An article printed in the New York Times over a century ago (on December 11, 1904) spoke of a New Jersey wife who approached a court for a divorce apparently because her husband woke up in the middle of the night laughing and apparently went on ‘in a riotous manner’.

I’m quite sure that no woman in contemporary India would dream of attempting to get relief from a court on that particular ground no matter how much she might want to.

http://query.nytimes.com/gst/abstract.html?res=9F07E7DB163DE733A25752C1A9649D946597D6CF