The Jharkhand High Court upheld divorce in favour of a husband after finding that the wife concealed her real age and her life imprisonment conviction in a murder case before marriage. The Court ruled that marriage cannot survive when trust is destroyed by suppression of serious facts.
RANCHI: The Jharkhand High Court has clearly held that a marriage cannot be forced to continue when it is built on lies, concealment, and fear. Upholding the divorce granted to a husband, the Court ruled that hiding crucial facts like real age and prior criminal conviction amounts to mental cruelty and breaks the very foundation of marital life.
The case arose from a marriage solemnised on 15 April 2019 in Gumla district between Ranthi Kumari Devi and Suresh Kumar Sahu. Soon after marriage, serious disputes started, forcing the husband to approach the Family Court seeking dissolution of marriage under Section 13 of the Hindu Marriage Act, 1955.
The Family Court, Gumla, granted divorce in September 2022. Challenging that decision, the wife filed an appeal before the Jharkhand High Court.
The husband alleged that the marriage itself was based on suppression of vital facts. According to him, the wife had misrepresented her age at the time of marriage. While she was projected to be around 27 years old, he later discovered that she was close to 40 years of age. More seriously, he claimed that she had concealed the fact that she had been convicted and sentenced to life imprisonment in a murder case relating to her former lover, along with her brother. Though she was on bail during the pendency of her criminal appeal, this information was never disclosed before marriage.
The husband further stated that the marriage was solemnised under pressure, even after his name was allegedly altered for horoscope matching. He also alleged that there was no normal conjugal relationship after marriage and that the wife frequently threatened to kill him and his family members.
According to him, whenever he objected, she would threaten to send him and his family to jail by filing false criminal cases. He also pointed out that multiple litigations were initiated, causing continuous mental stress and fear.
The wife denied these allegations and claimed that all facts regarding her age and criminal case were disclosed before marriage. She stated that she had been falsely implicated in the murder case and that the husband was aware of everything. She also alleged that the husband had concealed his earlier marriages and that she was harassed and thrown out after marriage.
After examining oral and documentary evidence, the Family Court concluded that the husband had proved mental cruelty and granted divorce. The wife argued before the High Court that the Family Court had ignored her evidence and had not framed proper issues.
Rejecting the appeal, the Jharkhand High Court observed that it had full power under Section 19 of the Family Courts Act to reappreciate both facts and law. After carefully reviewing the entire record, the Court found no perversity in the Family Court’s findings.
The Division Bench made strong observations on the importance of trust in marriage and held that concealment of serious facts strikes at the root of the relationship.
The Court categorically held:
“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”
The High Court noted that hiding real age and a life conviction in a murder case is not a minor omission but a grave suppression. Such concealment, combined with repeated threats, criminal complaints, and hostile conduct, causes deep mental agony and makes it unreasonable to expect the husband to continue the marital relationship.
The Court further observed that cruelty under matrimonial law is not limited to physical violence. Continuous fear, threats of false cases, and suppression of truth before marriage amount to mental cruelty under Section 13 of the Hindu Marriage Act.
Finding no legal or factual error in the Family Court’s judgment, the High Court dismissed the wife’s appeal and affirmed the decree of divorce. All pending applications were also disposed of.
This judgment quietly reinforces an important reality of matrimonial litigation: when men are trapped in marriages built on deception, fear, and misuse of criminal law, courts cannot shut their eyes. Marriage is not a punishment, and trust once shattered cannot be repaired by forcing coexistence.
Explanatory Table: Laws & Sections Involved
| Law | Section | Explanation in Simple Terms | How Applied in This Case |
| Hindu Marriage Act, 1955 | Section 13(1)(ia) | Allows divorce on the ground of cruelty, including mental cruelty | Concealment of real age, life imprisonment conviction, threats, and criminal cases were held to be mental cruelty |
| Family Courts Act, 1984 | Section 19(1) | Provides right to appeal against Family Court orders before High Court | Wife filed appeal challenging divorce decree |
| Indian Penal Code | Section 498A | Criminal provision relating to cruelty by husband or his relatives | Wife filed 498A case after marriage, relied upon as part of cruelty pattern |
| Code of Civil Procedure | Section 96 (principle) | Governs scope of first appeal | Applied by analogy while explaining appellate powers |
| Hindu Marriage Act, 1955 | Section 13 (general) | Governs dissolution of marriage | Basis for granting divorce |
| Criminal Law | S.T. Case No. 221/2004 | Sessions Trial for murder | Wife and her brother convicted and sentenced to life imprisonment |
| Criminal Appeal | Cr. Appeal (DB) No. 573 of 2006 | Appeal against life conviction | Bail granted, but conviction concealed before marriage |
Case Details
- Case Title: Ranthi Kumari Devi v. Suresh Kumar Sahu
- Court: High Court of Jharkhand at Ranchi
- Case Number: F.A. No. 137 of 2022
- Neutral Citation: 2026:JHHC:423-DB
- Date of Judgment: 08 January 2026
- Coram / Bench: Hon’ble Mr. Justice Sujit Narayan Prasad & Hon’ble Mr. Justice Arun Kumar Rai
- Counsels
- For Appellant (Wife): Ms. Chandana Kumari, Advocate
- For Respondent (Husband): None
Family Court Judgment Challenged
- Judgment dated 20.09.2022
- Decree signed on 30.09.2022
- Passed by Principal Judge, Family Court, Gumla
- Original Suit No. 23 of 2022
Key Takeaways
- Marriage obtained by hiding age and serious criminal conviction is not a sacred bond but legal deception.
- Threats of false cases and fear of jail are recognised as mental cruelty, not normal marital conflict.
- Courts have finally acknowledged that men cannot be forced to live under constant criminal intimidation.
- Trust is the backbone of marriage; once broken by lies, law cannot compel coexistence.
- This judgment quietly exposes how criminal law misuse inside marriage destroys men’s mental peace and dignity.
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