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The parties were married on 3 June 1993 and had seven children. The applicant submitted that, by July 2013, the parties' marriage had become quarrelsome because the respondent:

1. would ignore and oppose the applicant's advice;
2. did not want to look after the parties' children;
3. failed to appreciate what the applicant would provide her with; and
4. had had an extra-marital affair.

Problems escalated and, by March 2014, the parties had separated after the respondent left the matrimonial home. The applicant had already made efforts to reconcile with the respondent but to no avail. Accordingly, the applicant requested that the court grant him a revocable divorce (talak satu raji).

Despite the respondent's absence from court, on the grounds of ongoing conflict between the parties, the court, pursuant to art 39(2) of Law No. 1 of 1974, art 19(f) of Government Regulation No. 9 of 1975, and art 116(f) of the Compilation of Islamic Laws, acceded to the applicant's request.

The plaintiff submitted that, in May 2009, the parties' had become strained after she relocated to Abu Dhabi a month earlier to work. Upon returning to Indonesia in July that same year, the plaintiff went to live with her elder sibling and since then the defendant had failed to provide the plaintiff with any financial or emotional support. The plaintiff also submitted that the defendant had physically assaulted her. The defendant, in response, claimed that the plaintiff had never sent him money from Abu Dhabi to assist him in taking care of the parties' two children. The defendant also refuted the plaintiff's submission that the parties' marriage was strained, submitting that he wished the parties would remain married.

Despite mediation between the parties, the plaintiff maintained her request for a divorce. The court acknowledged that the purpose of marriage, that being a peaceful, hopeful and loving (sakinah, mawaddah, warahmah) home, as envisaged in Surat Al-Rum verse 21 from the Qur'an, art 1 of Law No. 1 of 1974 on Marriage, and art 3 of the Compilation of Islamic Laws, was no longer feasible. Accordingly, pursuant to art 19(f) of Government Regulation No. 9 of 1975, and art 116(f) of the Compilation of Islamic Laws, the court granted the plaintiff an irrevocable divorce (talak satu ba'in shughra) on the grounds of ongoing conflict.

In 2011, after 23 years of marriage, the parties' relationship had begun to deteriorate. The plaintiff submitted that the defendant had married another woman with whom he had a child (son). For two years the plaintiff and defendant had lived separately and had not been physically intimate with one another.

The defendant denied the plaintiff's submissions, stating that the plaintiff had often accused him of marrying another woman, and that her accusations were generally based on hearsay. Moreover, the defendant submitted that he had often tried to initiate physical intimacy with the plaintiff, only to be rejected.

After unsuccessfully counselling the parties to reconcile, the court noted that the defendant had acknowledged the deterioration of the relationship, but not the causes thereof. While the defendant did not want a divorce, the plaintiff's submissions, supported by witness statements that the parties had already tried to reconcile, moved the court to grant the plaintiff an irrevocable divorce. The court was satisfied that the plaintiff had met the evidentiary requirements contained in art 39(2) of Law No. 1 of 1974, and acceded to the plaintiff's request for an irrevocable divorce (talak satu ba'in shughra) on the grounds of ongoing conflict, pursuant to art 19(f) of Government Regulation No. 9 of 1975, and art 116(f) of the Compilation of Islamic Laws.

The parties were married on 15 February 2001 but had been living separately for the past 11 years and six months. Their marriage had begun to deteriorate in August 2002 because, according to one witness, the defendant had failed to provide his family with sufficient financial support.

Despite the defendant's absence from court, the court granted the plaintiff an irrevocable divorce (talak satu ba'in shughra), pursuant to art 39(2) of Law No. 1 of 1974 on Marriage, art 19(f) of Government Regulation No. 9 of 1975, and art 116(f) of the Compilation of Islamic Laws, on the grounds of ongoing conflict.

The parties were married on 6 June 1988, after which they lived with the plaintiff's parents and had three children. From December 2012, the parties' marriage had become quarrelsome because the defendant struggled to meet the family's financial needs. In January 2013 the parties separated and remained separated for the 11 months leading up to the divorce proceeding.

Despite the defendant's absence from court, the court was satisfied that the plaintiff had met the evidentiary burden contained in art 39(2) of Law No. 1 of 1974. Pursuant to art 19(f) of Government Regulation No. 9 of 1975, and art 116(f) of the Compilation of Islamic Laws, it therefore acceded to the plaintiff's request for an irrevocable divorce (talak satu ba'in shughra) on the grounds of ongoing conflict.

The parties were married on 27 March 1984 and had three children. By January 2008, however, the parties' marriage had become quarrelsome. The plaintiff submitted that this was due to the defendant's inability to meet the family's financial needs, as well as the defendant having married another woman. Problems escalated in December 2011 resulting in the parties sleeping in separate beds. During this time the defendant, the plaintiff submitted, had failed to provide her with any financial or emotional support. Feeling the marriage was beyond repair, the plaintiff requested that the court grant her an irrevocable divorce (talak satu ba'in shughra).

The court, pursuant to art 39(2) of Law No. 1 of 1974 on Marriage, art 19(f) of Government Regulation No. 9 of 1975, and art 116(f) of the Compilation of Islamic Laws, acceded to the plaintiff's request on the grounds of ongoing conflict.

The parties were married on 27 June 2007 and had one child. Since January 2010, however, the parties' marriage had become quarrelsome because, the plaintiff submitted, the defendant had struggled to meet the family's financial needs. The plaintiff also submitted that when the parties quarrelled the defendant would often beat her. Problems escalated in October 2010, resulting in the parties separating. For the next two years and six months, leading up to the divorce proceeding, the defendant failed to provide the plaintiff with any emotional or financial support.

Information provided by witnesses in court corroborated with that of the plaintiff, moving the court to accede to the plaintiff's request for a divorce. Pursuant to art 39(2) of Law No. 1 of 1974 on Marriage, art 19(f) of Government Regulation No. 9 of 1975, and art 116(f) of the Compilation of Islamic Laws, the court granted the plaintiff an irrevocable divorce (talak satu ba'in shughra) on the grounds of ongoing conflict.

The parties were married on 20 October 2000 and had two children. By October 2010, however, the parties' marriage had become quarrelsome because, the plaintiff submitted, the defendant had been courting another woman. Problems escalated in September 2013, resulting in the parties separating for the two months leading up to the divorce proceeding.

Despite the defendant's absence from court, the court was satisfied that the plaintiff had met the evidentiary burden contained in art 39(2) of Law No. 1 of 1974. Pursuant to art 19(f) of Government Regulation No. 9 of 1975, and art 116(f) of the Compilation of Islamic Laws, it therefore acceded to the plaintiff's request for an irrevocable divorce (talak satu ba'in shughra) on the grounds of ongoing conflict.

The parties were married on 5 September 2007 but had no children. In August 2012, the parties' marriage became strained when the plaintiff went to Saudi Arabia to work. The plaintiff returned in July 2013, during which time the defendant had provided the plaintiff with no emotional or financial support. Problems escalated in August 2013, resulting in the plaintiff moving to live with her parents. Feeling the parties' marriage was beyond repair, the plaintiff requested that the court grant her an irrevocable divorce (talak satu ba'in shughra).

Despite the defendant's absence from court, the court was satisfied that the plaintiff had met the evidentiary burden contained in art 39(2) of Law No. 1 of 1974. Pursuant to art 19(f) of Government Regulation No. 9 of 1975, and art 116(f) of the Compilation of Islamic Laws, it therefore acceded to the plaintiff's request for an irrevocable divorce (talak satu ba'in shughra) on the grounds of ongoing conflict.

The parties' were married on 27 March 2003 and had one child. By January 2007, however, their marriage had become quarrelsome because, the plaintiff submitted, the defendant was not able to provide his family with sufficient financial support. The marriage broke down in July 2007, resulting in the defendant leaving the plaintiff for approximately four years, during which time the defendant failed to provide the plaintiff with any emotional or financial support.

Satisfied that the plaintiff had met the evidentiary requirements contained in art 39(2) of Law No. 1 of 1974, the court, pursuant to art 19(f) of Government Regulation No. 9 of 1975, and art 116(f) of the Compilation of Islamic Laws, acceded to the plaintiff's request for an irrevocable divorce (talak satu ba'in shughra) on the grounds of ongoing conflict.

The Muslim Women (Protection of Rights on Divorce) Act was passed by India's Parliament in 1986, allegedly to protect the economic rights of Muslim women upon divorce. The Act, however, has been controversial as it essentially overrode the Shah Bano judgment and limited the maintenance Muslim women could receive after divorce to the iddat period (a three month period).

In Sarabai, the Bombay High Court upheld "triple talaq" (the pronunciation of talaq, or male-initiated divorce, three times) to be a valid form of irrevocable divorce.

The Indian Supreme Court held that for talaq (unilateral, male-initiated divorce) to be valid, there must be (1) a reasonable cause and (2) proof of an effort of reconciliation; a simple utterance of talaq, or the presentation of a written statement stating that the respondent had divorced the plaintiff sometime previously, was not sufficient to effect unilateral divorce.

The plaintiff submitted that, since January 2009, the parties' marriage had become disharmonious because:

1. the parties would often quarrel because the defendant was not transparent regarding his finances, only ever providing the plaintiff with daily spending money (the plaintiff did not know how much the defendant earned);
2. since having had their first child, the plaintiff would have to ask the defendant, sometimes after having been brought to tears, for physical intimacy;
3. the defendant always refused invitations to family gatherings at the plaintiff's parents' home for Eid;
4. by 2011, the parties were still quarrelling over the same matters, despite the plaintiff's attempts to be patient with the defendant, and the defendant would only alter his behaviour if he needed something from the plaintiff;
5. in 2012, the defendant still refused to attend the plaintiff's parents' home for Eid;
6. finally, on 27 September 2014, the plaintiff invited the defendant to her parents' home, but the defendant refused to attend and instead told the plaintiff to return to her parents' home alone, which she did.

Since then the parties had remained separated. The plaintiff, however, withdrew her case in court stating that she and the defendant had reconciled their differences. The defendant concurred, assenting to the case's withdrawal.

The plaintiff submitted that, since November 2010, the parties' marriage had become disharmonious because:

1. the parties quarrelled regularly because the defendant had failed to provide the plaintiff with sufficient financial support, and the defendant often stayed at his parents' home rather than the parties' home, and in the event of an argument, the defendant would often return to his parents' home for up to one month, after which the parties would then quarrel again;
2. finally, in mid-August 2014, when the plaintiff had rejected the defendant's request that the plaintiff provide him with her work documents, payslip, identity card and family card as financial guarantee for his friend's car, the defendant had become angry and returned to his parents' home with his clothes in tow.

While the plaintiff requested that the court grant her an irrevocable divorce (talak satu ba'in sughra), the court dismissed her application on the grounds that her claim did not contain a legal reason for divorce, as required under art 39(2) of Law No. 1 of 1974 on Marriage.

The applicant submitted that the parties' marriage was harmonious until 2008, after which time he and the respondent had begun to quarrel regularly because:

1. the respondent was never satisfied with the amount of financial support provided by the applicant, that being the applicant's entire monthly salary (IDR 1,600,000); and
2. the respondent would often direct unsubstantiated accusations at the applicant that he had had an extra-marital affair.

The applicant claimed that he had sought to reconcile and improve the parties' marriage, but, since October 2008, had felt compelled to leave the matrimonial home and return to his parents' home. Despite having been summonsed formally, the respondent failed to attend the proceeding. Accordingly, the court, pursuant to art 19(b) of Government Regulation No. 9 of 1975, in conjunction with art 116(b) of the Compilation of Islamic Laws, granted the plaintiff an irrevocable divorce (talak satu raj'i) on the grounds that the parties had been apart for more than two years.

The plaintiff submitted that the defendant left the matrimonial home [date not specified in judgment] and the parties' four children, and had not returned in nine years and one month, during which time he had not sent any news of his whereabouts and neglected his obligation to provide for his family. The plaintiff maintained that she had tried to locate the defendant, even asking his family in Jakarta, but no one she asked knew of his whereabouts.

The court granted the plaintiff an irrevocable divorce (thalak satu bain shughra) on the grounds of ongoing conflict, and that the parties had been separated for more than two years, per art 19(f) and (b) of Government Regulation No. 9 of 1975, in conjunction with art 116(f) and (b) of the Compilation of Islamic Laws.

The appellant sought to challenge the decision of the Kutacane Shari'a Court to grant the respondent an irrevocable divorce (talak satu ba'in sughra). The Court found that legislation requires a proceeding to be conducted in camera if it is dealing with both a marriage ratification and an irrevocable divorce, which, in this case, it was. As it was conducted in an open forum, however, the Court held the decision of the lower court must be overturned.

The appellant sought to challenge the decision of the Kualasimpang Shari'a Court to grant the respondent an irrevocable divorce (talak satu ba'in sughra).

In upholding the decision of the lower court, the Court acknowledged that the parties had already quarrelled for some time because of the appellant having had an extra-marital affair. The Court found that these were sufficient reasons to fulfil the requirements of art 39(1) and (2) of Law No. 1 of 1974 on Marriage to grant a divorce.

The appellant sought to challenge the ruling of the Langsa Shari'a Court, which had granted the respondent an irrevocable divorce (talak satu bain shughra). The Court dismissed the appeal insofar as it agreed with the decision of the lower court to grant an irrevocable divorce. It did, however, amend the decision to ensure that the court registrar send copies of the decision to the marriage registry.