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Grounds for Divorce — Mental Disorder, Venereal Disease, Renunciation, Presumption of Death

Topic 19 | Module 2: Hindu Marriage Act, 1955 | The Legal Bridge

For Judicial Service Aspirants: RJS | DJS | PCS-J | HJS | APO

Comprehensive Study Notes with Landmark Case Laws, Mnemonics & Exam Tips

Grounds for Divorce — Mental Disorder, Venereal Disease, Renunciation, and Presumption of Death

Relevant Provisions: Section 13(1)(iii), (v), (vi), (vii) of Hindu Marriage Act, 1955 | Note: S.13(1)(iv) Leprosy — DELETED in 2019

Priority: HIGH | Exam Relevance: RJS / DJS / PCS-J / HJS / University Exams (MCQs + essay)

1. Introduction

This topic covers the remaining fault-and-frustration grounds for divorce under Section 13(1) HMA — mental disorder under S.13(1)(iii), venereal disease under S.13(1)(v), renunciation of the world under S.13(1)(vi), and presumption of death under S.13(1)(vii). It also notes the important legislative development of 2019: Section 13(1)(iv), which previously allowed divorce for leprosy, was DELETED by the Personal Laws (Amendment) Act, 2019, reflecting modern medical understanding that leprosy is curable and treatable.

These four grounds represent different aspects of matrimonial breakdown. Mental disorder under S.13(1)(iii) addresses situations where one spouse suffers from such severe mental illness that the other cannot reasonably be expected to continue living with them — it is partly a 'frustration of marriage' ground. Venereal disease under S.13(1)(v) addresses communicable disease posing risk to the other spouse. Renunciation under S.13(1)(vi) covers the classical Hindu concept of entering the sannyasa (renounced) order of life. Presumption of death under S.13(1)(vii) — operating when a spouse has been missing for 7 years or more — is an ingenious provision that allows the deserted spouse to remarry without risking bigamy.

These grounds are REGULARLY TESTED in examinations, primarily through MCQs (asking about specific requirements, periods, or consequences) and in essay questions covering the full range of S.13 grounds. Questions also frequently test the 2019 amendment removing leprosy as a ground — an important recent legislative development. The interaction between civil presumption of death (under S.108 Indian Evidence Act / S.110 BSA 2023) and the matrimonial ground under S.13(1)(vii) is another frequently tested area.

2. GROUND 5: MENTAL DISORDER — Section 13(1)(iii)

2.1 Text of Section 13(1)(iii)

Section 13(1)(iii) HMA provides that either spouse may seek divorce on the ground that the other party:

"has been incurably of unsound mind, or has been suffering continuously or intermittently from mental disorder of such a kind and to such an extent that the petitioner cannot reasonably be expected to live with the respondent."

The Explanation to this clause defines 'mental disorder' and 'psychopathic disorder':

"In this clause — (a) the expression 'mental disorder' means mental illness, arrested or incomplete development of mind, psychopathic disorder or any other disorder or disability of mind and includes schizophrenia; (b) the expression 'psychopathic disorder' means a persistent disorder or disability of mind (whether or not including sub-normality of intelligence) which results in abnormally aggressive or seriously irresponsible conduct on the part of the other party, and whether or not it requires or is susceptible to medical treatment."

2.2 Two Distinct Grounds Under S.13(1)(iii)

Section 13(1)(iii) contains TWO SEPARATE sub-grounds:

1. Incurable unsoundness of mind: The respondent has been INCURABLY of unsound mind. This is the stricter sub-ground — requires complete mental incapacity that cannot be treated or cured.
2. Mental disorder making cohabitation impossible: The respondent has been suffering from a mental disorder of such kind and extent that the petitioner cannot reasonably be expected to live with him/her. This is the broader sub-ground and the more frequently used one.

2.3 Essentials of the Mental Disorder Ground

To succeed under the second sub-ground, the petitioner must establish:

1. Existence of mental disorder: The respondent is suffering from a mental disorder — mental illness, arrested mental development, psychopathic disorder, schizophrenia, or similar condition.
2. Severity and kind: The disorder must be of such KIND and EXTENT that makes cohabitation unreasonable.
3. Continuous or intermittent: The disorder may be continuous OR intermittent — both qualify if sufficiently severe.
4. Cannot reasonably be expected to live together: The petitioner cannot reasonably be expected to continue cohabitation.

2.4 What is 'Mental Disorder'?

The Explanation provides a BROAD definition including:

• Mental illness (psychotic disorders, mood disorders, anxiety disorders in severe form).
• Arrested or incomplete development of mind (intellectual disability, developmental delay).
• Psychopathic disorder (persistent disorder resulting in aggressive or seriously irresponsible conduct).
• Any other disorder or disability of mind.
• Schizophrenia (specifically included).

2.5 Strict Interpretation — R. Lakshmi Narayan v. Santhi (2001)

The Supreme Court in R. Lakshmi Narayan v. Santhi (2001) 4 SCC 688 adopted a STRICT INTERPRETATION of S.13(1)(iii). Key holdings:

• Mere mental weakness, eccentricity, or peculiarity is NOT sufficient.
• The mental disorder must be of such severity that genuinely unfits the respondent for marital life.
• Medical evidence is essential — psychiatric diagnosis and assessment.
• The burden of proof on the petitioner is heavy.
• Courts should not readily grant divorce simply because of stated mental health issues.

2.6 Ram Narain Gupta v. Rameshwari Gupta (1988)

In Ram Narain Gupta v. Rameshwari Gupta (AIR 1988 SC 2260), the Supreme Court discussed schizophrenia. Even a confirmed diagnosis of schizophrenia does not automatically justify divorce — the petitioner must show:

• The severity of the disorder.
• Its impact on marital life.
• Why the petitioner cannot reasonably be expected to continue cohabitation.
• Whether the condition is being treated and with what effect.

2.7 Concerns About Stigmatisation

The mental disorder ground has attracted criticism for potentially STIGMATISING persons with mental health conditions. Modern psychiatric science recognises that many mental illnesses are treatable, and mental illness does not disqualify a person from being a spouse or parent. Courts have accordingly interpreted S.13(1)(iii) strictly — not to allow divorce on the basis of mild or treatable conditions, but only in cases of genuinely debilitating mental illness that makes cohabitation unreasonable.

2.8 Distinction from S.12(1)(b)

S.12(1)(b) deals with violation of S.5(ii) mental capacity at the TIME OF MARRIAGE — making the marriage VOIDABLE. S.13(1)(iii) deals with mental disorder during the MARRIAGE (could have developed after marriage) — permitting DIVORCE. The distinction:

• S.12(1)(b): Annulment. Defect existed at time of marriage. Strict time limits (generally).
• S.13(1)(iii): Divorce. Mental disorder may have developed later. No specific time limit.

2.9 Landmark Cases on Mental Disorder

⚖️ R. Lakshmi Narayan v. Santhi (2001) 4 SCC 688

Ratio: LANDMARK case. Supreme Court held that S.13(1)(iii) requires strict proof. Mere mental weakness, eccentricity, or peculiarity is insufficient. The mental disorder must be of such severity as to genuinely unfit the person for marriage. Medical evidence from qualified psychiatrists is essential. Burden of proof is heavy. This case has been consistently followed.

⚖️ Ram Narain Gupta v. Rameshwari Gupta AIR 1988 SC 2260

Ratio: Supreme Court on schizophrenia. Even diagnosed schizophrenia does not automatically justify divorce. The petitioner must establish: severity, impact on marital life, and impossibility of cohabitation. Treatment and its effect are relevant. Courts should not stigmatise mental illness.

⚖️ Sharada v. Dharampal (2003) 4 SCC 493

Ratio: Supreme Court held that in proceedings under S.13(1)(iii), the court can direct the respondent to undergo medical examination by qualified psychiatrists. Refusal to undergo examination may lead to adverse inference. Balances privacy rights with need for evidence.

⚖️ Kollam Chandra Sekhar v. Kollam Padma Latha (2014) 1 SCC 225

Ratio: Supreme Court held that schizophrenia of wife, even if established, must be shown to render her unfit for marriage and procreation. The mere existence of the disorder is insufficient — its effect on marital life and treatment prospects must be considered.

3. S.13(1)(iv) LEPROSY — DELETED BY 2019 AMENDMENT (Important Historical Note)

3.1 The Original Provision

As originally enacted, S.13(1)(iv) HMA provided:

"has been suffering from a virulent and incurable form of leprosy."

3.2 The 2019 Amendment

The PERSONAL LAWS (AMENDMENT) ACT, 2019 — an important and progressive legislative development — DELETED Section 13(1)(iv) entirely. The Act was enacted in response to:

1. Medical advances: Leprosy is now curable with multi-drug therapy (MDT). The WHO has consistently advocated removing legal disabilities based on leprosy.
2. Human rights concerns: Discrimination against persons affected by leprosy violates their dignity and constitutional rights.
3. International obligations: India is signatory to international resolutions promoting the elimination of leprosy-related discrimination.
4. Law Commission recommendations: The Law Commission of India (256th Report, 2018) recommended removing leprosy as a ground for divorce.

3.3 Other Statutes Amended

The 2019 Amendment was comprehensive — it removed leprosy as a ground for matrimonial relief, separate residence, or disqualification under several statutes:

• Hindu Marriage Act, 1955 (S.13(1)(iv) deleted).
• Dissolution of Muslim Marriages Act, 1939.
• Divorce Act, 1869.
• Hindu Adoptions and Maintenance Act, 1956 (S.18(2)(c)).
• Special Marriage Act, 1954 (S.27(1)(g)).
• Various other statutes.

3.4 Current Position

AFTER 2019: Leprosy is NO LONGER a ground for divorce or judicial separation under Hindu law (or under any other matrimonial statute in India). A spouse suffering from leprosy cannot be divorced solely on that ground. However, if leprosy symptoms cause specific matrimonial problems (e.g., persistent refusal of treatment leading to cruelty, or infectious conditions endangering family), the other grounds (cruelty under S.13(1)(ia), or venereal disease if communicable form under S.13(1)(v)) may potentially be invoked in appropriate cases.

EXAM POINT: Students must know that leprosy is NO LONGER a ground for divorce. Questions asking 'which of the following is NOT a ground for divorce under HMA' often include leprosy as a trap answer. The correct answer is that leprosy is not a ground (deleted 2019).

4. GROUND 6: VENEREAL DISEASE — Section 13(1)(v)

4.1 Text of Section 13(1)(v)

Section 13(1)(v) HMA provides that either spouse may seek divorce on the ground that the other party:

"has been suffering from venereal disease in a communicable form."

4.2 Essentials

1. Venereal disease: The respondent must be suffering from a VENEREAL DISEASE — i.e., a sexually transmitted disease.
2. Communicable form: The disease must be in a COMMUNICABLE (transmittable) form — i.e., still contagious at the time of the petition.
3. Continuing condition: The condition must be subsisting — a disease that has been cured is not a ground.

4.3 What is 'Venereal Disease'?

Venereal diseases (now often called 'sexually transmitted diseases' or 'sexually transmitted infections') include:

• Syphilis.
• Gonorrhoea.
• Chlamydia.
• Genital herpes.
• HIV/AIDS — though there is some judicial debate on whether HIV counts as 'venereal disease' for S.13(1)(v) purposes given its different epidemiological profile.
• Hepatitis B (when sexually transmitted).
• Other sexually transmitted conditions.

4.4 Why 'Communicable Form' Requirement?

The 'communicable form' requirement reflects the legislative intent:

• The law is concerned with the RISK OF TRANSMISSION — both to the petitioner-spouse and potentially to any children born of the marriage.
• If the disease is cured or reduced to a non-communicable state, the risk is eliminated and divorce is not warranted on this ground.
• Some venereal diseases (like HIV) may remain communicable for long periods, while others are curable with treatment.

4.5 1976 Amendment — Removal of Time Period

Before the 1976 Amendment, S.13(1)(v) required that the respondent had been 'suffering from venereal disease in a communicable form, the disease not having been contracted from the petitioner' — AND required a minimum 3-year period. The 1976 Amendment SIMPLIFIED the provision:

• Removed the 3-year period requirement.
• Removed the 'not contracted from petitioner' qualification.
• Made any communicable venereal disease a ground, regardless of source and duration.

Note: Although the law no longer explicitly requires that the disease was not contracted from the petitioner, the general principle under S.23(1)(a) — that petitioner cannot take advantage of own wrong — means a petitioner who herself/himself transmitted the disease to the respondent might face bars.

4.6 HIV/AIDS — Modern Complication

HIV/AIDS presents complex issues under S.13(1)(v):

• HIV is transmitted through sexual contact — qualifying as 'venereal.'
• HIV remains communicable throughout the life of the infected person (though modern antiretroviral therapy can reduce viral load to non-detectable levels).
• Legal discrimination against persons with HIV violates constitutional rights.
• Courts have been cautious about treating HIV automatically as ground — considering individual circumstances, treatment status, and the other spouse's awareness.

Policy balance: The law must protect the other spouse from disease transmission while avoiding stigmatisation of persons with HIV/AIDS.

4.7 Landmark Cases on Venereal Disease

⚖️ Smt. Mayadevi v. Jagdish Prasad AIR 2007 SC 1426

Ratio: Supreme Court discussed venereal disease under S.13(1)(v). The disease must be COMMUNICABLE at the relevant time. Evidence of the condition being in transmittable form is required. Medical evidence establishing the diagnosis and communicability is essential.

⚖️ X v. Hospital Z (1998) 8 SCC 296

Ratio: Important Supreme Court decision on HIV/AIDS and matrimonial law. While primarily about medical confidentiality, the Court discussed implications of HIV status for marriage. Disclosure obligations to prospective spouse are crucial. Concealment of HIV status may constitute fraud under S.12(1)(c) or cruelty under S.13(1)(ia).

5. GROUND 7: RENUNCIATION OF THE WORLD — Section 13(1)(vi)

5.1 Text of Section 13(1)(vi)

Section 13(1)(vi) HMA provides that either spouse may seek divorce on the ground that the other party:

"has renounced the world by entering any religious order."

5.2 Essentials

1. Renunciation of the world: The respondent has renounced the world (samsara) — abandoned worldly life.
2. Entering a religious order: The renunciation must be by ENTERING A RELIGIOUS ORDER — formal entry into an organised religious community or institution.

5.3 Meaning of Renunciation

Renunciation (sannyasa, sannyas) is a classical Hindu concept. In traditional Hindu life-stage (ashrama) system, sannyasa is the fourth and final stage — complete withdrawal from worldly life, family, and possessions in pursuit of spiritual liberation. A person entering sannyasa:

• Performs renunciation ceremonies (which vary by tradition).
• Gives up family relationships (including matrimonial).
• Renounces possessions.
• Joins a religious order or mathās (monastery).
• Often adopts new name.
• Dons distinctive robes (saffron color in most Hindu traditions).
• Is considered 'civilly dead' in some traditional views.

5.4 Formal Entry into Religious Order Required

The statute requires FORMAL ENTRY into a religious order — mere personal spiritual practice, pilgrimages, or religious devotion are not enough. Recognised forms include:

• Joining an established Hindu monastery (math).
• Taking sannyasa from a recognised guru with traditional rites.
• Joining Buddhist sangha (though Buddhists are governed by HMA per S.2(1)(b)).
• Formal ordination in any organised religious order.

5.5 What Does NOT Constitute Renunciation

• Personal religious devotion or increased religiosity.
• Temporary retreats or sabbaticals.
• Wearing religious dress without formal ordination.
• Neglecting family due to religious preoccupation (could be cruelty but not renunciation).
• Joining a cult or unrecognised religious group (though individual cases may need examination).

5.6 Consequences

The classical Hindu view was that a person entering sannyasa is 'civilly dead' — all worldly relationships end. Modern interpretation of S.13(1)(vi) tempers this:

• The marriage does NOT automatically dissolve upon renunciation — the other spouse must file for divorce under S.13(1)(vi).
• Property consequences may be governed by customary rules of the specific religious order.
• The renouncing spouse generally loses inheritance rights (they are considered 'dead' for worldly purposes).

5.7 No Additional Period Required

S.13(1)(vi) does NOT require any waiting period. As soon as the respondent has formally entered a religious order, the ground is available.

5.8 No Alternate Relief Under S.13A

S.13A allows the court to grant judicial separation as alternative to divorce on most grounds — but expressly EXCLUDES grounds (ii), (vi), and (vii) of S.13(1). Thus, for renunciation, the court cannot grant judicial separation instead — divorce is the only available decree. The rationale: these grounds reflect situations of inherent breakdown where preserving the marriage serves no purpose.

5.9 Landmark Cases on Renunciation

⚖️ Sital Das v. Sant Ram AIR 1954 SC 606

Ratio: Pre-HMA case on renunciation. The Supreme Court discussed what constitutes formal entry into religious order. Requires specific ceremonial acts — shaving of head, performance of last rites for oneself, etc. (in orthodox sannyasa tradition). Not mere spiritual commitment.

⚖️ Krishna Singh v. Mathura Ahir AIR 1980 SC 707

Ratio: Held that for legal purposes, renunciation requires formal entry into a religious order with the prescribed ceremonies. The claimant must prove the ceremonial entry, not just spiritual status.

6. GROUND 8: PRESUMPTION OF DEATH — Section 13(1)(vii)

6.1 Text of Section 13(1)(vii)

Section 13(1)(vii) HMA provides that either spouse may seek divorce on the ground that the other party:

"has not been heard of as being alive for a period of seven years or more by those persons who would naturally have heard of it, had that party been alive."

6.2 Essentials

1. Not heard of as being alive: There must be NO COMMUNICATION OR INFORMATION indicating that the missing spouse is alive.
2. Seven years or more: The period must be at least 7 YEARS.
3. By those who would naturally have heard: The absence of information must be from persons who would normally have heard from the missing spouse — family members, close friends, colleagues, etc.

6.3 Seven-Year Rule

The 7-year period parallels the CIVIL PRESUMPTION OF DEATH under Section 108 of the Indian Evidence Act, 1872 (now Section 110 of Bharatiya Sakshya Adhiniyam, 2023). Under these provisions, if a person has not been heard of for 7 years by those who would naturally have heard of them, the burden of proving they are alive shifts to the party asserting they are alive.

6.4 Distinction from Civil Presumption of Death

6.5 Practical Importance

S.13(1)(vii) provides a CRUCIAL remedy for spouses of missing persons. Without this provision, the deserted spouse would be trapped in an undissolved marriage, unable to remarry without risking bigamy. S.13(1)(vii) allows:

• The deserted spouse to obtain divorce after 7 years of no communication.
• Subsequently remarry freely.
• Avoid the legal limbo of uncertain marital status.

6.6 What if the 'Dead' Spouse Returns?

A troubling issue: what happens if the spouse presumed dead under S.13(1)(vii) actually returns after divorce has been granted and the deserted spouse has remarried?

1. Divorce decree stands: The divorce under S.13(1)(vii) remains valid — it was properly obtained at the time.
2. Second marriage valid: The deserted spouse's second marriage (contracted after divorce) is valid — no bigamy.
3. First marriage ended: The first marriage was legally terminated by the divorce decree — the returning spouse cannot reclaim the first spouse as their wife/husband.
4. If second marriage was contracted WITHOUT divorce: Mere presumption of death under S.108 IEA does NOT automatically dissolve marriage. If the first spouse returns, the 'remarriage' based on presumption alone would be bigamous. Hence importance of obtaining S.13(1)(vii) divorce.

6.7 Landmark Cases on Presumption of Death

⚖️ Narain Singh v. State of Punjab AIR 1962 SC 1303

Ratio: Discussed the presumption of death under S.108 IEA. The presumption arises when a person has not been heard of for 7 years by those who would naturally have heard. The burden of proving life shifts to the party asserting the person is alive.

⚖️ L. Sulochana v. Late T.V.R. Sundaram AIR 1976 Mad 97

Ratio: Madras HC on S.13(1)(vii). The petitioner must show that the spouse has not been heard of for 7 years by family members, friends, and others who would naturally have known of them. Isolated absences or migrations for work without communication may not suffice.

⚖️ In re Poolla Satyanarayana AIR 1954 Mad 37

Ratio: Procedural aspects of presumption of death. Court can examine multiple family members and persons who would have had contact with the missing person. Documentary evidence (letters, messages received or not received) is relevant.

7. WIFE-SPECIFIC GROUNDS UNDER S.13(2) — BRIEF OVERVIEW

While the main focus of this topic is the S.13(1) grounds, a brief mention of the ADDITIONAL grounds available only to WIFE under S.13(2) is useful for exam completeness:

7.1 S.13(2)(i) — Pre-Act Bigamy

Husband had another wife living at the time of solemnisation (pre-HMA). Now largely of historical interest.

7.2 S.13(2)(ii) — Rape, Sodomy, Bestiality

Husband has been guilty of rape, sodomy, or bestiality since the marriage.

7.3 S.13(2)(iii) — Non-Cohabitation After Maintenance Order

After order/decree for maintenance under S.125 CrPC (now S.144 BNSS) or S.18 HAMA, no cohabitation for 1 year.

7.4 S.13(2)(iv) — Repudiation of Child Marriage

Wife married before age 15 can repudiate on attaining 15, before turning 18. Important provision protecting child brides.

8. SUMMARY TABLE — S.13(1) GROUNDS AFTER 2019 AMENDMENT

9. IMPORTANT POINTS FOR EXAM REVISION

1. S.13(1)(iii) Mental disorder: Two sub-grounds — incurable unsoundness + mental disorder making cohabitation unreasonable. Explanation defines mental disorder broadly. Strict interpretation per R. Lakshmi Narayan (2001).
2. 2019 Amendment — Leprosy deleted: S.13(1)(iv) is NO LONGER a ground. Personal Laws (Amendment) Act, 2019. Important recent legislative development.
3. S.13(1)(v) Venereal disease: Must be in COMMUNICABLE form. No specific period required (post-1976). HIV raises complex issues.
4. S.13(1)(vi) Renunciation: Must be FORMAL entry into religious order — not mere spiritual devotion. Sannyasa ceremonies with established religious order.
5. S.13(1)(vii) Presumption of death: 7 years no communication from those who would naturally have heard. Parallel to S.108 IEA / S.110 BSA. Crucial for remarriage after disappearance.
6. No additional period for (iii), (v), (vi): These grounds available immediately upon fulfillment of conditions.
7. S.13A exclusions: Alternative relief (judicial separation) NOT available for (ii), (vi), (vii) — court can only grant divorce.
8. Burden of proof: On petitioner for all grounds. Medical evidence essential for (iii) and (v). Ceremonial evidence for (vi). Communication evidence for (vii).
9. Strict vs. liberal interpretation: Mental disorder — strict (not to stigmatise). Venereal disease — mainly evidentiary. Renunciation — formal. Presumption of death — temporal requirement.

🧠 MNEMONIC: Post-2019 S.13(1) Grounds — ACDC-MVRD

Adultery, Cruelty, Desertion, Conversion — then — Mental disorder, Venereal, Renunciation, Death presumption. Remember: Leprosy deleted 2019. Ground (iv) now EMPTY.

🧠 MNEMONIC: Periods to Remember

Desertion: 2 years. Presumption of death: 7 years. Adultery: single act. Cruelty: no specific duration. Mental disorder: no specific duration. Venereal: no specific duration (post-1976). Renunciation: no period. Conversion: no period.

🎯 EXAM TIP

Critical exam points: (1) LEPROSY DELETED 2019 — common MCQ trap; (2) Mental disorder — strict interpretation per R. Lakshmi Narayan; (3) Venereal disease — must be COMMUNICABLE; (4) Renunciation — formal entry into religious order required; (5) Presumption of death — 7 years; (6) S.13A does NOT apply to (ii), (vi), (vii) — can only grant divorce, not judicial separation.

✨ Essay Strategy

For complete S.13 essay: start with overview (all 8 grounds, wife's additional 4), then detail each with: (a) Requirements; (b) Key case; (c) Period if any; (d) Special features. Mention 2019 amendment. Note that (ii), (vi), (vii) have no alternative relief under S.13A. For specific ground questions, follow: Text → Essentials → Proof → Landmark case → Comparisons/Exclusions.

10. PRACTICE QUESTIONS

Q1: Discuss mental disorder as a ground for divorce under Section 13(1)(iii) HMA. What are the two sub-grounds? How has the Supreme Court interpreted this provision?

Q2: Explain the 2019 amendment to Section 13(1)(iv) HMA. Why was leprosy removed as a ground for divorce? What was the rationale?

Q3: Discuss venereal disease as a ground for divorce under Section 13(1)(v) HMA. What constitutes 'communicable form'? How does HIV/AIDS fit within this provision?

Q4: What constitutes 'renunciation of the world' under Section 13(1)(vi) HMA? Is mere spiritual devotion sufficient? Support with case law.

Q5: Explain the presumption of death ground under Section 13(1)(vii) HMA. How does it relate to Section 108 of the Indian Evidence Act (now Section 110 BSA)? What if the presumed-dead spouse returns after divorce?

Q6: A wife of a Hindu husband discovers that he is suffering from schizophrenia that developed after marriage. His condition is severe and he refuses treatment. Can she seek divorce? What must she prove?

Q7: List and briefly explain all the grounds for divorce under Section 13(1) HMA after the 2019 amendment. Which grounds are available immediately and which require a statutory period?