• Before the advent of no-fault divorce, this term was commonly used in divorce statutes. The term was often part of the longer phrase willful, continued, and obstinate desertion. [Cases: Divorce 37(15). C.J.S. Divorce §§ 41, 78.]
obstinate desertion
Desertion by a spouse who persistently refuses to return to the marital home, so that the other spouse has grounds for divorce.