Madhya Pradesh High Court Dissolves Marriage Due to Mental Cruelty and False Allegations

Husband's appeal succeeds as court finds wife's unfounded accusations amount to serious mental cruelty

The Madhya Pradesh High Court in Jabalpur has dissolved the marriage between Manoj Kumar and Smt. Mamta Arsiya, citing mental cruelty arising from false allegations made by the wife. The Division Bench, comprising Justices Vishal Dhagat and Anuradha Shukla, delivered the judgment on October 15, 2025, allowing the husband's appeal and overturning the earlier decision of the Principal Judge, Family Court, Mandla.

The husband, Manoj Kumar, had filed a divorce petition citing desertion and cruelty as grounds for dissolution of his marriage. However, the Family Court initially dismissed his petition, leading him to appeal the decision. In its judgment, the High Court examined the evidence and determined that the mandatory two-year period for desertion had not been met, as the couple had continued their matrimonial relationship until June 5, 2017. Consequently, the ground of desertion was not applicable in this case.

The central issue in the appeal was the allegation of cruelty, particularly the wife's persistent and false accusations that her husband was addicted to intoxication. The High Court highlighted that while there were instances of quarrels between the couple, the wife's accusations intended to ridicule and humiliate the husband in his social circle constituted serious mental cruelty. The court observed that such behavior unjustifiably affected the physical and mental health of the spouse, citing precedents from Supreme Court judgments that characterized similar actions as grounds for divorce.

The evidence presented included documents from a previous compromise between the parties and testimony from the wife's brother. However, the court found that these did not substantiate the allegations of intoxication and criticized the trial court for relying on evidence beyond the scope of pleadings. The High Court concluded that the wife's allegations were unfounded and baseless, impacting the husband's social standing and amounting to mental cruelty.

In allowing the appeal, the High Court set aside the previous judgment and decree, dissolving the marriage from the date of the judgment. The court's decision underscores the importance of substantive proof in allegations and the impact of false accusations in marital disputes.

Bottom Line:

Divorce petition - False allegations and social ridicule by one spouse can amount to mental cruelty and justify dissolution of marriage.

Statutory provision(s): Hindu Marriage Act, 1955 Section 13(1)(ia)

Manoj Kumar v. Smt. Mamta Arsiya, (Madhya Pradesh)(Jabalpur)(DB) : Law Finder Doc Id # 2798394