The Madhya Pradesh High Court (Indore Bench) has ruled that compelling a wife to discontinue her studies constitutes mental cruelty and is 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 whose husband and in-laws had barred her from pursuing education beyond Class XII.
The Court emphasized that education is a fundamental right under Article 21 of the Constitution and is crucial for a dignified life. It stated that preventing a wife from continuing her studies or creating an environment that hinders her education is equivalent to crushing her aspirations at the outset of married life. The Court further held that forcing a woman to stay with a husband who is uneducated and unwilling to improve himself amounts to mental cruelty, justifying divorce under Section 13(1)(ia) of the Hindu Marriage Act, 1955.
The case involved a couple who married in 2015. The wife, who had passed Class XII at the time, wished to pursue higher education. However, her in-laws allegedly opposed her studies and subjected her to dowry-related harassment. The husband, in his defense, denied these allegations and claimed he had provided financial support for her BSc course.
In 2020, the Family Court ruled in favor of the husband, holding that the wife had left without reasonable cause. Challenging this decision, she approached the High Court.
Upon review, the High Court noted that the husband, who was uneducated, had admitted he did not bear her educational expenses. It also considered witness testimonies highlighting the husband’s unwelcoming behavior and his failure to respect the wife’s privacy during a trip.
The Court observed that since their marriage on May 1, 2015, the couple had only spent three days together in July 2016, after which they lived apart. The wife described this brief period as a distressing experience.
Disagreeing with the Family Court’s conclusions, the High Court stated that the wife was not at fault but was instead forced to sacrifice her dreams and career for marital obligations. Concluding that she had suffered mental cruelty and had a justified reason to live separately, the Court also noted the irretrievable breakdown of the marriage.
Consequently, the High Court allowed the wife’s appeal, dissolved the marriage, and nullified the decree for restitution of conjugal rights.
