Denying Wife Education After Marriage Amounts To Mental Cruelty: Madhya Pradesh HC
The court stated that preventing a woman from pursuing her studies after marriage is akin to ‘destroying her dreams’ and constitutes mental cruelty, granting the wife a divorce.
The Madhya Pradesh High Court at Indore has ruled that compelling a wife to discontinue her studies after marriage is equivalent to destroying her dreams and amounts to mental cruelty under Section 13(1)(ia) of the Hindu Marriage Act, 1955. A Division Bench comprising Justice Vivek Rusia and Justice Gajendra Singh delivered the verdict while setting aside the family court’s orders and granting divorce to the appellant-wife.
The court observed: “Compelling the wife to discontinue her studies or creating such an atmosphere that she is unable to continue her education is equivalent to destroying her dreams at the beginning of their marital life. 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 for divorce under Section 13(1)(ia) of the Hindu Marriage Act, 1955."
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The court was hearing a case arising from two appeals filed by the wife. Firstly, the wife had challenged the family court’s rejection of her divorce petition, and another appeal was filed against the decree of restitution of conjugal rights in favour of the husband.
The couple married on 1 May 2015, and the gauna ceremony (the ritual where a bride moves from her natal home to her marital home after marriage) was performed on 16 July 2016. At the time of marriage, the wife had completed her 12th standard and wished to continue her studies, which her in-laws had agreed to. However, upon moving into her matrimonial home, she was allegedly prevented from studying within two to three days and subjected to demands for dowry, including Rs 1 lakh and a motorcycle. She claimed to have faced harassment, domestic violence, and unnatural sexual intercourse.
Due to the alleged mistreatment, she returned to her parental home and filed a case under the Protection of Women from Domestic Violence Act (DV Act), 2005, along with a petition for divorce on 21 November 2016, citing cruelty.
The husband contested the allegations, asserting that he had supported his wife’s education and never demanded dowry. He claimed that she had willingly left the matrimonial home and refused to return despite his efforts. He also stated that he had given a considerable amount of jewellery to the wife’s family at the time of the gauna ceremony and alleged that she had filed a false case to retain the jewellery. He later filed a petition for restitution of conjugal rights, arguing that she had withdrawn from cohabitation without reasonable excuse.
The family court, however, dismissed the wife’s divorce plea and allowed the husband’s restitution petition.
The High Court reappraised the evidence and, citing the Apex Court’s judgment in Mohini Jain v. State of Karnataka & Others (1992), recognised that “education is a facet of life" and an integral part of the “right to life" under Article 21 of the Constitution of India, meaning that access to education is essential for living a life with dignity.
The court also quoted the American philosopher, psychologist, and educational reformer John Dewey, noting that “education is not just about preparing for life, but it is life itself."
The court found that this was not a case where the wife was attempting to benefit from her own wrongdoing. Instead, it was a situation where she had been compelled to sacrifice her dreams and career under the pretext of fulfilling marital obligations. It acknowledged the irretrievable breakdown of the marriage, as the parties had been living separately since 2016, and ruled that “there is no possibility of reunion of the parties."
Consequently, the court concluded that the wife had been subjected to mental cruelty, which justified granting her a divorce. The orders of the family court were set aside, and the wife’s plea for divorce was allowed.
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