According to R.N. Sharma, Hindu marriage is a religious sacrament in which a
man and a woman are bound in a permanent relationship for the physical, social
and spiritual purposes of dharma, procreation and sexual pleasure. Hindu
marriage is an ancient tradition, prevailing from the Vedic period to modern
The Hindus conceived marriage as a holy and sacramental tie and not a
contractual union. Whilst Manu did not recognise the concept of divorce,
Kautilya's Arthashastra permitted divorce by mutual consent in a case of
illegitimate marriage. It was by the introduction of The Hindu Marriage Act,
1955 ('HMA'), the legal provisions for the dissolution of a Hindu marriage were
Under Section 13 of the HMA, any marriage solemnised, may, on a petition
presented by either the husband or the wife, be dissolved by a decree of divorce
on the following grounds:
Voluntary Sexual Intercourse - Section 13(1)(I)Under Section 13(1)(i) of the HMA, a decree of divorce may be sought on the
ground that a party/spouse had voluntary sexual intercourse with any other
person other than his/her spouse during the subsistence of the marriage. As
defined by the Black's Law Dictionary, adultery is the voluntary sexual
intercourse of a married person with a person other than the offender's husband
Although adultery as a criminal offence has been decriminalised by the Hon'ble
Supreme Court of India but remains a valid ground for divorce, the Hon'ble Apex
Court in the matter of Joseph Shine v. Union of India held that:
'Though adultery may be an act committed in private by two consenting adults, it
is nevertheless not a victim-less crime. It violates the sanctity of marriage,
and the right of a spouse to marital fidelity of his/her partner. It impacts
society as it breaks the fundamental unit of the family, causing injury not only
to the spouses of the adulteror and the adulteress, it impacts the growth and
well-being of the children, the family, and society in general, and therefore
must be subject to penal consequences.' 
Any spouse may file a petition for divorce on the ground of adultery before a
competent court of law; the burden of proof would always lie with the person who
alleges it. To prove adultery, one would be required to implead and specify the
adulterer as a respondent, even if no relief is claimed against him/her,
failing which the divorce petition may not be maintainable.
However, in situations when specifying or impleading the adulterer may not be
possible at all, a court depending upon the facts and circumstances, may make
such exceptions. Mere suspicion of adultery would not be held as a valid
ground for adultery. The direct evidence of proof of adultery is rare, and it
is therefore accepted as a rule that it may be proved by circumstantial evidence
and the circumstances ought to be such that it would lead the guarded discretion
of a reasonable and prudent man to a conclusion of adultery.
Some instances which may construe as adultery are:
In a case where a husband can prove continuous and repeated acts of adultery and
cohabit in adultery, he may not be liable to provide maintenance to his wife
under Section 125 (4) of the Criminal Procedure Code or Section 18 of the Hindu
Adoptions and Maintenance Act 1956. The acts of adultery, however, must be
continuous and not a single or occasional lapse, even at the time of the divorce
petition, and not a matter of the past.
- when a husband is able to prove beyond a reasonable doubt that his wife is
absenting herself from their house for a long time, and is seen in the
company of a stranger without any reasonable explanation or that she has
given a false explanation for her having been seen in the company of that
stranger at different places or in a room, would give rise to a reasonable
inference that she has contacted illicit connection with that man and has
been living in adultery,
- Admission of adultery by wife or husband,
- testimony of disinterested witnesses to the extent that they had seen
husband or the wife committing adultery, and
- when a child is born beyond the period of twelve months after the
cessation of marital consortium between the spouses, etc.
If a husband alleges that a child was born out of adultery and challenges the
legitimacy of the child, he is required to rebut the presumption of legitimacy
under the Indian Evidence Act 1872. Section 112 of the Indian Evidence Act 1872
states that any person born during the continuance of a valid marriage between
his marriage and any man, or within two hundred and eighty days after its
dissolution, the mother remained unmarried, shall be conclusive proof that he is
the legitimate son of that man unless it can be shown that the parties had no
access to each other any time when he could have begotten. Therefore, to
presume that a child was born out of adultery at all, the husband must also
prove that he had no access to his wife, and it was only during that period that
the child was born.
Once the validity of the marriage is proved, then there shall be a strong
presumption regarding the legitimacy of the children born out of that wedlock
unless that presumption is rebutted by strong, clear, and satisfying
evidence. Section 112 of the Indian Evidence Act is based on the legal maxim
pater est quem nuptiae demonstrant i.e. he is the father whom the marriage
indicates and would apply in cases when a husband can prove that he had no
access to sexual intercourse with the woman and only then, the man cannot be
said to be the father.
A husband may otherwise, file an application before
the court requesting assistance in conducting a deoxyribonucleic acid ('DNA')
test of the child and establish his assertion of adultery, whom he claims he is
not the father of.
The Hon'ble Supreme Court of India in the case of Goutam Kundu v. State of West
Bengal summarised the law on DNA testing as:
- The Courts cannot order blood tests as a matter of course,
- Wherever applications are made for such prayers to have a roving
inquiry, the prayer for blood test cannot be entertained,
- There must be a strong prima facie case in that the husband must
establish non-access in order to dispel the presumption arising under
Section 112 of the Indian Evidence Act,
- The court must carefully examine as to what be the consequence of
ordering blood test; whether it will have the effect of branding a child as
a bastard and the mother as an unchaste woman, and
- No one can be compelled to give a sample of blood for analysis.
In a recent case, the husband without obtaining any kind of order from the court
or consent from the wife, carried out a DNA test on their child and filed for a
divorce along with the DNA report, which in fact supported his allegations of
adultery, before the court. The Hon'ble High Court of Delhi however, held that
such DNA tests were not conducted as per law, and accordingly, the DNA test
report was also held to be invalid in the eyes of law.
It is important to
note that one cannot be forced to undergo a test, and at most in case of such a
refusal, adverse inference may be withdrawn. In another recent case, the Hon'ble Apex Court allowed a DNA test to be carried out as requested by the
husband however, also imposed a condition that in case it is found that the
husband was the father, the husband would pay compensation INR 30,00,000 (Indian
Rupees Thirty Lacs) to the wife, in addition to the usual maintenance and other
costs as the husband may be directed to pay towards the wife and the child.
Cruelty - Section 13 (1)(Ia)Cruelty is another ground for divorce as laid out under Section 13(1)(ia) of HMA.
The Hon'ble Supreme Court of India in the matter of Vishwanath Sitaram Agrawal
v. Sarla has held that cruelty could be mental or physical, direct or indirect,
intentional or unintentional. It was further observed by the Hon'ble Apex Court
that 'the expression 'cruelty' has an inseparable nexus with human conduct or
It is always dependent upon on the social strata or the milieu
to which the parties belong, their ways of life, relationship, temperaments, and
emotions that have been conditioned by their social status.' 
act whether it may constitute as cruelty or not, would broadly depend upon two
elements i.e. the act complained of i.e. the nature of the cruel treatment, and
the nature of its effect on the aggrieved spouse. The intent is not a
necessary element for an act to be determined cruelty, but by an ordinary sense
in human affairs, the act or the conduct complained of, could itself be regarded
Physical Cruelty Versus Mental Cruelty
The acts of cruelty involving physical assaults, harm or injury, may be obvious,
however, when mental cruelty is alleged, the court must assess the facts and
circumstances which may vary from case to case. There may be circumstances where
mental cruelty could be construed as more painful than physical cruelty, as the
former may continue to hurt all along and any amount of therapy/ healing may not
wipe out the scars lifelong.
Even a single act of violence may be of such
grievous and inexcusable nature that it satisfies the test of cruelty. However,
isolated acts of assaults which may be committed during a spur moment, and on
account of real or fancied provocation, may not necessarily amount to cruel
Some of the examples amounting to mental cruelty would include, a wife falsely
alleging that the husband was a lunatic and that there was a streak of insanity
running in his family or falsely accusing the husband that he tried to force
her into prostitution, a wife abusing her mother-in-law, and insulting her
husband in front of his colleagues. Likewise, if a husband frequently visits
his wife's office and humiliates her, calling her a prostitute in front of her
colleagues, the same would also amount to cruelty.
The Hon'ble Supreme Court
of India in the matter of Samar Ghosh v. Jaya Ghosh held that:
indecent defamatory allegations against the spouse or his or her relatives in
the pleadings, filing of complaints or issuing notices or news items which may
have an adverse impact on the business prospect or the job of the spouse and
filing repeated false complaints and cases in the court against the spouse would
amount to causing mental cruelty to the other spouse.
In a recent case, the Hon'ble High Court of Madras held that the acts of the
wife in suspecting her husband's character and making false allegations of him
having extramarital affairs in the presence of his colleagues amounted to
cruelty. On the other hand, the Hon'ble High Court of Kerala held that the
constant and repeated taunts of the husband in comparing his wife with other
women and complaining that the wife is not of his expectation, would as well
amount to mental cruelty.
Some of the other examples of cruelty would include false allegations of
physical violence by the spouse's family, unchastity or casting aspersions
on the wife's character, wife filing false proceedings against the husband
causing humiliation and lowering his reputation in the eyes of his peers.
The husband suffering from paranoid schizophrenia, due to which he was not able
to have a sexual relationship with his wife, was construed as cruelty by the
Hon'ble Apex Court.
It is a settled law that if either of the parties to a marriage being in a
healthy physical capacity refuses to have sexual intercourse with another, the
same would amount to cruelty entitling the other party to a decree for
dissolution of marriage. It would not make any difference in law whether denial
of sexual intercourse is the result of the sexual weakness of the husband
disabling him from having a sexual union with the wife, or it is because of any
wilful refusal by the husband. In a recent judgment delivered by the High
Court of Madras, it was held that refusal to have sexual intercourse even on
account of physical incapacity, would be construed as cruelty.
The Hon'ble divisional bench of the High Court of Delhi granted a decree for
dissolution of marriage to the husband on the ground that the wife caused mental
cruelty to her husband and his family, by not only refusing to consummate their
marriage during the marriage but by also falsely implicating her husband and his
The question whether rape of a wife by her husband (i.e. marital
rape), is a criminal offence or not, is yet to be decided by the Hon'ble Supreme
Court of India after the Hon'ble High Court of Delhi delivered a split verdict
on the same issue. Though the divorce laws prevailing in India, have been
time to time amended while protecting the rights of women, yet there are several
situations where women are expected to act or conduct themselves within the
contours set out by the old and continuing traditions and norms of the society.
The Hon'ble Apex Court in the matter of Narendra v. K. Meena has held that:
wife demanding her husband to leave his parents and live separately has also
been held as mental cruelty, this has also been upheld in a recent case by
the High Court of Chhattisgarh.
Desertion - Section 13 (1)(Ib)The expression 'desertion' under Section 13 of the HMA is explained as the
desertion of the petitioner by the other party to the marriage without
reasonable cause, and without the consent or against the wish of such party, and
includes the wilful neglect of the petitioner by the other party to the
marriage. A spouse living apart by mutual agreement, consent, or on account of
employment, or exigencies of business, would not amount to desertion.
essential ingredients for desertion are - the factum of separation as well as
the intention of permanent cohabitation, which must both exist for a continuous
period of two years. Desertion must be a voluntary action/ conduct by the
deserted spouse, and without any reasonable cause.
A spouse living separately on account of violence, cruelty, being
ill-treated by a husband or his family, business or occupation, owing to
medical conditions/ treatments, would not constitute as desertion. Further,
a husband having illicit relations with another woman; impelling his wife to
live separately would also not amount to desertion. In the case of Vinay
Kumar v. Nirmala, the Hon'ble High Court of Delhi granted the decree of divorce
in favour of the husband and against his wife, who voluntarily left her
matrimonial house on account of being unable to adjust with her husband and
in-laws, and never returned.
In the matter of Smt.Prabhavati v. K. Somashankar, the Hon'ble High Court of
Karnataka held that:
The standard of proof required for granting of divorce on
the ground of desertion, should not be merely on the preponderance of
probabilities, but must be proof beyond a reasonable doubt. In a case where
the husband forcibly, turns his wife out of the matrimonial house because of
which she is constrained to live separately, the husband would be guilty of
The desertion test is not about which spouse left the
matrimonial home first. Constructive desertion is the expression used to show
that the spouse who compels the other to leave him or her, is guilty of
desertion, even though the party going away from the matrimonial home is the
other party. Therefore, if a spouse by his/her words or conduct, compels the
other spouse to leave the marital home, the former would be guilty of
Conversion - Section 13(1)(Ii)A spouse has a right to seek divorce under Section 13(1)(ii) of HMA, if the
other spouse voluntarily converts himself/herself to any other religion other
than Hindu. In the matter of Lily Thomas v. Union of India, the Hon'ble
Supreme Court of India held that conversion or apostasy would not automatically
dissolve a marriage already solemnized but would only provide as a ground for
divorce under Section 13(1)(ii) of the Hindu Marriage Act, 1955.
non-converted spouse would be entitled to seek divorce under Section 13(1)(ii)
of the HMA, however, the converted spouse would not be disentitled to seek
divorce on other grounds under the HMA merely on the ground of being converted
to any other religion. The Hon'ble High Court of Kerala held that a Hindu
wife would be entitled to live separately from her husband if the husband has
ceased to be a Hindu by conversion to any other relation, and the same would not
disentitle the wife to claim maintenance.
Incurable Unsound Mind Or Mental Disorder - Section 13(1)(Iii)One of the essential conditions for the solemnization of a marriage under Hindu
laws is that neither party must be incapable of giving valid consent or
suffering from a mental disorder of such a kind, failing which the marriage
would be voidable and may be annulled by a decree of nullity.
13(1)(iii) of the HMA, a spouse may seek for dissolution of marriage, pursuant
to marriage from their spouse suffering from incurable unsound mind or mental
disorder. A spouse seeking divorce under Section 13(1)(iii) of HMA must
establish that their husband/ wife is of unsound mind, the same is incurable and
that the mental disorder is to the extent that the spouse cannot reasonably be
expected to live their husband/wife.
In the case of Kollam Padma Latha vs Kollam Chandra Shekhar, the Hon'ble Apex
Court held that:
Schizophrenia is not of such a serious nature and particularly
when it is treatable, it cannot be a ground for divorce under Section 13(1)(iii)
of HMA. A wife suffering from a slight mental disorder, not of such kind, to the
extent that the husband could not live with her, was rejected as a ground for
divorce under Section 13(1)(iii) of the HMA.
Instances like occasional bouts of laughter, not wearing mangalsutra or
applying bindis, short temper or erratic behaviour cannot be termed as a
mental disorder. A wife occasionally locking herself in the bathroom, stating
that she wants to die, setting clothes on fire, creating a scene on roads, was
construed as hazardous behaviour by the High Court of Madhya Pradesh and had
accordingly granted the decree for dissolution in favour of the husband.
order to obtain a decree of divorce under Section 13(1)(iii) of the HMA, one
must be able to prove that no reasonable person would be able to live with
his/her spouse owing to their mental sickness.
Venereal Disease - Section 13(1)(V)A marriage may be dissolved by a decree of divorce under Section (1)(v) of HMA,
on the ground that the spouse is suffering from a venereal disease which may be
in communicable disease. The term 'venereal disease' is defined by
Merriam-Webster dictionary as a contagious disease (such as gonorrhoea or
syphilis) that is typically acquired in sexual intercourse. Human
Immunodeficiency Virus ('HIV') which leads to Acquired Immunodeficiency Syndrome
('AIDS') has been held as a valid ground under Section (1)(v) of the HMA by
various courts in India.
Renounced The World By Entering Any Religious Order - Section 13(1)(Vi)A wife/husband would be entitled to seek divorce from their spouse, who
voluntarily renounces himself/herself from the world by entering into any
religious order (i.e. Hindus, Buddhists, Sikhs and Jains). The Black's Law
Dictionary explains the expression "renounce" to mean "to give up or abandon
formally (a right or interest); to disclaim (renounce an inheritance), to refuse
to follow or obey; to decline to recognize or observe (renounce one's
The expression "renounce" as defined by the Concise Oxford
Dictionary of Current English is "consent formally to abandon; surrender; give
up ( a claim, right, possession, etc); repudiate; refuse to recognize any longer
(renouncing their father's authority); a decline further association or disclaim
relationship with (renounced my former friends); withdraw from; discontinue;
forsake; refuse or resign a right or position esp., as an heir or trustee".
is relevant to mention that necessary ceremony and procedure towards
renunciation of the world must have taken place, and merely just declaring
to have become sanyasi or that person starts wearing clothes ordinarily used
by sanyasis would not amount to renunciation from the world.
Disappearance For Seven Years Or More - Section 13(1)(Vii)A person may seek dissolution of divorce under Section 13(1)(vii) of HMA, on the
ground that his/her spouse has been unheard of being alive for a period of seven
years or more by the persons who naturally heard of him or her. Section 108 of
the Indian Evidence Act 1872 provides that the question whether a person is
alive, or dead must be proved that he has not been heard of, for seven years or
more, by those who would naturally have heard of him if he had been alive.
burden of proving that he is alive would be shifted to the person who affirms
it. Once the person has not been heard of being alive for a period of seven
years or more, the presumption under Section 108 of the Indian Evidence Act 1872
would raise that he is dead at the time the question was raised.
Non-Resumption Of Cohabitation Or Restitution - Section 13(1A)Section 13(1A) of HMA entitles either party to a marriage to seek dissolution of
marriage on the ground:
- No resumption of cohabitation has taken place between the spouses for a
period of one year or more from the date after the passing of a decree for
judicial separation in a proceeding to which they were parties, and
- That no restitution of conjugal rights has taken place between the
spouses for a period of one year or more from the date after the passing of
a decree for restitution of conjugal rights in a proceeding to which they
were parties. Section 13(1A) of HMA was introduced by way of an
amendment of 1964, prior to which only the spouse who had obtained the decree
for restitution of conjugal rights was permitted to apply for a decree of
divorce and not the spouse against whom the decree was passed.
either party to the marriage can present a petition for dissolution of marriage
if there had been non-compliance of the decree of judicial separation or the
decree for restitution of conjugal rights.
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- Eight Edition.
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Satyanarayana Avadhani v. Hindu Religious Endowment Board AIR 1957 AP 824
- Avasarala Kondala Row v. Ishwara Sanyasi, 33 MLJ 63
- Section 13(1A)(i) of HMA
- Section 13 (1A)(ii) of HMA
The content of this Article is intended to provide general information about the
subject matter and should not be construed as legal advice in any manner. Please
feel free to contact the author for any additional information/ advice.
Written By: Kunal Kumar, Advocate
Email: [email protected]
, Ph no: +91-9811420230