EARNEST JOHN WHITE vs MRS. KATHLEEN OLIVE WHITE AND OTHERS

The Supreme Court held that under Section 14 of the Divorce Act, 1869, the standard of proof for adultery requires clear and satisfactory evidence beyond mere balance of probabilities. The Court found that the lower courts misread and ignored critical evidence, including the wife's stay with another man in a hotel under an assumed name, which warranted a conclusion of adultery. Consequently, the Supreme Court set aside the lower courts' findings and ruled in favor of the appellant, granting the dissolution of marriage.