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I have only heard undue hardship used in a bankruptcy context when dealing with student loans. In this context, undue hardship means that you have some kind of permanent disability and are therefore unable to pay off your student loans. Basically, you would need to be paralyzed, have MS or ALS, Parkenson's, etc... Merely being unable to find a job in the filed you studied is not enough.

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12y ago
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Q: What does undue hardship encompass in bankruptcy in NH?
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