Y. Narasimha Rao v Y. Venkata Lakshmi (1991)

CPC & Limitation Act · Transfer of Cases (ss.22–25)

Facts.

A husband obtained a divorce from a foreign court in a State where neither spouse was domiciled, then relied on it in India.

Issue.

When is a foreign matrimonial judgment conclusive under s.13?

Held.

A foreign matrimonial decree is conclusive only if the foreign court was one that the Act under which the parties married recognises as competent, and the decision was on the merits; the decree here failed both tests.

Why it matters.

The leading modern authority on the competent-court and on-the-merits exceptions in s.13.

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