In a significant ruling, the Allahabad High Court recently reiterated the principles underlying Section 14 of the Hindu Marriage Act, 1955, which prohibits the dissolution of a Hindu marriage within one year of marriage unless there are exceptional circumstances of hardship or depravity. The decision was made in the case Sri Nishant Bhardwaj v. Smt. Rishika Gautam (First Appeal Defective No. 12 of 2025).
The case involved a petition filed by the parties for the mutual dissolution of their marriage under Section 13-B of the Act. However, the Principal Judge of the Family Court in Saharanpur rejected the petition, citing the mandatory one-year limitation period specified under Section 14 of the Act. The court emphasized that no petition for divorce can be presented within one year of the marriage unless it is proven that the case involves "exceptional hardship" or "exceptional depravity."
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Court’s Observation:
A division bench consisting of Justice Ashwini Kumar Mishra and Justice Donadi Ramesh examined the merits of the appeal. The bench observed that the grounds presented in the petition were confined to mutual incompatibility and the inability of the parties to live together. However, no exceptional circumstances, as required under the proviso to Section 14, were established.
The court remarked:
"The provision contained under Section 14 of the Act has a laudable object to subserve, inasmuch as the legislature has put an embargo in entertaining an application for dissolution of marriage within one year for specific reasons. Marriage between two Hindus is sacrosanct, and its dissolution would be permissible only for reasons recognized under the law."
The bench further noted that the grounds presented in the petition did not indicate any exceptional hardship to the petitioner or exceptional depravity on the part of the respondent. As a result, the jurisdiction of the court to grant an exemption from the one-year limitation was not invoked.
Importance of Section 14 of the Hindu Marriage Act:
Section 14 of the Hindu Marriage Act serves a vital purpose in preserving the sanctity of marriage. The provision ensures that couples do not hastily seek dissolution and that they attempt to resolve their differences within the initial period of marriage. This legislative intent is especially significant in maintaining the sacrosanct nature of Hindu marriages.
The court emphasized that exemptions to this limitation are granted only in rare and exceptional cases, thereby upholding the law’s broader intent of fostering marital stability. Routine grounds like mutual incompatibility do not suffice to warrant an exemption.
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In its final judgment, the Allahabad High Court dismissed the appeal, affirming the lower court's decision. The bench clarified that the parties are free to file a fresh petition for dissolution after the mandatory one-year period has elapsed. The judgment underscores the judiciary's commitment to upholding the legislative purpose of Section 14 and ensuring that divorces are not granted on frivolous grounds within the initial year of marriage.
Case Title: Sri Nishant Bhardwaj v. Smt. Rishika Gautam [FIRST APPEAL DEFECTIVE No. - 12 of 2025]
