In ARUN KUMAR AGARWAL v. RADHA ARUN 4, a Division Bench of Karnataka High Court observed similarly under similar circumstances as follows: "Where such adulterer is named in the petition and evidence is let in to show that the spouse had intercourse with such person, the Court will have to record a finding that the spouse had a voluntary sexual intercourse with such named person. There is no gain-saying that such a finding/decision will adversely affect the reputation of the person who is alleged to have committed the adulterous act. Public interest and principles of natural justice require that the person concerned should have an opportunity to defend his reputation before such a finding is recorded. It is precisely for this reason that Rules framed by several High Courts (Allahabad, Andhra Pradesh, Mumbai, Delhi, Gujarat, Himachal Pradesh, Kerala, Chennai, Orissa, Patna, Punjab and Rajasthan) specifically require that the alleged adulterer should be impleaded as a co-respondent in a petition under S.13(1)(i) of Hindu Marriage Act, even though no relief may be claimed against him.
As observed by a Division Bench of Calcutta High Court in Sikha Singh v. Dina Chakrabarty, AIR 1982 Cal 370, the Rule requiring joinder of the adulterer as a co-respondent proceeds on a public policy to prevent collusion and character assassination."