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DR ALEXANDER YAWSON V. AGNES WARDY

Case

Jurisdiction

HIGH COURT

Judge

N/A

Catalog Type

Case

Judgement Date

Jun 28, 2016

Summary

Divorce – Irretrievable Breakdown of Marriage – Separation – Unreasonable Withholding of Consent – Burden of Proof – Maintenance, Custody, and Financial Provision. This case involves a petition for divorce filed by the Petitioner against the Respondent, who were married under the Marriage Ordinance in 1998 and had two children. The Petitioner sought dissolution of the marriage on the ground that the Respondent’s behaviour made it unreasonable for him to continue living with her. He also sought shared custody of the children. The Respondent, however, denied that the marriage had broken down beyond reconciliation and sought ancillary reliefs including maintenance, custody, rent, and a lump sum payment. The primary issue for determination was whether the marriage had broken down beyond reconciliation as required by section 1(2) of the Matrimonial Causes Act, 1971 (Act 367). The Petitioner alleged that the Respondent’s constant arguments over money caused him significant stress, negatively affecting his health and work. However, the court found that he failed to substantiate these claims with credible evidence, as required under the Evidence Decree, 1975 (NRCD 323), which places the burden of proof on the party making the assertion. Despite this failure, the court found that both parties admitted to having lived apart and having had no marital relations for a period of four years prior to the filing of the petition. This fact satisfied one of the statutory indicators of irreconcilable breakdown under section 2(1)(d) of Act 367. Although the Respondent withheld her consent to the divorce, the court held that such refusal was unreasonable given the prolonged period of separation. Relying on the authority of Addo v Addo (1973) 2 GLR 103, the court concluded that a respondent cannot insist on maintaining a marriage in circumstances where cohabitation and marital relations have ceased for a significant duration. The court therefore held that the marriage had broken down beyond reconciliation and granted a decree of divorce.

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