Ranchi, Aug 27: The Jharkhand High Court has dismissed a man’s plea seeking annulment of his marriage, ruling that the allegations of concealment of his wife’s medical condition did not establish the kind of fraud required under matrimonial law.
A division bench comprising Justices Sujit Narayan Prasad and Pradeep Kumar Srivastava observed that the evidence indicated the husband was aware of his wife’s medical condition from 2018, contrary to his claim that he discovered crucial information only in 2022.
The couple married in 2017. The husband later alleged that his wife had concealed a medical condition that could affect her ability to conceive. He also claimed that she had undergone surgery for an ovarian problem and cyst before their marriage.
According to his case, he discovered old medical records while cleaning his house in October 2022. He subsequently consulted a doctor and claimed that he then understood the seriousness of the condition and its possible impact on fertility.
The husband contended that the alleged concealment amounted to fraud and that his consent to the marriage had consequently been obtained through fraudulent means. He sought a decree of nullity under the Hindu Marriage Act.The Family Court had earlier rejected his petition, prompting him to approach the High Court.
During the hearing, his counsel argued that the Family Court had incorrectly concluded that the husband knew about his wife’s condition in 2018. It was also argued that the wife’s alleged failure to disclose her reproductive health history amounted to deliberate concealment.
The High Court, however, found that the evidence did not support the husband’s claim to the extent required for granting a decree of nullity.The bench also clarified the legal distinction between fraud in matrimonial proceedings and fraud under contract law.
It observed that the provisions of the Hindu Marriage Act cannot simply be interpreted by applying the definition of fraud contained in the Contract Act.The court noted that Hindu marriage has traditionally been regarded as a sacrament rather than a commercial contract and that the two statutes operate in different legal fields.
The judgment also emphasised that the Hindu Marriage Act does not treat every alleged misrepresentation or concealment as fraud capable of invalidating a marriage.
The court ultimately dismissed the husband’s application, leaving the marriage legally undisturbed. The ruling underscores the importance of establishing the specific legal requirements for matrimonial relief and demonstrates that allegations concerning a spouse’s medical history must be supported by sufficient evidence before a marriage can be declared invalid.
