A FAMILY LAW PROJECT

ON

"DIVORCE BY MUTUAL CONSENT UNDER HINDU LAW AND

MUSLIM LAW"

[Submitted as a partial fulfillment of B.A.LL. B (Hons.) 5-year integrated course]

Submitted on: September 30, 2023

Submitted by: Submitted to:

Vinayak Sharma Dr. Juhi

Pawa

Roll No. – 115 Faculty – Family

Law

Semester: V – B

University Five Year Law College

Rajasthan University
 Jaipur

CERTIFICATE

Dr. Juhi Pawa Date: September 30, 2023

Faculty
University Five Year Law College

This is to certify that Vinayak Sharma of V Semester of University Five Year Law College,
University of Rajasthan has carried out the project entitled “DIVORCE BY MUTUAL
CONSENT UNDER HINDU LAW AND MUSLIM LAW” under my supervision and
guidance. It is an analysis report of a minor project. The student has completed research work in
my stipulated time and according to the norms prescribed for the purpose.

Supervisor

1
 DECLARATION

I, Vinayak Sharma, hereby declare that this project entitled “DIVORCE BY MUTUAL
CONSENT UNDER HINDU LAW AND MUSLIM LAW” based on the original research
work carried out by me under the guidance and supervision of Dr. Juhi Pawa.

The interpretations put forth are based on my reading and understanding of the original Texts,
the books, articles and the websites etc. Which have been relied upon by me has been duly
acknowledged at the respective places in the text.

For the present project which I am submitting to the university, no degree or diploma has been
conferred on me either, in this or in other university.

Date: September 30, 2023

Vinayak Sharma

Roll no. 115

Semester: V – B

2
 ACKNOWLEDGEMENT

I have written this project “DIVORCE BY MUTUAL CONSENT UNDER HINDU LAW
AND MUSLIM LAW” under the supervision of Dr. Juhi Pawa, Faculty, University Five
Year Law College, University of Rajasthan, Jaipur. Her Valuable suggestions herein have not
only helped me immensely in making this work but also in developing an analytical approach
this work.

I found no words to express my sense of gratitude to Director Dr. Akhil Kumar and Dy.
Director Sandeep singh for constant encouragement at every step.

I am extremely grateful to librarian and library staff of the college for the support and
cooperation extended by them from time to time.

Vinayak Sharma

3
 TABLE OF CONTENTS

CERTIFICATE................................................................................................................................1

DECLARATION.............................................................................................................................2

ACKNOWLEDGEMENT...............................................................................................................3

TABLE OF CONTENTS................................................................................................................4

INTRODUCTION...........................................................................................................................5

RESEARCH METHODOLOGY....................................................................................................6

OBJECTIVES OF THE RESEARCH.............................................................................................6

RESEARCH QUESTIONS.............................................................................................................6

CHAPTER – I..................................................................................................................................7

DIVORCE BY MUTUAL CONSENT UNDER HINDU LAW.....................................................7

 DIVORCE BY MUTUAL CONSENT UNDER HINDU LAW..........................................8

 GROUNDS FOR DIVORCE BY MUTUAL CONSENT UNDER SECTION 13B...........8

 OTHER CONDITIONS OF DIVORCE BY MUTUAL CONSENT...................................8

 JURISDICTION FOR DIVORCE BY MUTUAL CONSENT............................................9

CHAPTER – II..............................................................................................................................12

DIVORCE BY MUTUAL CONSENT UNDER MUSLIM LAW................................................12

CONCLUSION..............................................................................................................................16

BIBLIOGRAPHY..........................................................................................................................17

 BOOKS REFERRED.........................................................................................................17

 WEB SOURCES................................................................................................................17

4
 INTRODUCTION

Marriage forms the basis of the most important institution of a civilised society, i.e., the family,
an indivisible part of a civilised society. However, the foundation of family is formed on the
institution of sacramental value, namely, marriage.
Divorce by mutual consent is a legal procedure that allows a married couple to end their
marriage by jointly agreeing to divorce without any allegations or fault. It is a consensual way of
dissolving a marriage where both spouses voluntarily decide to part ways. The concept revolves
around the idea that marriage is a personal and consensual union, and if both spouses no longer
wish to continue the relationship, they should have the freedom to do so amicably and without
unnecessary legal battles. Divorce by mutual consent promotes the idea of a dignified exit from a
failed marriage, emphasizing the importance of the individuals' autonomy and their right to make
decisions about their own lives.
Divorce by mutual consent is seen as a more peaceful and less adversarial way to end a marriage
compared to contested divorces. It reduces the burden on the legal system and the emotional
stress on both parties, especially when there are children involved. When couples can divorce
amicably, it often leads to better co-parenting relationships, which is in the best interest of any
children from the marriage. This is particularly relevant in contemporary society, where co-
parenting is encouraged and valued. The concept of divorce by mutual consent also plays a role
in promoting gender equality. It allows both spouses, regardless of gender, to have an equal say
in the decision to divorce and its terms, fostering a more equitable approach to marital
dissolution.
In India, divorce by mutual consent is codified in family laws, providing a structured and legally
recognized framework for couples to follow. This legal recognition ensures that the rights and
responsibilities of both spouses are protected. It provides an alternative to traditional, adversarial
divorce processes, aligning with the evolving views on marriage and relationships in modern
times.1

1
https://nbassociates.net/

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 RESEARCH METHODOLOGY

The researcher has adopted doctrinal method research. The researcher has made extensive use of
available resources at the library of University Five Year Law College, University of Rajasthan
and also internet resources.

OBJECTIVES OF THE RESEARCH

1. Divorce by mutual consent under Hindu law.

2. Divorce by mutual consent under Muslim law or Islamic law.

RESEARCH QUESTIONS

1. Is the six-month waiting period mandatory for getting a divorce by mutual consent?
2. Whether consent can be unilaterally withdrawn for divorce by mutual consent?

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 CHAPTER – I
DIVORCE BY MUTUAL CONSENT UNDER HINDU LAW

The Hindu Marriage Act, 1955, is a significant legislation that governs marriage and divorce
among Hindus in India. It provides a legal framework for regulating Hindu marriages and
divorce. The Act applies to Hindus, Buddhists, Jains, and Sikhs, and it covers issues related to
marriage, divorce, maintenance, and child custody among others.

The Hindu Marriage Act, 1955 enshrines the right to divorce by way of mutual consent under
Section 13B. The divorce law for Hindus is provided under Section 13 of the Hindu Marriage
Act 1955. The spouses can jointly file a petition seeking divorce under Section 13B before the
family court, which possesses the jurisdiction to pass such a decree of divorce under Section
13B. The Section expressly mentions the conditions under which the spouses can file a petition
for the grant of divorce by mutual consent. Section 13 B of Hindu Marriage Act, 1955 and
Section 28 of the Special Marriage Act, 1954 require the couple to be living separately for at
least one year before divorce proceedings can begin. Section 10A of Divorce Act, 1869,
however, requires the couple to be separated for at least two years. Do note that living separately
does not necessarily mean living in different locations; the couple only needs to prove that they
have not been living as husband and wife during this time period.2
Under Hindu law, couples seeking divorce by mutual consent must fulfil certain conditions,
including:
 Both spouses must have lived separately for at least one year before filing for divorce.
 They must jointly state that they have been unable to live together and have mutually
decided to dissolve the marriage.
 There should be no coercion or undue influence on either party.
Mutual means ‘two or more people feeling the same emotion or doing the same thing to each
other or for each other.
Mutual consent means ‘as agreed by the people involved.

Divorce means ‘the legal dissolution of a marriage by a court or other competent body’ or
legally dissolving one’s marriage.

2
https://blog.ipleaders.in/mutual-consent-divorce/

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 DIVORCE BY MUTUAL CONSENT UNDER HINDU LAW

The divorce law for Hindus is provided under Section 13 of the Hindu Marriage Act 1955.
Section 13B talks about Divorce by mutual consent. Section 13B was inserted in Hindu Marriage
Act by Amendment Act 1976. Section 13B provides that a petition for dissolution of marriage by
a decree of divorce by mutual consent may be presented in the district court by both husband and
wife together. Such a petition can be presented on the grounds provided in Section 13B of HMA.

 GROUNDS FOR DIVORCE BY MUTUAL CONSENT UNDER SECTION 13B

Section 13B provides the following grounds on which a petition for dissolution of marriage by
way of divorce by mutual consent can be presented in court:

1) Both husband and wife have been living separately for a period of one year or more, and
2) They have not been able to live together, and
3) They have mutually agreed that the marriage should be dissolved.

The above are the explicit conditions which are provided under section 13B of the Hindu
Marriage Act. All the above grounds are mandatory before a petition for dissolution of marriage
is presented in court. If any of the above grounds are missing in the petition for dissolution of
marriage, the Court may reject such a petition.3

 OTHER CONDITIONS OF DIVORCE BY MUTUAL CONSENT

Besides the grounds provided in Section 13B of the Hindu Marriage Act, there are some other
conditions. These conditions the court may weigh before granting a decree of divorce by mutual
consent. These are:

(1) Marriage is solemnised as per Hindu Laws.

(2) Parties to marriage i.e., husband and wife must have settled all their dispute or differences if
any. They must have entered in full and final understanding. Nothing should be left, which
may be a reason for future contentions or litigation between the parties to the marriage. If any
permanent alimony is to be given, the wife must have received all amount of alimony, or if
the alimony is to be given on future dates, the husband and wife must have entered into a
written understanding to that respect.

3
https://www.legalserviceindia.com/

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(3) If Parties to marriage i.e., husband and wife have any child, they must have entered into an
understanding as to how the child to be raised. There must be a clear understanding of
custody and how to finance child education.

 DIVORCE BY MUTUAL CONSENT PROCESS UNDER SECTION 13B HINDU

MARRIAGE ACT 1955

The followings are Divorce by mutual consent process under Section 13B as in the Hindu
Marriage Act 1955.

 First – Parties to marriage i.e., husband and wife filing a joint petition for divorce by mutual
consent in the court of law.
 Second – Court makes inquires and takes statements of the Parties.
 Third – Court passes an order. Gives parties a cooling-off period minimum of six months.
 Fourth – Parties present a second motion. This second motion must be presented after six
months of the court’s first order and before the expiry of eighteen months.
 Fifth – The court hears both parties. The court makes inquiries for its satisfaction as to
whether the marriage was solemnised and whether the averments made in the petition are
true.
 Sixth – Once being satisfied and taking the statements of the parties, Court passes a decree
4
of dissolution of marriage.

 JURISDICTION FOR DIVORCE BY MUTUAL CONSENT

The question of where to file a divorce by mutual consent is also important. As per section 19 of
the Hindu Marriage Act (HMA) of 1955, a petition for divorce by mutual consent can be filed in
the district court where:

1. The marriage was solemnised; or

2. Parties to marriage last resided together, or
3. Where the wife is residing on the date of the filing of the petition, or
4. Where one petitioner resides in India and the other is outside India, where the petitioner
reside.

4
https://www.jstor.org/

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 Is the six-month waiting period mandatory for getting a divorce by mutual consent?
Getting a divorce is a very serious matter, it can destroy and separate families. But, on the other
hand, the parties get to exercise their right to choose and pursue their happiness as there is no
point to continue being in a matrimonial relationship if the spouses are not happy. For couples
who go for filing divorce by mutual consent are given time to try and make their marriage work.
They are advised to go for mediation and reconciliation to sort their issues out.

They mutually decided to resolve all the disputes and file for divorce by mutual consent. The
custody of their children would be with the husband, and permanent alimony was paid to the
wife. After all these issues were mutually sorted by the parties, they just wanted a quick divorce
and sought to waive off the waiting period. The parties could no longer be with each other and
the waiting period would only prolong their agony.

Keeping this in view, Hon’ble Supreme Court laid down the waiting period of six months can be
waived off if the court is satisfied that the spouses have lived separately for more than the
statutorily prescribed time of at least one year and have settled the issues of alimony and custody
of children (if any).5

In case of K. Omprakash v. K. Nalini AIR 1986 AP 167 (DB), the parties were not happy with
their marriage anymore and were allegedly having extramarital relationships. It was the
contention of the petitioner that they were living apart without ever visiting each other for more
than a year and so, there was no scope of reconciliation between them. They blamed each other
for their suffering and unhappiness. Both alleged each other to be involved in a series of illicit
relationships but denied ever being involved in such relationships themselves. There was no
other option left but only to file for divorce by mutual consent. The marriage had suffered
irretrievable damage and had reached a point of no return. Both parties prayed for an instant
divorce and a waiver of the waiting period. Observing that the parties had lived separately for
long enough and there was no scope of getting the marriage to work again. The High Court of
Andhra Pradesh held that Section 13B (2) of the Hindu Marriage Act should be read not as a
statutory mandate, but only as a directory. Hence, the waiting period which was once mandatory
in nature now remains discretionary.

 Whether consent can be unilaterally withdrawn for divorce by mutual consent?

5
https://www.loc.gov/

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After the first motion, if the parties are provided with the waiting period, they may sometimes
decide to change their mind. Not all cases of divorce are irreparable and some may still have
some scope of reconciliation and the parties may choose to withdraw their consent and give their
marriage a second chance. The waiting period proves to be very useful for some cases as the
parties get to go for mediation which may change their mind. The consent of the parties is also
deemed to be withdrawn after the expiry of the waiting period of 18 months, wherein a decree of
divorce shall not be granted.

The phrase “Divorce by Mutual Consent” is self-explanatory, it simply means that the consent
of both parties is required in order for the court to grant the decree of divorce. In Sureshta Devi
v. Om Prakash6, the wife’s consent was fraudulently obtained by the husband for filing a
divorce. The wife was unwilling to give her consent for divorce and therefore she did unilaterally
revoke her consent. Upon reading the judgement of the Supreme Court we can conclude that a
party can unilaterally withdraw their consent if the same has not been freely given.

After the first motion has been passed the parties will have agreed to settle on various issues such
as alimony, custody of children and other marital expenses. Now, If one of the parties
unilaterally withdraws their consent the other party may suffer prejudice that could be
irreversible.

In Rajat Gupta v. Rupali Gupta7, the court says that the agreement between the parties to settle
their issues and opt for divorce by mutual consent is a binding agreement and a form of
undertaking. If a party now unilaterally withdraws their consent, they would be in breach of their
undertaking made before the court of law, resulting in civil contempt of court by wilfully
disobeying an undertaking. If the consent has to be withdrawn unilaterally, it must be done so on
a just and reasonable ground and the other party must not suffer prejudice. Therefore, consent
can be unilaterally withdrawn only in exceptional cases on reasonable grounds.

6
1992 AIR 1904 1991 SCR (1) 274 1991 SCC (2) 25 JT 1991 (1) 321 1991
7
2016 SCC OnLine Del5009

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 CHAPTER – II
DIVORCE BY MUTUAL CONSENT UNDER MUSLIM LAW

Previous to Islamic legislation, the wives had no right to claim dissolution of the marriage on any
ground whatsoever. In special cases only the power of divorce was expressly reserved in their
favour by contract. As a general rule neither the ancient Hebrews nor the pre-Islamic Arabs
recognized the right of divorce for women.8 Islamic law never conferred the same power to
pronounce talak on the woman as it does on the man. However, it does recognize a Muslim
woman's right to seek divorce with the consent of the husband. 9 The Koran allowed them this
privilege which had been denied to them by the ancient institutions of their country. Says and are
apprehensive that they cannot observe. the bounds prescribed by the divine laws (that is they
cannot perform the duties imposed on them by the conjugal relationship), the woman can release
herself from the tie by giving up some property in consideration for which the husband has to
give her a khula and when they have done this a talak-ul-bain would take place.

A hadith runs –

A woman who asks to be divorced from the husband without cause, the fragrance of the
garden is to be forbidden to her.

There are two forms of divorce by mutual consent, in both the woman has to part with her
property. One is the "khula" divorce and the other one is the "mubarat" form of divorce!10

MUBARAT

The literal meaning of the word Mubarat is 'obtaining release from each other.' It is said to take
place when the husband and wife, with mutual consent and desire, obtain release and freedom
from their married state. The offer for separation in mubarat may proceed either from the wife or
from the husband and as soon as it is accepted dissolution is complete. It takes effect as one
irrevocable divorce without the aid of the court. Under Hanafi law, mubarat is equivalent to one
irrevocable pronouncement of talaq, making it necessary for the parties to contract a fresh
marriage with each other if they wish to resume a marital relationship.

8
Syeed Amir Ali, “Muhammadan Law”, (Kitab Bhavan, New Delhi, 1986), p. 466.
9
Paras Diwan, "Family Law", (4 Edition, Allahabad Law Agency, Faridabad, 1998), P. 177
10
https://arjungupta 1993.wordpress.com/2015/03/22/divorce-by-mutual-consent-in-muslim-law- mubarat

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According to the holy Quran, the basis of Mubarat is Surah al-Baqrah 11, it is given in the book,
“that there is danger in mubarat, just as with all forms of divorce, to which the parties might act
hastily, then repent, and again wish to separate. To prevent such capricious action repeatedly, a
limit is prescribed. Two divorces (with attempted reconciliation in between) are allowed. After
that the parties must definitely make up their minds, either to dissolve their union permanently or
to live together in mutual love and forbearance” 12. If the husband is the one who makes the initial
offer of a mubarat, his offer may not be retracted. It is up to the wife, then, to neither accept or
reject this offer. This is primarily because this offer by the husband is deemed equivalent to an
oath of repudiation, which becomes effective immediately when the wife signifies her
acceptance of the offer. On the other hand, if the wife makes the initial offer of a mubarat, she
may retract her offer at any time before acceptance by the husband. Since mubarat requires
consent of both parties to the marriage contract, the agreement to divorce may be voidable if
either or both the parties lacked the necessary intent or have been induced into acceptance by
fraud or duress.

KULA

While in the Khula divorce, the request proceeds from the wife to be released and the husband
agrees for certain consideration, usually the mehar, in mubarat apparently both are happy at the
prospect of being rid of each other. No formal form is insisted on for mubarat by the Sunnis. The
offer may come from either side. When both the parties enter into mubarat all mutual rights and
obligations come to an end.13

At first in the Indian sub-continent the form of Khula talaq and mubarat were not recognised as
form of a valid talaq according to law. It was in the case of Mst. Umar Bibi v Muhammad
Din14 that the concept of mubarat was recognised and brought in the fore front.

"So, the second khalifa, Umar, shut up a petitioning wife in a filthy room for three days and three
nights in order to determine the extent of revulsion. On being taken out, the Khalifa enquired as

11
The Holy Quran', Text, Translation and Commentary by Abdullah Yousaf Ali Sh.Mohammad Ashraf Publishers
& book sellers, Surah Al-Baqrah
12
ibid.
13
Bhartiya V. P. "Muslim Law", ed. 5.
14
AIR 1945 Lah. 51

13
to how she had fared, and she replied, "By Allah, these three days have been the only days of
peace of my life since marriage."

The divorce was subsequently given in this case. The judge relied on the spoken words of the
wife.15 The judge decided that even where there was mutual dislike or extreme incompatibility of
temperament between husband and wife there can be mubarat, sukoon, and rehmat in the married
life (declared to be objectives of marriage by the Qur'an) with the procreation of children.

In the case of Mst. Sayeeda Khanam v. Muhammad Sami16, it was decided that
"incompatibility of temperaments, aversion or dislike cannot form a ground for a wife to seek
dissolution of her marriage at the hands of a Qazi or court, but is to be dealt with under the
powers possessed by the husband and the wife under Muslim law, as parties to the marriage
contract". This case defined khula as dissolution of a marriage by agreement between the parties
for a consideration paid or to be paid by the wife to the husband. It was necessarily a case of
mubarat.

CASE STUDY – MST. UMAR BIBI V MUHAMMAD DIN

 Khurshid Bibi was married to Muhammad Amin, and her brother was married to his sister.
Since there were no offspring of the wedlock, Muhammad Amin took a second wife. Within
twenty days of the second marriage, their relations became strained. She demanded a
separate house and though he promised it to her, he failed to fulfill his promise. She
complained of maltreatment at his hands. There arose such differences between them that
Muhammad Sharif, her brother, took out warrants under section 100, Criminal Procedure
Code, and she left his house. The respondent's father convened two Panchayats, but efforts at
reconciliation between the spouses failed.
 Khurshid Bibi then brought a suit for dissolution of marriage with Muhammad Amin, and he
instituted a suit for restitution of conjugal rights. Her suit was dismissed, but her husband's
suit was decreed against her on January 21, 1960. Muhammad Amin visited her at her
parents' house to realize costs awarded to him in his suit.

15
http://heinonline.org/HOL/Page?
handle-hein journals/modlr30&div-32&g sent-1&collection-journals
16
PLD 1952 (WP) Lah 113 (FB)

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 Khurshid Bibi then initiated a second suit against Muhammad Amin on February 22, 1960,
alleging that he had orally divorced her on January 29, 1960 and agreed to give her a deed of
divorce on the following day, but had not kept his promise. She prayed for a declaration that
having been divorced by him, she was no longer his wife, and in the alternative, for a decree
for dissolution of her marriage by khula. She was willing to give up her dower, since it had
become impossible for them to live together as husband and wife. She also alleged that
Muhammad Amin had not incurred any expenses in his marriage with her. In response,
Muhammad Amin denied that he had orally divorced her or that she was entitled to
dissolution of marriage by khula. He said their relationship was not so unhappy as to make it
impossible for them to live together. He also claimed he had spent Rs. 2,000 on their
marriage. He was opposed to divorcing her even if she were to give up her dower.
 The trial court did not believe that Khurshid Bibi's husband had orally divorced her. The trial
court then decided that there was no likelihood of the parties being restored to a harmonious
relationship. Since the plaintiff had filed a second suit for dissolution of marriage, she clearly
was determined not to live with him or go to his house. Islam preferred separation rather than
a married state in name only. So the court decreed the plaintiff's suit, dissolving her marriage
in exercise of her right of khula.
 In Muhammad Amin's appeal, the District Judge held it was not possible to believe that
immediately after the dismissal of her suit, the respondent would divorce her, and that if he
had really wanted a divorce, he would have given her a statement in writing. The Judge also
stated that khula should not be granted because the Plaintiff had not come to court with a
straightforward story, and because there was some truth to the fact that it was a case of zid
(obstinacy) on her part because of his second marriage.
 In Khushid Bibi's second appeal, the Single Judge of the High Court believed that because
her brother was married to his sister, he could not afford to be inconsiderate towards her.
Thus, he felt that if the defendant could not provide a separate residence for her it was
because he lacked the means. He also felt that because she was not prepared to live with her
husband because he had remarried, but that this was not a ground for khula divorce. Her
appeal was dismissed in limine.

15
 CONCLUSION

The position of law with reference to divorce by mutual consent is identical for Hindus, Parsis
and marriages registered under the Special Marriage Act Researcher feels that divorce by mutual
consent is not swamping all other grounds of divorce in these cases. To begin with there are
certain fixed requirements laid down in order to attain a decree of dissolution of marriage by
divorce by mutual consent. An application for divorce by mutual consent can only be made by
both the parties to the marriage together on their ground that they have been living separately for
one year or more, that they have not been able to live together, and have mutually agreed that the
marriage should be dissolved. Thus, it can be seen that there are many grounds for divorce which
have been mentioned in the previous chapter which can in no way be brought under divorce by
mutual consent. Any situation in which only one party wishes to get a divorce would require that
there be other grounds for divorce since mutual consent is unavailable. Further though the courts
have occasionally brought cases for divorce filed under different provisions under this one, it is
only for the benefit of the parties and the promulgation of justice and has only been done when
neither party wishes to continue with the marriage. The law for Parsis and couples whose
marriages are registered under the Special Marriages Act is the same as that mentioned above.

As per Muslim Law, divorce by mutual consent can take place in two ways. In the case of
Mubarat, both partners wish to dissolve the marriage & either of them can make the offer for
divorce, which becomes when the other party accepts. In the case of Khula, the wife requests
dissolution of the marriage and agrees to pay a mutually accepted consideration to the husband
for her release. the dissolution becomes complete when the husband accepts the offer. In the case
of Muslim law Divorce by mutual consent is the only way by which the woman may end the
marriage and this certainly does not "swamp" the other grounds for divorce like talak where the
everything is in the hands of the man.

16
 BIBLIOGRAPHY

 BOOKS REFERRED

1. Paras diwan, Hindu Law (1985)

2. Paras diwan, Muslim Law
3. Syeed Amir Ali, “Muhammadan Law”, (Kitab Bhavan, New Delhi, 1986), p. 466.
4. Paras Diwan, "Family Law", (4 Edition, Allahabad Law Agency, Faridabad, 1998),
P. 177
5. The Holy Quran', Text, Translation and Commentary by Abdullah Yousaf Ali Sh.
Mohammad Ashraf Publishers & book sellers, Surah Al-Baqarah

 WEB SOURCES

 http://heinonline.org/
 https://blog.ipleaders.in/
 https://www.legalserviceindia.com/
 https://nbassociates.net/
 https://www.jstor.org/
 https://www.loc.gov/

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