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BEFORE

THE HON’BLE HIGH COURT OF KARNATAKA

UNDER SEC 28 OF THE HINDU MARRIAGE ACT , 1955

APPEAL NO. _________/2024

CASE CONCERNING DISPUTE OVER DIVORCE AND MARRIAGE VALIDITY

KAMINI…………………………………………………………(APPELLANT)

V.

RAJA…………………………………………………..….(RESPONDENT)

MEMORIAL ON BEHALF OF APPELLANT

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S.NO TITLE Pg. NO

1. Table of content 2-3

2. Table of Abbreviations 4

3. Index of Authorities 5-6

4. Statement of Jurisdiction 7-8

5. Statement of Facts 9-10

6. Statement of Issues 11

7. Summary of Arguments 12-15

8.

9. Prayer 35

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TABLE OF ABBREVIATIONS

Hon’ble honourable

HMA The Hindu Marriage Act , 1955

V./vs Versus

Sec. Section

Ors. Others

Anr. Another

Ltd. Limited

& And

Pvt. Private

AIR All India Reporter

Acc. According

& And

b/w Between

Art. Article

u/s Under Section

Sd/- Signed

SCC Supreme Court Cases

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INDEX OF AUTHORITIES CITED

Statutes:

1. The Hindu Marriage Act , 1955

2. The Domestic Violence Act , 2005

Cases :

1. Vinita Saxena vs Pankaj Pandit AIR 2006 SUPREME COURT 1662

2. Yuvraj Digvijay Singh vs. Yuvrani Pratap Kumari, AIR 1970 SC 137

3. Shrikant Anandrao Bhosale vs. State of Maharashtra, (2002) 7 SCC 748,

4. A. Jayachandra vs. Aneel Kaur, (2005) 2 SCC 22,

5. Smt. Uma Wanti vs. Arjan Dev , AIR 1995 P&H 312

6. Harbhajan Singh Monga vs. Amarjeet Kaur AIR 1986 MP 41

7. Mrs. Rita Nijhawan vs. Shri Balkishan Nijhawan, AIR 1973 Delhi

8. Vijay Kumar Ramchandra Bhate vs. Neela vijaykumar Bhate, AIR 2003 SC 2462

9. B.N. Panduranga Shet vs. N. Vijaylaxmi, AIR 2003 Karnataka 357

10.

Books :

1. Universal’s concise commentary Hindu law

2. Halsbury’s Law of India , Volume 26 , Family Law - 1

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STATEMENT OF JURISDICTION

The Appellant humbly submits to the jurisdiction of the Hon'ble High Court in pursuance of

Section 28 of The Hindu Marriage Act, 1955.

Section 28 -Appeals from decrees and orders.—

(1) All decrees made by the court in any proceeding under this Act shall, subject to the

provisions of sub-section (3), be appealable as decrees of the court made in the exercise of its

original civil jurisdiction, and every such appeal shall lie to the court to which appeals

ordinarily lie from the decisions of the court given in the exercise of its original civil

jurisdiction.

(2) Orders made by the court in any proceeding under this Act under section 25 or section 26

shall, subject to the provisions of sub-section (3), be appealable if they are not interim orders,

and every such appeal shall lie to the court to which appeals ordinarily lie from the decisions

of the court given in exercise of its original civil jurisdiction.

(3) There shall be no appeal under this section on the subject of costs only.

(4) Every appeal under this section shall be preferred within a [period of ninety days] from the

date of the decree or order.

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STATEMENT OF FACTS

1. Kamini, the only daughter of her parents, Yogish and Ambika, married Raja, the only son

of Ramachandra and Uma, in January 2010. Kamini's marriage to Raja was arranged

through their parents, although both had the freedom to approve the proposal.

2. Before the marriage, Kamini and Raja knew each other as they were students in the same

engineering college but were in different courses.

3. After the marriage, Kamini moved in with Raja and his parents. She observed strange

behaviour in Raja, who frequently took pills and slept for extended periods. When Kamini

questioned Raja and his mother about his condition, she was met with hostility. Eventually,

Raja disclosed that he had been under treatment for nervousness, but he did not elaborate.

4. Kamini later discovered that Raja had been under treatment for schizophrenia since his

college days. When she confronted her in-laws about Raja's medical history, she was

verbally abused, and Raja physically assaulted her. During the assault, Raja attempted

suicide by consuming pesticide, but he was treated and survived.

5. Shocked by these events, Kamini returned to her parents' home and filed for divorce in the

Family Court at Kudala. Kamini's grounds for divorce included suppression of material

facts regarding Raja's mental illness, his impotency, the non-consummation of the

marriage, and the mental and physical cruelty she endured.

6. Raja contested the divorce, arguing that Kamini was aware of his condition before the

marriage and that the marriage was conducted in the hope that he would recover. He denied

any abuse or impotency and claimed that the divorce petition was premature.

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7. During the trial, Kamini presented evidence of Raja's schizophrenia and his impotency,

including testimonies from medical professionals. However, the trial court rejected her

divorce petition, stating that there was insufficient evidence to prove impotency or

incurable mental illness and that the evidence of cruelty was inadequate. Raja's incomplete

evidence further complicated the case.

8. Kamini, dissatisfied with the trial court's decision, appealed to the High Court of Karnataka.

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STATEMENT OF ISSUES

-1-

Whether Kamini’s petition for divorce is maintainable?

-2-

Whether there was suppression of material facts regarding Raja’ s mental illness during the

marriage proposal, which could affect the validity of the marriage?

-3-

Whether Kamini has provided sufficient evidence to establish Raja’s impotency, which could

be grounds for divorce under Hindu Marriage Act, 1955?

-4-

Whether divorce be granted to kamini on ground of mental and physical cruelty?

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SUMMARY OF ARGUMENTS

1. Whether Kamini’s petition for divorce is maintainable?

It is most reverently submitted before the Hon’ble Court that

2. Whether there was suppression of material facts regarding Raja’ s mental illness

during the marriage proposal, which could affect the validity of the marriage?

It is most reverently submitted before the Hon’ble Court that

3. Whether Kamini has provided sufficient evidence to establish Raja’s impotency,

which could be grounds for divorce under Hindu Marriage Act, 1955?

It is most humbly submitted before the hon’ble court that

4. Whether divorce be granted to kamini on ground of mental and physical cruelty?

It is most reverently submitted before the Hon’ble Court that

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ARGUMENTS ADVANCED

1) Whether Kamini’s petition for divorce is maintainable?

It is most respectfully submitted before the Hon’ble Court that the present suit is required

to be allowed and is maintainable on the basis of the following grounds:

(i) Grounds for Mental Disorder

It is most reverently submitted before the Hon'ble Court that under Section 13(1)(iii)

of the HMA , 1955, a spouse can seek divorce on the ground that the other party has

been suffering from a mental disorder of such a nature and to such an extent that the

petitioner cannot reasonably be expected to live with them. In the present case,

Kamini’s petition for divorce is based on Raja’s mental illness, specifically

schizophrenia, a recognized and severe mental disorder.

Medical evidence, including reports from Dr. Ananth's clinic, shows that Raja has been

suffering from schizophrenia for a prolonged period and has been undergoing

psychiatric treatment even before the marriage. Schizophrenia is widely recognized as

a disorder that can significantly impair a person’s ability to maintain a healthy and

stable marital relationship. The illness not only affects Raja's mental health but also his

ability to fulfil marital duties, which, in turn, has caused considerable distress and

hardship to Kamini.

Given the severity of Raja's condition and its profound impact on their marital life,

Kamini’s petition falls well within the provisions of Section 13(1)(iii). It would be

unreasonable to expect her to continue living with someone who is incapacitated by a

debilitating mental illness that severely impairs the foundation of their marriage.

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Therefore, Kamini’s plea for divorce is maintainable under the Act. The Hon'ble Court

is humbly urged to consider this provision while assessing the validity of the petition.

Further it was held by the Supreme Court in “Ram Narain Gupta v. Smt.

Rameshwari Gupta1”, held that chronic schizophrenia is a valid ground for divorce

under Section 13(1)(iii) of the Hindu Marriage Act, 1955, as it affects the spouse's

ability to continue marital obligations.

(ii) Suppression of facts

That the respondent was suffering from Schizophrenia even before the marriage and

that they have suppressed the material facts and it is pleaded as fraud played on the

appellant. The Lower Appellate Court has categorically given its finding that the

conduct of the respondent and her parents amounts to fraud and suppression of facts

and thereby, they have obtained the consent of the respondent by force and therefore,

the petition is maintainable under Section 12(1)(c) of the Act and the decision granting

decree of nullity of the marriage solemnized between the parties need not be interfered

with.

It is most reverently submitted before the Hon'ble Court that the suppression of material

facts regarding the mental illness of the respondent, Raja, amounts to fraud within the

scope of Section 12(1)(c) of the Hindu Marriage Act, 1955.

The section provides grounds for annulment of a marriage if consent for the marriage

was obtained by fraud or force and reads as follows :

12. Voidable marriages.—

(1) Any marriage solemnised, whether before or after the commencement of this

Act, shall be voidable and may be annulled by a decree of nullity on any of the

following grounds, namely:—

1
AIR 1988 SC 2260

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[(a) that the marriage has not been consummated owing to the impotence of the

respondent; or]

(b) that the marriage is in contravention of the condition specified in clause (ii)

of section 5; or

(c) that the consent of the petitioner, or where the consent of the guardian in

marriage of the petitioner [was required under section 5 as it stood

immediately before the commencement of the Child Marriage Restraint

(Amendment) Act, 1978 (2 of 1978)], the consent of such guardian was

obtained by force [or by fraud as to the nature of the ceremony or as to any

material fact or circumstances concerning the respondent];

In the present case, the fact that Raja was suffering from schizophrenia before the

marriage was deliberately concealed by the respondent and his family, and this

deception constitutes a significant breach of trust.

The mental illness of Raja was a material fact that directly affects the foundation of a

marital relationship. Kamini was led into this marriage without the knowledge of Raja's

pre-existing condition, which has now severely impacted her well-being and the

sanctity of the marital bond. Such suppression amounts to a fraudulent

misrepresentation of facts, and the marriage can be rendered voidable at the option of

Kamini. This misrepresentation, which led Kamini to enter the marriage under false

pretences, satisfies the conditions under Section 12(1)(c), thereby making the petition

for annulment valid and maintainable.

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(iii) Grounds for cruelty

It is most reverently submitted before the Hon'ble Court that the appellant’s petition for

divorce is valid and maintainable on the grounds of cruelty as provided under Section

13(1)(ia) of the Hindu Marriage Act, 1955.

Firstly, non-consummation of the marriage constitutes a significant act of cruelty

towards the appellant. It is well-established that the denial of physical relations without

any reasonable cause deprives the other spouse of marital life’s essence, which itself

amounts to mental cruelty. In the present case, the appellant, Kamini, was denied the

matrimonial bliss of physical relations due to the respondent's incompetency. Such

deprivation has caused immense psychological distress to the appellant. The Supreme

Court, in Samar Ghosh v. Jaya Ghosh (2007)2, held that prolonged denial of physical

intimacy in a marriage without sufficient justification amounts to mental cruelty, further

supporting the appellant’s claim.

Secondly, the respondent's suicidal tendencies and attempts have exacerbated the

mental cruelty inflicted upon Kamini. The respondent’s repeated threats to commit

suicide, along with actual attempts such as consuming "Baygon spray," have placed

Kamini under extreme mental strain and anxiety. Living with the constant threat of the

respondent’s self-harm has made cohabitation impossible and mentally traumatizing

for the appellant. In Gananath Pattnaik v. State of Orissa 3(2002), the court

2
AIRONLINE 2007 SC 347

3
AIRONLINE 2002 SC 93

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recognized that repeated threats or attempts to commit suicide by one spouse can cause

severe mental cruelty to the other, further justifying the appellant's plea for divorce.

The respondent, however, got only his statement recorded and before his cross-
examination could be concluded, deliberately did not appear in the witness box to
complete his deposition.

Section 13(1)(1-a) and (iii) of the Act

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2) Whether there was suppression of material facts regarding Raja’ s mental illness

during the marriage proposal, which could affect the validity of the marriage?

It is most reverently submitted before the Hon'ble Court that the evidence provided by the

appellant, both oral and documentary, along with the medical records, clearly

demonstrates that the respondent was undergoing treatment for a mental illness since few

years after he entered Engineering college. This crucial fact was deliberately concealed

from the appellant. Had the appellant been informed about the respondent’s mental health

condition, she would not have consented to the marriage. There was no condonation of

this act by the appellant.

The lower court, however, misinterpreted the case by treating it as one seeking divorce

based on incurable mental illness, whereas the standard required under Section 12 of the

Hindu Marriage Act, 1955 for annulment due to suppression of mental illness is not as

stringent as it is for divorce on the ground of mental illness. The appellant’s case revolves

around the respondent’s concealment of material facts, not the severity of her mental

condition.

Therefore, if it is established that the respondent was indeed suffering from a mental

illness, and that this information was deliberately suppressed to obtain the appellant’s

consent to the marriage, the inevitable legal consequence is the annulment of the marriage.

This stands as long as the fraud has not been condoned by the appellant and the petition

has been filed within the time period specified by law.

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In Govindan Embranthiri.V vs Sujatha4, it was held by Kerala High Court that for

annulment of marriage, it is not necessary to prove that the mental disorder was incurable.

The suppression of mental illness thereby obtaining his consent by fraud itself is a

sufficient ground for annulment.

(i) Material Fact Suppression

In this case, the suppression of Raja’s mental health condition—particularly the fact that

he had been undergoing treatment for mental illness such as schizophrenia—constitutes a

clear case of fraudulent concealment. Mental illness, especially of a severe nature, has

profound effects on the ability of a person to lead a normal married life and is considered

a critical piece of information that must be disclosed prior to entering into a marriage. The

failure to disclose such an important fact amounts to material suppression.

The following cases have been relied on:

a) SUJATHA VS. C.D.HARIHARAN5

b) SMT.ASHA SRIVASTAVA VS. R.K.SRIVASTAVA

c) Srividya vs Subramaniam (25 Nov 2005)

d) Vandana J. Kasliwal vs Jitendra N. Kasliwal 6

for the proposition that concealment about the ailment of Schizophrenia will amount to

suppression of material facts. In the said judgments, the High Courts held that the

concealment of Schizophrenia will amount to fraud and obtaining consent by force.

Here, Raja’s mental health should have been revealed to Kamini (the appellant) prior to

marriage, as this fact directly impacts the marital relationship and her decision to marry.

4
2017 (5) ALL MR (Journal) 49
5
1995 (2) MLJ 327
6
AIR2007BOM115

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The non-disclosure not only misled her but also deprived her of the right to make an

informed choice about her life partner. Therefore, this suppression serves as a strong

ground for annulment under the Act.

(ii) Effect on Consent

The foundation of a valid marriage rests on the free and informed consent of both parties.

In this case, the appellant’s consent to the marriage was obtained without fully disclosing

the crucial detail of Raja's mental illness, which would have significantly influenced her

decision. The Supreme Court in Suman Singh v. Sanjay Singh 7(2001) made it clear that

withholding essential information, especially about mental health, amounts to obtaining

consent through fraudulent means. Kamini was unaware of Raja’s mental health condition

at the time of the marriage, thus rendering her consent invalid. Consent obtained under

such circumstances, where one party is not fully aware of the significant details about the

other’s mental health, is not true consent as per law. Had the appellant been informed

about Raja’s mental health, she may have reconsidered her decision to marry. In legal

terms, this lack of disclosure leads to a vitiated consent, entitling her to seek an annulment

under Section 12(1)(c) of the Act.

(iii)Fraudulent Misrepresentation

The deliberate act of not disclosing Raja’s mental illness and treatment history amounts

to fraudulent misrepresentation, which is a ground for nullity under the Hindu Marriage

Act. Raja's condition was not merely an incidental illness but one that significantly

7
AIR 2017 SUPREME COURT 1316

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affected his mental stability and ability to engage in the responsibilities of married life.

The fact that he was undergoing medical treatment, had a history of mental instability, and

even exhibited suicidal tendencies, further aggravates the gravity of the concealment. In

K. Veerabhadrappa v. M. R. Shantha (2008), the court ruled that non-disclosure of a

serious medical condition, especially one that affects the spouse’s ability to fulfill marital

obligations, constituted fraudulent misrepresentation. The present case echoes the same

principles. Raja’s medical history and his ongoing treatment were critical facts, and by

concealing them, he (or his family) actively misrepresented his fitness for marriage,

thereby deceiving Kamini into the union. As per Section 12(1)(c), when consent is

obtained by fraud, and the fraud pertains to vital aspects such as health, the marriage is

liable to be declared null and void. There was a suppression of the fact that the respondent

was afflicted with the disease schizophrenia. The non-disclosure or the suppression is a

concealment of a vital fact. There is no evidence in this case that the said fact was disclosed

to the parents of the appellant or to him before the marriage. By concealing this vital fact,

the consent has been obtained from the appellant. Hence, it amounts to fraud, with

reference to a material fact concerning the respondent.

In light of the evidence and circumstances, the hon’ble lower court’s dismissal of the

appellant’s petition is unsustainable in law. The court failed to properly appreciate the

significance of the suppression of material facts, and the petition should be allowed. The

marriage between the appellant and the respondent must be declared null and void under

Section 12(1)(c), as the appellant’s consent was obtained through fraudulent means.

Divorce on Ground of Mental Disorder –

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The Supreme Court of India in Vinita Saxena vs Pankaj Pandit 8 on 21 March, 2006

held that “Mental disorder as a ground of divorce is only where it is of such a kind and

degree that the appellant wife cannot reasonably be expected to live with the respondent

husband. Where the parties are young and the mental disorder is of such a type that sexual

act and procreation of children is not possible it may furnish a good ground for nullifying

the marriage because to beget children from a Hindu wedlock is one of the principal aims

of Hindu Marriage where sanskar of marriage is advised for progeny and offspring .”

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AIR 2006 SUPREME COURT 1662

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3) Whether Kamini has provided sufficient evidence to establish Raja’s impotency,

which could be grounds for divorce under Hindu Marriage Act, 1955?

There was absolutely nothing to show that the documents and prescription given by the doctors have

been concocted. They are the official records of the Hospital.

The medical prescriptions and the evidence of doctors clearly illustrate that the respondent was under

the treatment of Dr. Samantha and was a case of Paranoid Schizophrenia.

The respondent, before his cross examination could be concluded, deliberately did not appear in

the witness box to complete his deposition and his evidence had to be closed.

4) Whether divorce be granted to kamini on ground of mental and physical cruelty?

LEGAL PROPOSITION ON THE ASPECT OF CRUELTY

In the case of Vinita Saxena , the hon’ble Supreme Court defined “Cruelty” as

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“The word 'cruelty' has not been defined and it has been used in relation to human

conduct or human behaviour. It is the conduct in relation to or in respect of matrimonial

duties and obligations. It is a course of conduct and one which is adversely affecting

the other. The cruelty may be mental or physical, intentional or unintentional. There

may be cases where the conduct complained of itself is bad enough and per se unlawful

or illegal. Then the impact or the injurious effect on the other spouse need not be

enquired into or considered. In such cases, the cruelty will be established if the conduct

itself is proved or admitted.”

In 1993 (2) Hindu L.R. 637, the Court had gone to the further extent of observing as follows:

“Sometime even a gesture, the angry look, a sugar coated joke, an ironic overlook may be more

cruel than actual beating" Each case depends on its own facts and must be judged on these

facts. The concept of cruelty has varied from time to time, from place to place and from

individual to individual in its application according to social status of the persons involved

and their economic conditions and other matters. The question whether the act complained of

was a cruel act is to be determined from the whole facts and the matrimonial relations between

the parties. In this connection, the culture, temperament and status in life and many other

things are the factors which have to be considered.”

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Therefore , It is most respectfully submitted before the Hon’ble High Court that the divorce should be

granted on the basis of the following grounds :

i. Non-consummation of the marriage itself would constitute mental cruelty to a married woman.

ii. The respondent attempted to commit suicide also amounts to mental cruelty and harassment.

iii. The appellant has lived only for few months after the marriage and she was mercilessly beaten

by the respondent and his mother.

iv. The appellant was denied the matrimonial bliss of physical relation by the respondent because

of his incompetency which itself constitute cruelty for a married woman.

v. The threat to commit suicide by the respondent amounts to cruelty and the Courts below took

cognizance of the fact that the respondent consumed "Baygon spray".

vi. Because Dr. Ananth was not alive, the medical record authored by him can only be proved by

secondary evidence medical Superintendent who certified on oath that the respondent was

admitted in Hospital and stated that he had brought the records in respect of Raja. He also

identified the signatures of Dr. Ananth and the medical prescriptions of his having treated the

respondent have also been produced and proved by him where it had been categorically stated

that the respondent is suffering from Paranoid Schizophrenia.

vii. Likewise on the ground of non-availability of Dr. Abhyankar, who had authored the medical

prescription as he was no more in service of the hospital cannot be fatal to disregard the

evidence of the other doctor, who produced and proved the entire record.

viii. The marriage between the appellant and the respondent hardly lasted for few months and both

of them are living separately for the last 13 years. the following decisions should be taken into

consideration :

1) Shrikant Anandrao Bhosale vs. State of Maharashtra, (2002) 7 SCC 748, 2) A. Jayachandra vs.

Aneel Kaur, (2005) 2 SCC 22,

3) Smt. Uma Wanti vs. Arjan Dev , AIR 1995 P&H 312

4) Harbhajan Singh Monga vs. Amarjeet Kaur AIR 1986 MP 41

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5) Mrs. Rita Nijhawan vs. Shri Balkishan Nijhawan, AIR 1973 Delhi 6) Yuvraj Digvijay Singh vs.

Yuvrani Pratap Kumari, AIR 1970 SC

6) Yuvraj Digvijay Singh vs. Yuvrani Pratap Kumari, AIR 1970 SC 137.

7) Vijay Kumar Ramchandra Bhate vs. Neela vijaykumar Bhate, AIR 2003 SC 2462

Also , in the case of Vinita Saxena v Pankaj Pandit , the Supreme court clearly stated in the
Judgement that “in the absence of any evidence led by the respondent, the appellant's
evidence had to be relied upon and on the basis of the evidence, the decree for divorce
was bound to be granted in favour of the appellant.”

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PRAYER

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In the lights of the facts stated, arguments advanced and authorities cited, it is most humbly

prayed and implored before the Hon’ble High Court, that it may graciously please to adjudge

and declare that:

i. The court should allow the present Appeal on ground of

ii. The Respondent was cruel against the Appellant.

iii. The Respondent has supressed the material facts.

iv. The court grants the decree of divorce

AND/OR

Also, pass any order that the Hon'ble Court may deem fit in the favour of The Appellants to

meet the ends of equity, justice and good conscience.

For this act of Kindness, The Appellants shall duty bound forever pray.

All of which is most humbly prayed.

Sd./-

Counsel for Appellant

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