Madhya Pradesh High Court rules that false infidelity allegations made in anger amount to mental cruelty, granting divorce to the husband under Section 13(1)(ia) of the Hindu Marriage Act.
Case in News:Wife’s false infidelity claim amounts to mental cruelty says Madhya Pradesh High Court as the Court granted divorce to the husband after finding his wife’s baseless accusations to be cruel . |
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Case Overview:
Case Name: Husband vs. Wife, decided on September 25, 2024
The Madhya Pradesh High Court, comprising Justice Vishal Dhagat and Justice Anuradha Shukla, dealt with a divorce appeal filed by a husband accused of infidelity by his wife . The couple, married in 2002 and parents to one child, had been living separately for over three years . While the Family Court had granted judicial separation, the husband approached the High Court, arguing that false allegations against his moral character caused severe mental cruelty .
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Key Aspects:
Before examining the legal position, the Court assessed the facts surrounding the wife’s accusations and her conduct in the marital relationship . The focus was on whether false charges of infidelity could constitute mental cruelty under matrimonial law .
- The wife alleged her husband had illicit relationships and claimed to have vulgar chats and photographs .
- The Court found the evidence to be inadmissible and lacking authenticity .
- It rejected her explanation that the accusations were made “in anger .”
- The Madhya Pradesh High Court held that such baseless claims caused serious mental cruelty to the husband .
Legal Insights :
The Court elaborated on the legal framework governing mental cruelty in matrimonial disputes . Under Section 13(1)(ia) of the Hindu Marriage Act, 1955, a spouse may seek divorce if the other party treats them with cruelty—whether physical or mental .
- Section 13(1)(ia), Hindu Marriage Act, 1955- This section allows divorce if one spouse treats the other with cruelty, whether physical or mental .The Court held that false charges of adultery or immorality amount to mental cruelty, damaging reputation and dignity .
- Section 12, Protection of Women from Domestic Violence Act, 2005 – The wife repeated similar allegations in her DV complaint under Section 12, which the Court said intensified the mental cruelty due to their baseless and defamatory nature .
- Section 125, Code of Criminal Procedure, 1973 – Reiterating false claims in maintenance proceedings under Section 125 CrPC was deemed further harassment and evidence of intentional cruelty .
- Sections 101–103, Indian Evidence Act, 1872 – The burden of proof lies on the person making serious allegations . Failure to prove them, the Court observed, constitutes mental cruelty under matrimonial law .
Court’s Verdict:
The Madhya Pradesh High Court held that the wife’s unfounded allegations of infidelity inflicted mental cruelty upon her husband . Accordingly, it dissolved the marriage solemnized in 2002 on the ground of cruelty while dismissing her cross-objection . However, the Court declined to grant divorce on the ground of desertion, noting that the couple still interacted due to their daughter .
Source- High Court of Madhya Pradesh
Read also – Code of Criminal Procedure, 1973
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