
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 ruled on Thursday 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 an essential aspect of life and an integral part of the right to life under Article 21 of the Indian Constitution, emphasizing that access to education is crucial for leading a dignified life.
“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 challenging the rejection of her divorce petition and the granting 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 dowry-related harassment.
The husband, on the other hand, denied any opposition to her education, asserting that the necessary expenses were provided for her to pursue a BSc course. He also refuted allegations of dowry demands and domestic violence.
In 2020, the Family Court ruled in favor of the husband, concluding that the wife had separated from him without a valid reason. She subsequently challenged this decision in the High Court.
However, the High Court noted that the husband, who is uneducated, had himself admitted that he did not cover her educational expenses.
The Court also considered a witness statement indicating that the wife had been subjected to unwelcoming behavior by 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 valid 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 prospect of reconciliation.
Accordingly, the Court upheld the wife’s appeals, dissolved the marriage, and nullified the decree for the restitution of conjugal rights.