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ApniLaw > Blog > High Court > Madhya Pradesh High Court > Denial of Education Amounts to Mental Cruelty: MP High Court Grants Divorce
FamilyHigh CourtMadhya Pradesh High CourtMarriage and DivorceNews

Denial of Education Amounts to Mental Cruelty: MP High Court Grants Divorce

Amna Kabeer
Last updated: March 13, 2025 5:10 pm
Amna Kabeer
3 months ago
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High Court of Madhya Pradesh
High Court of Madhya Pradesh
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Court Recognizes Education as a Fundamental Right in Marriage Dispute


The Indore Bench of the Madhya Pradesh High Court has ruled that forcing a wife to discontinue her studies or creating conditions which is denial of education constitutes mental cruelty. This judgment, delivered by a division bench of Justice Vivek Rusia and Justice Gajendra Singh, granted divorce under Section 13(1)(ia) of the Hindu Marriage Act, 1955.

Contents
Court Recognizes Education as a Fundamental Right in Marriage DisputeFamily Court’s Decision OverturnedHusband’s Conduct Considered Mental CrueltyCourt Declares Marriage Irretrievably Broken


Family Court’s Decision Overturned


The case involved a woman whose petition for divorce was initially rejected by the Principal Judge, Family Court, Shajapur. The trial court had also granted restitution of conjugal rights to the husband. However, the High Court found that the woman was not at fault but was forced to sacrifice her education and career due to marital obligations.
The court emphasized that depriving a spouse of education violates fundamental rights. It referred to the Supreme Court’s ruling in Mohini Jain vs. State of Karnataka & Others (1992). This recognized education as an integral part of the right to life under Article 21 of the Constitution.


Husband’s Conduct Considered Mental Cruelty


The case details revealed that the couple married in 2015 when the wife had completed her 12th standard. She was assured she could continue her education. However, after marriage, her in-laws prevented her from returning to her maternal home for further studies. She also faced dowry harassment and was subjected to unnatural sexual intercourse.
The husband and his family claimed they had no objection to her education and even paid for her B.Sc. course. However, the High Court noted that the husband, who was uneducated himself, admitted he did not bear her study expenses. The wife’s statements about being compelled to discontinue education were deemed credible.
Additionally, the court found that the couple had cohabited only for three days in July 2016. The wife described her experience as a “nightmare,” and there was no further marital cohabitation.


Court Declares Marriage Irretrievably Broken


Quoting American philosopher John Dewey, the court reiterated that “education is not just about preparing for life, but it is life itself.” Given the couple’s prolonged separation and irreconcilable differences, the court ruled the marriage had irretrievably broken down.
Setting aside the family court’s decision, the High Court dissolved the marriage on the grounds of mental cruelty under Section 13(1)(ia) of the Hindu Marriage Act, 1955.

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TAGGED:EducationGrounds for DivorceHindu Marriage ActMadhya Pradesh High CourtRight to Educationwomen's rights
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