Cross-border divorces rarely end with a single court order. This article explains why the same marriage can appear “divorced” in one country and unresolved in another, and how Indian courts approach foreign divorce proceedings, anti-suit injunctions, and jurisdictional conflicts. Through recent High Court and Supreme Court decisions, it highlights why timing, context, and procedural posture matter as much as substantive law.

When the Bharatiya Nyaya Sanhita (2023) replaced the IPC, Section 69 redefined the “false promise of marriage” offence into an intent-based provision — punishing deceit, not heartbreak. Based on 132 High Court judgments, this analysis traces how courts distinguish genuine relationships from deception, affirming that criminal law protects against fraud, not failed intimacy.