In the context of student debt relief, 'undue hardship' refers to a situation where a borrower is unable to maintain a minimal standard of living if forced to repay student loans. This concept is crucial when filing an adversary proceeding in bankruptcy court, as it requires the borrower to demonstrate that repaying the student debt would cause significant financial distress. The court examines the borrower's financial situation, efforts to repay the debt, and the likelihood of future financial improvement when considering if 'undue hardship' applies.