consent and breakdown.

The former recognizes few grounds such as adultery and

conversion by the husband.
It is the latter statute, however, which calls for our attention: it re-enacts each of
the three theories of divorce in Sections 27 and 28. Many fault grounds are
recognized, including lengthy imprisonment, incurable insanity, leprosy,
presumption of death, over and above traditional fault grounds such as adultery and
cruelty. This broad outlook is reiterated by the Hindu Marriage Act, 1955.
JURISDICTION IN ENGLISH LAW Several fundamental changes have been effected
by the Domicile and Matrimonial Proceedings Act, 1973, following which the
jurisdiction of English courts has been limited to two grounds- domicile and
habitual residence. According to the statute, the first of these grounds is satisfied
if either party is domiciled in the country on the date of initiation of proceedings.
Moreover, a subsequent change in domicile would not alter the jurisdiction
already enjoyed by the English courts. The second ground of habitual residence
has been recognized in light of the Hague Conventions regarding the same. At the
same time, the term has not been defined, but left to be determined by factual
elements instead. This idea has been underlined by the Council of Europe on
Fundamental Legal Concepts thus: “in determining whether a residence is
habitual, account Is to be taken of the