Compelling Wife to Discontinue Studies Amounts to Cruelty, a Valid Ground for Divorce: Madhya Pradesh High Court

The Madhya Pradesh High Court, comprising Justice Vivek Rusia and Justice Gajendra Singh, granted a divorce to a woman whose husband and in-laws had prevented her from continuing her studies after Class XII. The Court underscored that the right to education is an essential aspect of Article 21 (Right to Life) of the Indian Constitution, making access to education fundamental to living with dignity. Addressing the issue of mental cruelty, the Court observed that compelling a wife to discontinue her studies or creating an atmosphere that hinders her education is akin to destroying her dreams at the outset of marriage. It further held that forcing a wife to live with an uneducated husband who lacks the desire for self-improvement amounts to mental cruelty, thereby constituting a ground for divorce under Section 13(1)(ia) of the Hindu Marriage Act.

The case involved a couple who married in 2015. At the time, the wife had completed Class XII and wished to pursue further studies, but her in-laws allegedly prohibited her from doing so and subjected her to dowry-related harassment. The husband denied these allegations, asserting that he never opposed her education and even provided financial support for her BSc course. He also refuted claims of domestic violence and dowry demands. In 2020, the Family Court ruled in favor of the husband, stating that the wife had separated from him without reasonable cause. The wife then appealed to the High Court.

Upon reviewing the case, the High Court found that the husband was uneducated and had admitted to not covering his wife’s education expenses. Witness testimonies indicated that the wife had faced unwelcoming behavior, including privacy violations during a trip. The Court highlighted that the couple had lived together for only three days in July 2016, nearly a year after their marriage, and that the wife’s experience during this period had been distressing. Since then, they had never cohabited, leading the Court to conclude that the marriage had suffered an irretrievable breakdown.

Disagreeing with the Family Court’s findings, the High Court ruled in favor of the wife, emphasizing that she had not taken advantage of her own fault but was instead forced to sacrifice her dreams and career due to marital obligations. The Court determined that she had been subjected to mental cruelty and had a reasonable excuse to live separately. Given the absence of any possibility of reconciliation, the High Court dissolved the marriage and set aside the decree of restitution of conjugal rights. Advocate Chandrakant Verma represented the wife, while Advocate Aditya Verma appeared for the husband.