LawChakra

“Schizophrenia Alone Cannot be Grounds for Divorce”: Allahabad HC on Mental Illness and Marital Dissolution

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The Allahabad High Court ruled that mental illnesses, like schizophrenia, do not automatically justify divorce under the Hindu Marriage Act without clear evidence of severe impact. It emphasized the necessity of proving the mental disorder’s seriousness. In this case, the court ultimately granted divorce due to willful desertion but upheld that mental health claims require stringent proof.

Allahabad: In a landmark judgment, the Allahabad High Court clarified that mental illnesses like schizophrenia alone are insufficient grounds for divorce under Section 13(1)(iii) of the Hindu Marriage Act unless conclusive evidence demonstrates a severe degree of the condition.

The bench of Justices Rajan Roy and Om Prakash Shukla emphasized that

“Section 13(1)(iii) of the H.M. Act does not make mere existence of a mental disorder of any degree sufficient in law to justify dissolution of a marriage.”

They underlined the necessity of assessing the severity of the mental disorder, stressing that the condition must be so grave that the spouse seeking relief cannot reasonably be expected to continue living with the affected partner.

The court clarified that not all mental abnormalities qualify as grounds for divorce.

“The personality disintegration that characterizes schizophrenia may be of varying degrees, and not all schizophrenics are characterized by the same intensity of disease,”

the bench stated.

Furthermore, the court held that the burden of proof lies on the spouse claiming the existence of a severe mental disorder to justify the dissolution of marriage.

The judgment came in response to an appeal filed by a man seeking divorce from his wife, alleging that she suffered from schizophrenia, which caused erratic behavior and posed risks to herself and others. The couple had been separated since 2012, and the husband claimed that the wife’s condition had been undisclosed before their marriage in 2003, leading to irreconcilable distress.

In her defense, the wife denied the allegations, asserting that she had no history of mental illness and accusing the husband of fabricating the claims. She alleged harassment over dowry and stated that she had fulfilled her marital responsibilities until she was expelled from her marital home.

The Family Court had dismissed the man’s divorce petition, stating that he failed to provide sufficient evidence to substantiate claims of desertion, cruelty, or mental illness severe enough to dissolve the marriage.

On appeal, the Allahabad High Court reviewed the evidence, noting that the wife had not appeared to contest the case. While the court acknowledged the prolonged separation and instances of willful desertion by the wife, it also upheld the Family Court’s opinion that the husband failed to prove the severity of the alleged mental illness.

The High Court referenced Supreme Court precedents, highlighting that cruelty in a marriage can encompass unintentional actions that create an untenable marital environment.

Ultimately, the court set aside the Family Court’s dismissal of the divorce suit and dissolved the marriage, stating that willful desertion was sufficient grounds for granting a divorce. However, the court reaffirmed that claims of mental illness must meet stringent evidentiary requirements.

The Allahabad High Court’s ruling underscores that mental illness cannot be generalized as a ground for divorce without substantial evidence of its impact on the marriage. This judgment provides clarity on the legal interpretation of mental health issues within marital disputes, balancing the rights of individuals against the integrity of the institution of marriage.

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