18/08/2026
The Delhi High Court has held that a spouse who, despite obtaining a decree for restitution of conjugal rights, refuses to resume cohabitation and simultaneously challenges the validity of the marriage cannot subsequently seek a decree of divorce under Section 13(1A) of the Hindu Marriage Act, 1955.
A Division Bench comprising Justice Vivek Chaudhary and Justice Renu Bhatnagar, in Yash Khanna v. Bhawna, MAT.APP.(F.C.) No. 252/2018, held that such conduct amounts to taking advantage of one’s own wrong, within the meaning of Section 23(1)(a) of the Hindu Marriage Act, 1955. The Court accordingly dismissed the husband’s appeal against the Family Court’s refusal to grant him a decree of divorce.
The Court’s reasoning underscores that the statutory right to seek divorce under Section 13(1A) cannot be invoked by a party whose own conduct has contributed to or perpetuated the matrimonial separation, particularly where the same party refuses to resume the marital relationship while questioning the very validity of the marriage.
Case: Yash Khanna v. Bhawna
Case No.: MAT.APP.(F.C.) No. 252/2018
Court: Delhi High Court
Bench: Justice Vivek Chaudhary and Justice Renu Bhatnagar
Relevant Provisions: Sections 13(1A) and 23(1)(a), Hindu Marriage Act, 1955.