The doctrine of indissolubility of marriage under traditional Hindu Law did not recognize that conversion would have the effect of dissolving a Hindu marriage. Conversion to another religion by one or both Hindu spouses did not dissolve the marriage.

In the case of 'In re Ram Kumari' (1891) ILR 18 Cal 266, where a Hindu wife converted to the Muslim faith and then married a Mohammedan, it was held that her earlier marriage to a Hindu husband was not dissolved by her conversion.

She was charged and convicted of bigamy under Section 494 of the IPC, 1860. It is held that there is no authority under Hindu Law for the proposition that an apostate is absolved from all civil obligations and that, as far as the matrimonial bond is concerned, such a view is contrary to the spirit of Hindu Law.

The Madras High Court followed 'In re Ram Kumari', (1891) ILR 18 Cal 266 in 'Budansa v. Fatima', AIR 1914 Mad 192. In 'Gul Mohammed v. Emperor', AIR 1947 Nag 121: 1947(48) CrLJ 43, a Hindu wife was fraudulently taken away by the accused, a Mohammedan, who married her according to Muslim Law after converting her to Islam.

It was held that the conversion of a Hindu wife to the Mohammedan faith did not ipso facto dissolve the marriage, and she could not, during the lifetime of her former husband, enter into a valid contract of marriage. Accordingly, the accused was convicted of adultery under Section 497 of the Indian Penal Code, 1860.