Court’s Decision
The Supreme Court upheld the divorce decree granted by the Family Court and affirmed by the High Court, stating that the wife’s conduct—false allegations of fraud, dowry demands, and character assassination—amounted to mental cruelty. The Court ruled that the marriage had irretrievably broken down, particularly since the husband had already remarried. Given the financial circumstances of both parties, the Court ordered the husband to pay ₹10,00,000 as a one-time permanent alimony to the wife.
Facts
- The marriage between the appellant-wife and respondent-husband took place on June 27, 2012, at Nagpur, following Hindu rites and customs.
- The couple had been in a relationship for four years before getting married.
- After marriage, they lived together for only about two months before disputes arose.
- The husband’s father suffered a heart ailment soon after the wedding, requiring hospitalization for 15 days. The husband claimed that during this period, he was unable to devote time to the wife, leading to her displeasure.
- The wife allegedly left the matrimonial home and refused to return, insisting that she would not live in a joint family.
- The husband filed for divorce in 2014 under Section 13 of the Hindu Marriage Act, 1955, citing cruelty and desertion.
- The wife had earlier filed a case under Section 6 of the Family Courts Act, 1984, Section 34 of the Specific Relief Act, 1963, and Section 12 of the Hindu Marriage Act, seeking annulment of marriage on the ground of fraud. She claimed the husband’s family misled her into marriage for monetary benefits.
- The Family Court dismissed her case in 2014. The wife neither challenged this dismissal nor returned to the matrimonial home.
- The husband claimed that the wife threatened to file false criminal cases against him and his family.
- The wife, in her defense, asserted that she was subjected to verbal and physical abuse by the husband, forcing her to stay separately.
- The husband also argued that the wife falsely accused him of having an illicit relationship with his friend’s wife during cross-examination, which constituted mental cruelty.
Legal Proceedings
- Family Court (2017): The court granted divorce on the ground of cruelty, rejecting the desertion claim. It held that:
- The wife’s false allegations of fraud, dowry demand, and harassment constituted cruelty.
- The wife’s attempt to force the husband to separate from his family also amounted to cruelty.
- The wife casting aspersions on the husband’s character in court was an additional act of cruelty.
- High Court (2018): The wife challenged the Family Court’s decision, but the High Court upheld the divorce decree, stating:
- The wife could not provide any evidence of fraud or dowry demand.
- Her allegations against the husband were baseless and amounted to cruelty.
- Her insistence that the husband separate from his family was unjustifiable.
- Her false accusations of infidelity during court proceedings further justified the divorce.
- Supreme Court (2025): The wife appealed, seeking to set aside the divorce decree and claiming maintenance. However, during the proceedings:
- The husband revealed that he had remarried in 2019.
- The Court attempted mediation for a one-time settlement amount, but no agreement was reached.
- The Supreme Court upheld the divorce decree and ordered the husband to pay ₹10 lakh as permanent alimony.
Issues
- Whether the wife’s conduct—false allegations of fraud, illicit relationships, and attempts to separate the husband from his family—amounted to mental cruelty.
- Whether the High Court was correct in upholding the Family Court’s decree of divorce.
- Whether the wife was entitled to maintenance, and if so, what would be a fair amount?
Petitioner’s (Wife’s) Arguments
- She denied the allegations of cruelty.
- She stated she had never mistreated the husband or his family.
- She alleged she was forced to live separately due to physical and verbal abuse.
- She contended that the divorce decree was obtained unfairly.
- She demanded maintenance, arguing that the husband had a stable income exceeding ₹1,30,000 per month.
Respondent’s (Husband’s) Arguments
- He stated the wife made false and malicious allegations against him and his family.
- He argued that her fraud allegations were baseless, as proven by the dismissal of her annulment petition.
- He contended that the wife demanded he separate from his family, which constituted cruelty.
- He pointed out that she publicly accused him of infidelity, which amounted to mental cruelty.
- He argued that he had financial constraints, earning only ₹16,612 per month.
Analysis of the Law
The Supreme Court analyzed maintenance laws using the precedents set in:
- Rajnesh v. Neha (2021) 2 SCC 324 – Established guidelines for maintenance based on:
- Status of the parties.
- Needs of the dependent spouse.
- Husband’s financial capacity.
- Wife’s independent income.
- Kiran Jyot Maini v. Anish Pramod Patel (2024 SCC OnLine SC 17824) – Reaffirmed that maintenance should be fair and reasonable, considering both parties’ incomes.
- Shailja v. Khobbanna (2018) 12 SCC 199 – Held that even if the wife is earning, she may still receive maintenance.
Precedent Analysis
- Rajnesh v. Neha – Maintenance should balance financial needs and obligations.
- Manish Jain v. Akanksha Jain (2017) 15 SCC 801 – Maintenance must consider the husband’s financial capacity.
- Sunita Kachwaha v. Anil Kachwaha (2014) 16 SCC 715 – Fair maintenance should be awarded without undue hardship to either party.
Court’s Reasoning
- The wife’s false allegations of fraud, dowry demand, and infidelity constituted mental cruelty.
- Her demand that the husband separate from his family was deemed unreasonable.
- The marriage had irretrievably broken down as the husband had already remarried.
- The Court focused on financial settlement, rather than re-examining cruelty allegations.
- The Court analyzed both parties’ affidavits and found that:
- The husband had multiple sources of income.
- The husband underreported his earnings.
- The wife’s claimed income of ₹2,00,000 per month seemed exaggerated.
Conclusion
- The divorce decree was upheld.
- ₹10,00,000 was awarded as a one-time settlement to the wife.
- The amount must be paid within three months.
- The settlement covered all past and future claims.
Implications
- False allegations in matrimonial disputes can constitute cruelty.
- The ruling sets a precedent for assessing maintenance based on real financial status.
- Courts will scrutinize financial disclosures to prevent underreporting of income.
- One-time settlements provide clarity and finality in divorce cases.
- The judgment highlights that forcing a spouse to separate from family may amount to cruelty.
This Supreme Court ruling reinforces that false allegations and mental harassment are valid grounds for divorce, and ensures that financially weaker spouses receive fair support without imposing undue hardship on the paying party.