A) Case: Rani Nirshimha Sastry v Rani Suneela Rani (2019 SC)
Facts: The appellant-husband filed a petition under Sections 13(1)(i-a) and 13(1)(iii) of the Hindu Marriage Act, 1955, seeking dissolution of marriage solemnized in August 2005 at the Annava ram Sri Veera Venkata Sathya narayana Swamy Temple, East Godavari District, Andhra Pradesh.
The parties lived together until January 2007, after which they separated and remained apart for over ten years. In 2007, the respondent-wife lodged an FIR against the appellant and his sister, leading to the framing of charges under Section 498A of IPC.
Decision: The Hon’ble Supreme Court allowed the appeal and dissolved the marriage u/s 13(1)(i-a) of the Hindu Marriage Act, 1955, on the ground of mental cruelty. While upholding the Trial Court’s rejection of the husband’s claim regarding the wife’s alleged mental illness, the Court held that the allegations, accusations, and character assassination made by the wife constituted mental cruelty.
It further observed that filing a complaint or FIR does not by itself amount to cruelty, when the husband has undergone trial and been acquitted of false allegations, such conduct causes mental suffering and amounts to cruelty. Considering that the parties had cohabited for only 18 months and had lived separately for over a decade, the Court granted a decree of divorce in favour of the appellant.
Link of the Judgement: https://indiankanoon.org/doc/60266171/
Legal Takeaway
The Supreme Court made it clear that false, reckless, and defamatory allegations within a marriage can amount to mental cruelty—especially when the allegations lead to criminal prosecution and the accused spouse is ultimately acquitted. In this case, the wife’s conduct of initiating a 498A case, levelling serious accusations, and attempting to damage the husband’s reputation constituted cruelty severe enough to justify divorce. The Court emphasized that while filing a complaint is not cruelty by itself, making false accusations that collapse during trial inflicts deep mental suffering.
B) Case : Raj Talreja v. Kavita Talreja – (2017 SC)
Facts: The wife seeking an injunction restraining the husband from entering the matrimonial home and made several false allegations against him through newspaper reports, complaints to the State Women Commission, the Chief Justice of the High Court, the Superintendent of Police, and the Chief Minister.
She lodged a false FIR u/s 452, 323, and 341 IPC, which the police, after investigation, found baseless, concluding that her injuries were self-inflicted and recommending action under Section 182 IPC against her.
The husband thereafter sought to include these instances as acts of cruelty. The trial court dismissed the petition, and the husband’s appeal was also rejected, leading to appeal to Supreme Court.
Decision: Cruelty cannot be defined with precision; it must be determined based on the facts and circumstances of each case. In the present case, the wife made reckless, defamatory, and false allegations against the husband, his family members, and colleagues, thereby lowering his reputation in society.
While the mere filing of complaints does not constitute cruelty if justified, making false accusations amounts to cruelty under the Hindu Marriage Act, 1955. Here, all the allegations made by the wife were found to be false.
The wife’s complaint alleging trespass and assault by the husband, was found baseless seemed injuries being self-inflicted. Consequently, proceedings were initiated against the wife under Section 182 of the Indian Penal Code.
Link of the Judgement: https://indiankanoon.org/doc/139144445/
Legal Takeaway
In this judgment, the Supreme Court reiterated that cruelty is not confined to physical harm—it includes reckless, defamatory, and malicious accusations that damage a spouse’s dignity and social standing. Here, the wife repeatedly filed false complaints, involved newspapers, authorities, and even lodged a baseless FIR later proven fabricated, with the police recommending action under Section 182 IPC. Such behaviour reflected a sustained pattern of harassment and reputation damage, clearly amounting to mental cruelty.
For individuals facing situations involving false allegations, fabricated FIRs, defamatory accusations, or prolonged marital conflict, understanding the legal consequences is crucial. Seeking timely guidance from an experienced divorce lawyer in Delhi can help clarify your rights, assess whether such conduct amounts to mental cruelty, and determine the appropriate legal remedies under the Hindu Marriage Act.
