Ghulam Fatima, where a wholesome reading of the provisions of the statute led the

court to conclude that a single set of proceedings had to be necessarily instituted in

the country where the divorce was obtained.
In 1899, Lindley, M.R. had observed that English courts only needed to look at the
finality of the judgment and jurisdiction of the court before recognizing a foreign
divorce, provided that English notions of substantial justice were not offended.
This viewpoint is reflected in the Act of 1971, which permits refusal on grounds of
violation of principles of natural justice and public policy.
[B] India
Each matrimonial law specifies grounds for dissolution of marriage. However,
none of these legislations, whether inadvertently or otherwise, state whether a
domiciliary/residence qualification is necessitated by a divorce. Consequently, it
becomes necessary to look at courts for guidance, and the judgment in Satya v.
Teja Singh clarifies the need for a domicile in the location of the court for
upholding the validity of the divorce.
Thus, Indian rules for recognition of foreign divorce are not fully developed yet
apart from general provisions contained in Section 13 of the Civil Procedure Code.
Accordingly, the development of case-law assumes