NATIONAL LAW INSTITUTE UNIVERSITY BHOPAL

THIRD TRIMESTER
SOCIOLOGY OF LAW PROJECT
R. Srinivas Kumar vs R. Shametha
(Family Law Case)

SUBMITTED BY: SUBMITTED TO:

RADHA CHARPOTA PROF.TAPAN MOHANTY
2019 BALLB[HONS] 30

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 CERTIFICATE

This is to certify that the Project titled – R. Srinivas Kumar vs R. Shametha

(Family Law Case) has been prepared and submitted by Radha Charpota ,who is currently
pursuing her BA LLB .(Hons.) at National Law Institute University, Bhopal in fulfillment of
Sociology of Law course .It is also certified this is original research report and this project has
not been submitted to any other university ,nor published in any journal.

Date:

Signature of the research supervisor:

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 ACKNOWLEDGEMENT

This project has been made possible by the unconditional support of many people, I would like
to acknowledge and extend my heartfelt gratitude to Prof. Tapan Mohanty for guiding me
throughout the development of this project into a coherent whole by providing helpful insights
and sharing their brilliant expertise. I also would like to thank the members of the library staff
and computer section for the cooperation in making available the books and accessing the
internet even during their free time. I am deeply indebted to my parents, seniors and friends for
all the moral support and encouragement.

Radha Charpota
2019 BALLB [HONS] 30

TABLE OF CONTENTS

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INTRODUCTION…………………………………………………………………...I
OBJECTIVES………………………………………………………………………..II

CONCLUSION………………………………………………………………………21
BIBLIOGRAPHY……………………………………………………………………22

INTRODUCTION:

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The Special Marriages Act and the Hindu Marriage Act do not recognize ‘Irretrievable Break
Down of Marriage’ as a ground for divorce. However, despite this fact, the Supreme Court has
held that ‘Irretrievable Break down’ of marriage constitutes a ground for divorce.In a recent
appeal before the Supreme Court, the Court dissolved the marriage on grounds that the marriage
had irretrievably broken down. The Appeal was lodged against the decision of the Andra Pradesh
High Court wherein, despite the fact that there was evidence that the couple had lived separately
for 22 years, the High Court refused to make the order of divorce because the Petitioner’s wife
refused to give her consent for the divorce.

 At the Supreme Court, the two-man bench consisting of Justices S.K. Kaul and M.R.
Shah, invoked the Court’s inherent powers under Article 142 of the Constitution, and granted the
divorce, holding that the marriage had broken down irretrievably.The Supreme Court has
previously issued verdicts mandating the lawmakers to amend the requisite legislation, by
introducing the ‘Irretrievable Breakdown’ as a ground for divorce. The Supreme Court’s verdicts
have not been obeyed.

 Also, in its 1978 and 2009 Reports, the Law Commission had recommended that immediate
actions should be taken to amend the requisite laws by introducing the ‘Irretrievable Breakdown’
ground, especially where wedlock has become a deadlock. Unfortunately, the recommendation
has not been carried out.The laws remain unamended. Due to this, many Petitioners have been
denied divorce even when it is shown that the couples have been living separately for many
years, and their relationship cannot be repaired.As a means of doing justice, the Supreme Court
has been compelled, on a number of occasions, to resort to invoking its power under Article 142,
in order to dissolve a marriage where it is evident that the marriage is emotionally dead, totally
unworkable, cannot be salvaged, and has irretrievably broken down.

OBJECTIVES:

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HYPOTHESIS:
Short-term changes, as in family developmental stages, may be obvious and easy to comprehend,
but they may not actually constitute changes at all in the long run.

METHOD OF STUDY:
This project is largely based on doctrinal method of data collection

REVIEW OF LITERATURE:
The Indian codified laws nowhere expressly talks about irretrievable breakdown of marriage as
ground for divorce. Section 13 of the Hindu Marriage Act, 1955 provides for the grounds for the
Divorce. Section 27 of the Special Marriage Act, 1954 also provides grounds for divorce but it is
applicable only if the marriage is solemnized under the said Act. Section 2 of The Muslim
Dissolution of Marriage Act also provides for various grounds of divorce to a Muslim woman.
However none of the legislation expressly deals with irretrievable breakdown of marriage as a
ground for divorce.
The Law Commission of India in its 71st Report titled “The Hindu Marriage Act, 1955 –
Irretrievable Breakdown of Marriage as a Ground of Divorce” recommended amendments in the
Hindu Marriage Act to make irretrievable breakdown of marriage as a new ground for granting
divorce among the Hindus. However it was never accommodated. Similarly in it 217 th report
again the Law Commission of India again upon intensive research and examining of various
judgments suggested that of the Supreme Court and High Courts on the subject and is of the
view that “irretrievable breakdown of marriage” should be incorporated as another ground for
granting divorce under the provisions of the Hindu Marriage Act, 1955 and the Special Marriage
Act, 1954. The Court before granting a decree for divorce on the ground that the marriage has
irretrievably broken down should also examine whether adequate financial arrangements have
been made for the parties and children.

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Accordingly the parliament introduced marriage law (amendment) Bill, 2010 which contained
irretrievable breakdown of marriage as a ground for divorce. However the bill never passed and
therefore has not taken a shape of law.
However the judiciary has actively taken cognizance of the fact that marriages do get
irretrievably broken down and it becomes necessary in societal interest to dissolve such
relationships. Therefore the Supreme Court at multiple instances has granted divorce on the
ground of irrevocable breakdown of marriage under Article 142 of the Constitution.

IRRETRIEVABLE BREAKDOWN OF MARRIAGE:

Why Irretrievable Breakdown?

The theoretical basis for including the irretrievable breakdown of marriage as a ground for
divorce is now commonly known among lawyers and jurists. Restricting the ground of divorce to
a particular offence or matrimonial disability causes injustice in those cases where the situation is
such that although none of the parties is at fault, or the fault is of such a nature that the parties to
the marriage do not wish to divulge it, yet there has arisen a situation in which the marriage
cannot be worked; that is, where the marriage has all external appearances of marriage but none
of the reality. In such circumstances, there is hardly any utility in maintaining the marriage as a
façade, when the emotional and other bounds which are the essence of marriage have
disappeared. After the marriage has ceased to exist in substance and in reality, there is no reason
for denying divorce. Divorce should be seen as a solution and a way out of a difficult situation.

Merits And Demerits of The Concept of Irretrievable Breakdown of Marriage

A law of divorce based mainly on fault is inadequate to deal with a broken marriage. Under the
faulty theory, guilt has to be proved; divorce courts are presented concrete instances of human
behavior as bring the institution of marriage into disrepute. Because of the divorce of
matrimonial offence, judges, and lawyers are sometimes reduced to the role of scavengers. The
lawyers have to look for and expose and the judges are confronted with, the worst obscenities
within a married life. It is therefore, not surprising that with the present adversary system all
types of allegations are freely hurled across the courtroom. We need not stand on an old divorce
law which demands that men and women must be found innocent or guilty .

One cannot say that it is an enhancement of the respondent for marriage if there are tens of
thousands of men and women desperately anxious to regularize their position in the community
and they are unable to do so. People should be able to marry again where they can obtain a death
certificate in respect of a marriage already long since dead. The objection that irretrievable
breakdown as a ground of divorce is vague has been already dealt with. Other objections to it
may be dealt with-
a) Irretrievable breakdown allows the spouses, or even one spouse, to terminate the marriage at
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will, thus transforming marriage from a union for life into one which can be ended at pleasure,

b) It is necessary to the basic principle that no man should be allowed to take advantage of his
own wrong; a spouse who was responsible for the breakdown of marriage should not be able to
rely on such breakdown in order to obtain a divorce against his or her partner’s will. By
authorizing one spouse to divorce the other against the latter’s will after separation for a specific
period, the law will have given statutory recognition for the first time to the principle that a
person may take advantage of his or her own wrong.

The theory that one cannot take advantage of one’s own wrong has not been adhered to in the
Hindu Marriage Act in the past. According to clause (ii) of sub section (1A) of section 13 of the
Act, either party to a marriage, whether solemnized before or after the commencement of this
Act, may present a petition for the dissolution of the marriage by a decree of divorce on the
ground that there has been no restitution of conjugal rights as between the parties to the marriage
for a period of one year or afterwards after the passing of a decree for the restitution of conjugal
rights in proceedings to which they were parties. This provision clearly contemplates that even
the party which has been in the wrong in so far as it has failed to comply with a decree for
restitution of conjugal rights can also apply for a decree of divorce on the ground that there has
been no restitution of conjugal rights as between the parties to the marriage for a period of one
year or upwards after the passing of the decree for restitution of conjugal rights in a proceeding
to which they were parties. Such a party, though at fault, would thus be taken advantage of its
own fault. It cannot therefore be said that under the provision of the Hindu Marriage Act, as they
stand at present, no person can be allowed to take advantage of his own wrong.

Thus, once the marriage has broken down beyond repair, it would be unrealistic for the law not
to take notice of that fact, and it would be harmful to society and injurious to the interests of the
parties if the legal bond is sought to be maintained notwithstanding the disappearance of the
emotional substratum. Such a course would encourage continuous bickering perpetual bitterness,
and may often lead to immorality. Where there has been a long period of continuous separation,
it may fairly be surmised that the matrimonial bond is beyond repair. The marriage becomes a
fiction, though supported by a legal tie. By refusing to sever that tie the law in such cases does
not serve the sanctity of marriage; on the contrary, it shows scant regard for the feelings and
emotions of the parties.

Since there is no acceptable way in which a spouse can be compelled to resume life with the
consort, nothing is gained by trying to keep the parties tied for ever to a marriage that in fact has
ceased to exit. Marriage is lifelong cohabitation in the home. When the prospect of continuing
cohabitation has ceased, the legal tie should be dissolved.

Factual Background
The appellant and the respondent got married in accordance with Hindu rites in the year 2000.
The parties co-lived for a period of two months, after which the respondent-wife went to Canada,
where she eventually obtained citizenship in 2002. The appellant alleged that the respondent
went to Canada without his consent. The respondent returned to Indian only after she got her
Canadian citizenship in 2002.

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Even after coming back, there were continuous quarrels between the parties. Owing to the same,
Panchayat had intervened and further asked the parties to reside separately from their family.
Even this solution did not prove to be effective. Subsequently, the respondent left to Canada
again.
This prompted the appellant to file for a divorce Section 13(1)(a) of the Hindu Marriage Act,
1955 on the ground of cruelty before the lower Court. The appellant contended that the
loneliness and lack of co-habitation had caused him extreme physical and mental torture.
Despite his reluctance to go to Canada, he had signed the immigration papers in order to save his
marriage, the appellant stated. However, the papers were never submitted. In fact, the appellant
stated that the respondent herself had reached Canada on improper travel documents.
The respondent, in her arguments, blamed the appellant for abandoning her and made various
other allegations relating to dowry, physical assault and extra-marital affairs.
She also claimed that she was forced to have an abortion when she was taken to a doctor once.
The appellant denied this allegation and stated that the respondent was never pregnant.
After hearing the arguments from both sides, the Additional District Judge granted a decree of
divorce against which an appeal was filed before the High Court of Punjab. Interestingly, the
High Court set aside the decree of divorce, attributing various allegations exchanged between the
parties to the wear and tear of marriage and “inflamed passions”. The High Court judge had
opined that these were not adequate to knock down the walls of marriage.
Aggrieved, the appellant-husband filed an appeal before the Supreme Court. The respondent-
wife, in the meanwhile, expressed consent to continue to staying with the appellant.

JUDGMENT
M.R. SHAH, J.
Feeling aggrieved and dissatisfied with the impugned judgment and order dated 06.02.2012
passed in C.M.A. No. 4142 of 2003 by the High Court of Judicature Andhra Pradesh at
Hyderabad, by which the High Court has dismissed the said appeal preferred by the appellant-
husband and has confirmed the judgment and order passed by the learned Family Court refusing
to pass a decree of divorce against the respondent-wife, the appellant-husband has preferred the
present appeal.
2. That the marriage of the appellant and the respondent took place on 09.05.1993. That out of
the said wedlock, the respondent gave birth to a male child on 29.08.1995. It appears that there
were differences of opinion between the parties and according to the appellanthusband, cruelty
was meted out to him. Up to 1997, many a times, the respondent-wife stayed at her parental
house. The appellant-husband filed a divorce petition in the year 1999 being O.P. No. 157 of
1999 before the Family Court at Hyderabad. That the said petition was filed for a decree of
divorce against the respondent-wife under Section 13(1) (ia) and (ib) of the Hindu Marriage Act,

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1955. That the learned Family Court dismissed the said divorce petition by observing and
holding that the appellant-husband has failed to prove the cruelty by the respondent-wife. The
Family Court also refused to pass a decree of divorce on the ground of irretrievable breakdown
of marriage.
2.1 Feeling aggrieved and dissatisfied with the judgment and order passed by the Family Court at
Hyderabad dated 04.09.2003 in O.P. No. 157 of 1999 dismissing the divorce petition, the
appellant-husband preferred an appeal before theHigh Court. Before the High Court also, the
appellant-husband sought a decree of divorce on the ground of irretrievable breakdown of
marriage. By the impugned judgment and order, the High Court has dismissed the said appeal.
Hence, the appellant-husband is before this Court by way of the present appeal.
3. Shri Guru Krishna Kumar, learned Senior Advocate appearing on behalf of the appellant-
husband has made strenuous efforts to upset the findings recorded by both the courts below on
cruelty. In the alternative, it is vehemently submitted by Shri Guru Krishna Kumar, learned
Senior Advocate appearing on behalf of the appellant-husband that both the appellant-husband
and the respondent-wife are residing separately since last 22 years and that it is impossible to
save the marriage and that there is no chance of marriage surviving and it is broken beyond
repair. It is submitted that therefore as there is irretrievable breakdown of marriage it is in the
fitness of the things to dissolve the marriage even in exercise of the powers under Article 142 of
the Constitution of India and to do substantial justice to the parties.
3.1 In support of his alternative submission to dissolve the marriage on the ground of
irretrievable breakdown of marriage, learned Senior Advocate has heavily relied upon the
following decisions of this Court, Durga Prasad Tripathy v. Arundathi Tripathy (2005) 7 SCC
353; Naveen Kohli v. Neelu Kohli (2006) 4 SCC 558; Sanghamitra Ghosh v. Kajal Kumar
Ghosh (2007) 2 SCC 220; Samar Ghosh v. Jaya Ghosh (2007) 4 SCC 511; K. Srinivas Rao v.
D.A. Deepa (2013) 5 SCC 226; and Sukhendu Das v. Rita Mukherjee (2017) 9 SCC 632.
3.2 Shri Guru Krishna Kumar, learned Senior Advocate appearing on behalf of the appellant-
husband has also stated at the Bar that the appellant-husband is ready and willing to pay a
reasonable permanent alimony to the respondent-wife in case a decree of dissolution of marriage
is granted to the appellant husband.
4. The present appeal is vehemently opposed by Shri Jayant Kumar Mehta, learned Advocate
appearing on behalf of the respondent-wife. He has vehemently submitted that this is not a fit
case to dissolve the marriage between the appellant and the respondent on the ground of
irretrievable breakdown of marriage, in exercise of the powers under Article 142 of the
Constitution of India.
4.1 It is vehemently submitted by the learned Advocate appearing on behalf of the respondent-
wife that a decree of divorce cannot be granted on the ground of irretrievable breakdown of
marriage, if either of the parties is not willing and has not consented to such dissolution. It is
submitted that only in a case where both the parties to the marriage agree and/or give consent,
the marriage can be dissolved and a decree of divorce can be passed on the ground of
irretrievable breakdown of marriage.

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4.2 Making the above submissions and relying upon the following decisions of this Court in the
cases of Chetna Dass v. Kamla Devi (2001 4 SCC 250; Vishnu Dutt Sharma v. Manju Sharma
(2009) 6 SCC 379; Hitesh Bhatnagar v. Deepa Bhatnagar (2011) 5 SCC 234; Darshan Gupta v.
Radhika Gupta (2013) 9 SCC 1; and Manish Goel v. Rohini Goel (2010) 4 SCC 393, it is prayed
to dismiss the present appeal.
5. We have heard the learned counsel for the respective parties at length.
5.1 At the outset, it is required to be noted and does not seem to be in dispute that since last 22
years both the appellant-husband and the respondent-wife are residing separately. It also appears
that all efforts to continue the marriage have failed and there is no possibility of reunion because
of the strained relations between the parties. Thus, it appears that marriage between the
appellant-husband and the respondent-wife has irretrievably broken down. In the case of Hitesh
Bhatnagar (supra), it is noted by this Court that Courts can dissolve a marriage as irretrievably
broken down only when it is impossible to save the marriage and all efforts are made in that
regard and when the Court is convinced beyond any doubt that there is actually no chance of the
marriage surviving and it is broken beyond repair.
5.2 In the case of Naveen Kohli (supra), a three Judge Bench of this Court has observed as under:
“74. ……Once the marriage has broken down beyond repair, it would be unrealistic for the law
not to take notice of that fact, and it would be harmful to society and injurious to the interests of
the parties. Where there has been a long period of continuous separation, it may fairly be
surmised that the matrimonial bond is beyond repair. The marriage becomes a fiction, though
supported by a legal tie. By refusing to sever that tiethe law in such cases does not serve the
sanctity of marriage; on the contrary, it shows scant regard for the feelings and emotions of the
parties.
85. Undoubtedly, it is the obligation of the court and all concerned that the marriage status
should, as far as possible, as long as possible and whenever possible, be maintained, but when
the marriage is totally dead, in that event, nothing is gained by trying to keep the parties tied
forever to a marriage which in fact has ceased to exist….
86. In view of the fact that the parties have been living separately for more than 10 years and a
very large number of aforementioned criminal and civil proceedings have been initiated by the
respondent against the appellant and some proceedings have been initiated by the appellant
against the respondent, the matrimonial bond between the parties is beyond repair.
A marriage between the parties is only in name. The marriage has been wrecked beyond the hope
of salvage, public interest and interest of all concerned lies in the recognition of he fact and to
declare defunct de jure what is already defunct de facto….”
[emphasis supplied]
A similar view has been expressed in the case of Samar Ghosh (supra).

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In the similar set of facts and circumstances of the case, this Court in the case of Sukhendu Das
(supra) has directed to dissolve the marriage on the ground of irretrievable breakdown of
marriage, in exercise of powers under Article 142 of the Constitution of India.
6. Now so far as submission on behalf of the respondent-wife that unless there is a consent by
both the parties, even in exercise of powers under Article 142 of the Constitution of India the
marriage cannot be dissolved on the ground of irretrievable breakdown of marriage is concerned,
the aforesaid has no substance. If both the parties to the marriage agree for separation
permanently and/or consent for divorce, in that case, certainly both the parties can move the
competent court for a decree of divorce by mutual consent. Only in a case where one of the
parties do not agree and give consent, only then the powers under Article 142 of the Constitution
of India are required to be invoked to do the substantial Justice between the parties, considering
the facts and circumstances of the case. However, at the same time, the interest of the wife is also
required to be protected financially so that she may not have to suffer financially in future and
she may not have to depend upon others.
7. This Court, in a series of judgments, has exercised its inherent powers under Article 142 of the
Constitution of India for dissolution of a marriage where the Court finds that the marriage is
totally unworkable, emotionally dead, beyond salvage and has broken down irretrievably, even if
the facts of the case do not provide a ground in law on which the divorce could be granted. In the
present case, admittedly, the appellant-husband and the respondent-wife have been living
separately for more than 22 years and it will not be possible for the parties to live together.
Therefore, we are of the opinion that while protecting the interest of the respondent-wife to
compensate her by way of lump sum permanent alimony, this is a fit case to exercise the powers
under Article 142 of the Constitution of India and to dissolve the marriage between the parties.
8. In view of the above and for the reasons stated above, the application for divorce filed by the
appellant-husband for dissolution of marriage is hereby allowed. The marriage between the
appellant-husband and the respondent-wife is ordered to be dissolved in exercise of powers
under Article 142 of the Constitution of India on the condition and as agreed by the learned
Senior Advocate appearing on behalf of the appellant-husband that the appellant-husband shall
pay to the respondent-wife a lump sum permanent alimony, quantified at Rs.20,00,000/( Rupees
Twenty Lakhs) to be paid directly to the respondent-wife by way of demand draft within a period
of eight weeks from today. Till the permanent alimony as above is paid to the respondent-wife,
the appellant-husband to continue to pay the maintenance as being paid to her.
9. The appeal is allowed in the aforesaid terms. No costs.

However, one must also take consideration of the fact that it is the choice of the parties to a valid
marriage to understand the importance of the institution and to preserve its sanctity. With the
changing requirements, attitude and aptitude, the society has drastically changed and it is very
difficult for the married couples to cope with change. While adjusting in a new atmosphere in the
matrimonial home, spouses may commit, knowingly or unknowingly, with or without intention,
whether economical dependent or independent, some kind of mistakes which may lead to a

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communication gap between them and create havoc in the matrimonial home. Where both the
parties of a valid marriage are at fault of any kind of matrimonial offence, it is difficult to prove
which one is an aggrieved party.

According to the Doctrine of Recrimination, no remedy can be granted to the party who is at
fault. It is imperative in law to have one party as innocent and another at fault to provide a
matrimonial relief. In case of no fault theory of divorce, it is not necessary to prove which party
is at fault. There may be many reasons based on which sweetness of matrimonial relationship is
at risk. If the parties prove with reliable evidence on record that their marriage is beyond all
possible repairs then law should understand the reality of the facts and should help the parties to
the marriage which has broken down irretrievably.

The breakdown theory of divorce which is inherently attached with no fault theory of divorce
represents the modern view of divorce. Under this theory, the law realizes a situation and says to
the unhappy couple: if you can satisfy the Court that your marriage has broken down, and that
you desire to terminate a situation that has become intolerable, then your marriage shall be
dissolved, whatever may be the cause. The marriage can be said to be broken when the objects of
the marriage cannot be fulfilled. When there is not an iota of hope that parties can be reconciled,
it can be considered as irretrievable breakdown of marriage.

Criticism
The concept of irretrievable breakdown of marriage to be made a ground for divorce under the
Hindu Marriage Act, 1955 has been although a lot more debated but it has equally been
criticized at various points by the state High courts and The Government of India. They can be
summarized as follows:-

Criticism by the High Court: High Court has in many cases, expressed disagreement with the
suggestion that the Hindu Marriage Act, 1955 should be amended with a view to making
irretrievable breakdown of marriage as a good ground for grant of a decree of divorce.

The judges of the High Courts have expressed themselves against the introduction of
irretrievable breakdown as a ground of divorce. One of the points made in the reply of the High
Court is that it is extremely difficult to say that the husband and wife would never live together
merely because there has been a rift between them and for the time being it appears that there
may not be any prospect of their living together.

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The mere fact that there has been a rift between the parties or that they are for the time living
apart does not mean that the marriage has come to an end.
It is possible that what may appear to one person to be irretrievable may appear to another as
not yet beyond repair. But such a state of things cannot be allowed to continue indefinitely, and
there must arrive a point of time when one of the parties should be permitted to seek the
judgment of the court as to whether there is or there is not a possibility of the marriage being
retrieved.

Criticism by the Govt.: The Government of India, Ministry of Education, Department of Social
Welfare, has expressed the review that making irretrievable breakdown of marriage a ground
for grant of a decree of divorce is redundant in the light of the fact that sufficient grounds
covering ‘irretrievable breakdown of marriage’ exist in the Hindu Marriage Act and the
Marriage Laws Amendment Act, 1976, for the purpose of seeking divorced.

Thus we see that though a lot of authorities have deliberated upon the aspect of irretrievable
breakdown of marriage as a ground for divorce there has also been a vast majority of
authorities that have seen the drawbacks behind this concept of breakdown theory and are not
in favor of its legislative birth and implementation.

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Conclusion
Thus to conclude, it can be said that marriage is an institution in the maintenance of which the
public at large is deeply interested. It is the foundation of the family and in turn of the society
without which no civilization can exist. This foundation presupposes the existence of a platform
build on the basis of sound understanding between the spouses. If this understanding is missing
between the spouses and the marriage is a continuous malady, then it is desirable that the
marriage should be dissolve with the intervention of the court. There is no useful purpose served
by continuing such a marriage. Thus, on the basis of "irretrievable breakdown theory" such
marriage should be dissolved for the common betterment of both the spouses.

This is the reason why the attitude of legislature changed from the "guilt theory" to the "divorce
by mutual consent" (the consent theory). There may be a case where relation of the parties has
broken down irretrievably and there is no chance of reconciliation and they are also not ready for
divorce by mutual consent. In that eventuality continuing such relation is futile and as per
Irretrievable Breakdown of Marriage theory such marriage should be dissolved. It is high time
that we appreciate the need of Irretrievable Breakdown of Marriage theory so that spouses can
have a new and better life instead of wasting their "young days" in courts

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BIBLIOGRAPHY:

WEBSITES:
 http://www.thehindu.com/news/national/bill-to-make-divorce-easier-may-be-
dropped/article6910089.ece
 http://www.ndtv.com/india-news/law-ministry-puts-proposal-to-amend-marriage-bill-on-
hold-780561
 NALSAR Law Review on Irretrievable Breakdown of Marriage.
 http://www.legalserviceindia.com/articles/irrbdom.htm
 http://www.legalserviceindia.com/articles/break_mar.html

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