Compelling Wife To Discontinue Studies Is Akin To Destroying Her Dreams, Amounts To Mental Cruelty: Madhya Pradesh High Court

The court also referred to Supreme Court's decision in Mohini Jain vs. State of Karnataka & others (1992) which recognized that "education is a facet of life" and is considered an integral part of "right to life" under Article 21 of the Constitution of India, meaning that access to education is essential for living a life with dignity.

A division bench of Justice Vivek Rusia and Justice Gajendra Singh observed:

 “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.”

"The Principal Judge, Family Court, Shajapur recorded the finding regarding issues no.1 & 2 ignoring this fact in RCS HM No.62/2016 and 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. Accordingly, findings of the trial court on issues no.1 & 2 are set aside and it is found proved that respondent/husband treated the petitioner/wife with mental cruelty and treating the petitioner/wife with cruelty was a reasonable excuse to live separately from the husband and trial court committed error regarding issue no.1 in RCS HM No.61/2018 and it is found proved that appellant/wife has withdrawn the society of respondent/husband with reasonable excuse," the court added. 

The present appeal was preferred by the wife/appellant being aggrieved by the judgment whereby the petition for divorce on the ground of cruelty under Section 13(1)(ia) of the Hindu Marriage Act, 1955 had been rejected and whereby the decree of restitution of conjugal rights under Section 9 of the Hindu Marriage Act, 1955 was passed in favour of respondent/husband against the wife/appellant by Principal Judge, Family Court, Shajapur.

As per the factual matrix of the case, marriage was solemnised between the appellant and the respondent in 2015. At the time of marriage appellant/petitioner had cleared 12th standard and expressed her desire to continue studies to which the parents and in-laws agreed and the petitioner was taken to her matrimonial home for 2 days with an assurance that she will return at her maternal home. Thereafter, when the petitioner requested to come back to maternal home, her in-laws intimated her that she cannot continue her studies and shall have to reside in the matrimonial home.

The petitioner was also harassed for fulfilment of dowry demands. During her stay in matrimonial home for 2-3 days, she was subjected to unnatural sexual intercourse and her life was put to danger by her drunken husband. Thus, she filed a case under Protection of Women from Domestic Violence Act, 2005 and a petition for divorce on the ground of cruelty.

On the contrary, in the reply filed by the respondents, it was stated that the husband and in-laws had no objection with her continuing her studies. In fact, it was claimed that they had paid necessary expenses for her B.Sc. course and the husband assured that he would cooperate further study of the petitioner.

The Principal Judge, Family Court held that wife had withdrawn from the society of her husband without reasonable excuse and dismissed the petition filed by the wife seeking divorce and allowed the petition of husband for restitution of conjugal rights.

While re-appreciating the evidence, the High Court noted that respondent/husband is uneducated (merely he puts his name as signature) and at the time of marriage, petitioner/wife had cleared her 12th standard examination and was desirous to pursue her studies further and she continued her graduation but respondent/husband in his statement accepted that he did not bear the expenses of her studies. The court also noted that when for the first time petitioner came to her matrimonial home, the husband took her on a trip along with his relative for 2-3 days without maintaining the privacy of the wife. The wife also alleged unwelcoming behaviour of the husband during the trip.

Further, the admission of respondent/husband that he did not bear the expenses of her studies supported the statement of petitioner/wife that she was compelled to discontinue her studies in matrimonial home.

“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 observed.

The court also quoted John Dewey, an American philosopher who said, “Education is not just about preparing for life, but it is life itself.”

Thus, the Court concluded that it is a case of irretrievable break down of marriage and since the appellant and the respondent have been living separately since July, 2016, there exists no possibility of reunion of the parties. The Family Court's order was hence, set aside and the marriage solemnized 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: X v/s Y 

Citation: 2025 LiveLaw (MP) 50

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