family Court’s findings, ruling that the wife had endured mental cruelty and had a justified reason to live separately.
The Court further noted that the case involved an irretrievable breakdown of marriage, as the couple had been living apart since July 2016 with no chance of reconciliation.
Accordingly, the Court upheld the wife’s appeals, dissolved the marriage, and annulled the decree for the restitution of conjugal rights.
