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ANDREW TAMPURI MOHAMMED VRS ESTHER HYANCITHA AKANDAKUM

Case

by ERIC ANSAH ANKOMAH J

Jurisdiction

HIGH COURT

Judge

ERIC ANSAH ANKOMAH J

Catalog Type

Case

Judgement Date

Nov 23, 2023

Summary

Matrimonial Causes – Dissolution of Marriage – Grounds for Divorce – Prolonged Separation – Burden of Proof – Consent Judgment. The case concerns a petition for divorce filed by the Petitioner on 31st May 2023 seeking the dissolution of his ordinance marriage to the Respondent under the Matrimonial Causes Act, 1971 (Act 367). The parties initially contracted a customary marriage in 2013, which was subsequently converted into an ordinance marriage on 4th October 2017. The marriage produced two children, aged nine and two years respectively, and the Petitioner also had a 20-year-old son who had lived with the family. Marital difficulties arose between the parties, leading to their separation in January 2022 when the Respondent moved out of the matrimonial home into a rented apartment with the younger child. The Petitioner asserted that for about three years preceding the petition, the parties had neither lived together as husband and wife nor engaged in sexual relations, and that all attempts at reconciliation by family members and a priest had failed. The Respondent entered appearance and filed an answer together with a cross-petition also seeking dissolution of the marriage, custody of the children, distribution of marital property, maintenance, and other financial reliefs. However, during the proceedings, the parties amicably settled all ancillary matters, including custody, property distribution, and maintenance, leaving only the issue of dissolution of the marriage for the court’s determination. The Respondent did not testify or call evidence in support of her answer or cross-petition, and she did not challenge the Petitioner’s evidence through cross-examination on the core issue of marital breakdown. The principal issue before the court was whether the marriage had broken down beyond reconciliation as required under section 1(2) of Act 367, and whether the evidence satisfied any of the statutory grounds under section 2(1), particularly that the parties had not lived together as husband and wife for a continuous period of at least two years with consent, or that they had been unable to reconcile their differences despite diligent efforts. A further issue was the effect of the Respondent’s failure to adduce evidence or challenge the Petitioner’s testimony regarding the breakdown of the marriage. In its judgment, the court held that the marriage had indeed broken down beyond reconciliation and granted the petition for divorce, thereby dissolving the ordinance marriage between the parties. The court also adopted the terms of settlement filed by the parties as a consent judgment governing all ancillary matters, including custody arrangements, maintenance, and distribution of property. In reaching its decision, the court relied on the uncontroverted evidence presented by the Petitioner that the parties had lived apart for approximately three years, had not engaged in marital relations during that period, and had made unsuccessful attempts at reconciliation through family and religious intervention. The court emphasized its statutory duty under sections 2(2) and 2(3) of Act 367 to inquire into the facts and be satisfied that the marriage had irreconcilably broken down. It found that the prolonged separation, absence of consortium vitae, and failure of reconciliation efforts were sufficient indicators of such breakdown. The court further reasoned that the Respondent’s failure to testify or challenge the Petitioner’s evidence amounted to an admission of the material facts. In support of this position, the court relied on authorities such as Aryeetey v Brown [2006] 5 MLRG 160 CA and Takoradi Flour Mills v Samir Faris [2005-2006] SCGLR 882, which establish that unchallenged evidence is deemed admitted and may be accepted by the court. The court also invoked the principles under the Evidence Act, emphasizing that while the burden of proof lies on the party asserting a claim, a defendant who fails to adduce evidence runs the risk of judgment being entered against them based on the claimant’s evidence alone. Applying these principles, the court concluded that there was sufficient and credible evidence demonstrating that the parties had ceased to live as husband and wife and had been unable to reconcile their differences. Accordingly, the statutory requirements for divorce under Act 367 were satisfied. The court therefore dissolved the marriage, cancelled the marriage certificate, and declared the parties no longer husband and wife. It further incorporated the agreed terms of settlement into its judgment, thereby bringing finality to all ancillary issues without making any order as to costs.

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