Marriage Built on Trust, Not Lies: Jharkhand High Court Backs Divorce Over Wife's Suppressed Murder Conviction

Holding that a spouse cannot be compelled to continue a marriage rooted in concealment of grave facts, the High Court of Jharkhand upheld a divorce decree where the husband alleged he learnt only after marriage that his wife was significantly older than disclosed and had been convicted to life imprisonment in her former lover's murder case.

"Relationship of wife and husband is based on the trust and respect to have upon each other and if it is broken it is non-repairable as the trust is the foundation of marriage. Marriage is a relationship built on mutual trust, companionship and shared experiences," court said.

A division bench of Justice Sujit Narayan Prasad and Justice Arun Kumar Rai upheld the September 2022 judgment of the Family Court, Gumla, which had dissolved the marriage between Ranthi Kumari Devi and Suresh Kumar Sahu under Section 13 of the Hindu Marriage Act, 1955.

The dispute arose out of the marriage solemnised on April 15, 2019, in Gumla district. Soon after the marriage, differences surfaced between the parties, leading the husband to approach the family court seeking dissolution of marriage on the ground of cruelty. He alleged that the marriage itself was vitiated by suppression of crucial facts by the wife.

According to the husband, the wife had misrepresented her age at the time of marriage. While her age was disclosed as 27 years, he later came to know that she was around 40 years old. More significantly, he alleged that she had concealed her conviction for murder in a 2006 sessions case, in which she and her brother were sentenced to life imprisonment. Though the wife was on bail during the pendency of her criminal appeal, the husband claimed he had no knowledge of this conviction prior to marriage.

The husband further alleged that the marriage was solemnised under pressure after alterations were made to his name for horoscope matching. He also claimed that there was no normal conjugal relationship and that the wife frequently threatened to kill him and his family members, besides warning him of false criminal cases if he objected to her conduct.

The wife, however, denied all allegations. In her written statement and evidence, she claimed that her age and criminal case were fully disclosed before marriage and that she had been falsely implicated in the murder case. She further alleged that the husband had concealed the fact that he had already contracted two marriages prior to marrying her and that she was subjected to harassment after marriage.

After appreciating the oral and documentary evidence, the family court concluded that the husband had established mental cruelty and granted a decree of divorce. Challenging this finding, the wife approached the high court contending that the family court had failed to frame proper issues and had ignored evidence led on her behalf.

Rejecting the appeal, the high court observed that under Section 19 of the Family Courts Act, it was empowered to reappreciate both facts and law. After examining the evidence on record, the bench held that the family court’s findings did not suffer from perversity.

The bench noted that the concealment of material facts such as age and criminal conviction went to the root of the marital relationship. “The relationship of husband and wife is on the thread of trust,” the court observed, adding that suppression of such facts before marriage caused mental agony and broke the foundation of trust necessary for continuation of marital life.

The court further held that repeated threats, criminal litigations, and the overall conduct of the wife, as established from the husband’s evidence, constituted mental cruelty within the meaning of Section 13 of the Hindu Marriage Act.

Finding no infirmity in the reasoning of the family court, the high court dismissed the appeal and affirmed the decree of divorce. All pending interlocutory applications were also disposed of.

Case Title: Ranthi Kumari Devi vs. Suresh Kumar Sahu

Judgment Date: January 8, 2026

Bench: Justice Sujit Narayan Prasad and Justice Arun Kumar Rai