Matrimonial courts cannot mechanically order medical examination of a spouse without establishing a strong prima facie case.

The Respondent-husband instituted divorce proceedings under Section 13(1)(ia), (ib), and (iii)(a) & (b) of the Hindu Marriage Act, alleging that the Petitioner-wife suffered from an incurable unsoundness of mind or mental disorder

The Petitioner denied these allegations, asserting her mental soundness

The Respondent filed an application (Exhibit-16) seeking a medical examination of the Petitioner to determine her mental status

The Trial Court (Civil Judge Senior Division, Dhule) allowed the application on August 2, 2025, directing the Petitioner to undergo a psychiatric examination at Civil Hospital, Dhule

The Petitioner challenged this order through the present Writ Petition, arguing the order was passed mechanically without prima facie evidence of mental illness

1. Whether a matrimonial court can direct a spouse to undergo a medical examination for mental health without first establishing a prima facie case through evidence

2. Whether the Trial Court’s order for psychiatric examination was a valid exercise of discretionary power or an abuse of process

Section 13(1)(iii) of the Hindu Marriage Act regarding divorce on grounds of mental disorder

Order XXXII Rule 15 of the Code of Civil Procedure regarding the court's power to determine unsoundness of mind

Sharda v. Dharmpal (2003) 3 SCR 105, which held that while matrimonial courts have the power to order medical tests without violating Article 21, such power must only be exercised if the applicant has a strong prima facie case and sufficient material exists before the court

Principle that orders for medical examination should not be passed casually as it would constitute an abuse of discretionary power

The High Court observed that while matrimonial courts possess the authority to direct medical examinations to resolve disputes under Section 13(1)(iii) of the Hindu Marriage Act, such authority is not absolute.

The court emphasized that the burden lies on the petitioner (the husband in the original suit) to prima facie establish the necessity of such an examination through leading evidence.

In the present case, the High Court found that the Trial Court failed to apply its mind to the pleadings and material on record.

The impugned order was deemed "bereft of sufficient reasons" because it did not demonstrate that the Trial Court had satisfied itself regarding the existence of grounds for the reference.

The High Court held that the Trial Court acted mechanically, leading to an unsustainable order in law.

The court held that medical examinations cannot be ordered as a matter of course upon mere allegations.

The court granted the Respondent-husband liberty to file a fresh application for medical examination after leading necessary evidence to establish a prima facie case.

The Trial Court was directed to reconsider any such fresh application by passing a well-reasoned order.

Rule was made absolute.