Narendra v. K. Meena
Background
The husband had been granted a divorce decree by the Family Court, Bangalore on the ground of cruelty, based on findings that his wife had repeatedly threatened suicide, had once locked herself in a bathroom and poured kerosene on herself before being rescued, levelled an unsubstantiated allegation that he was having an affair with a household maid, and had pressed him to separate from his parents and live with her alone. The wife successfully appealed to the Karnataka High Court, which set aside the divorce decree, reappreciating the evidence and finding no cruelty, prompting the husband's further appeal to the Supreme Court.
Decision Breakdown
The Supreme Court held that the High Court had erred in re-appreciating the evidence and reversing the trial court's well-reasoned findings. It held that a spouse's act of attempting suicide (or threatening to) amounts to mental cruelty by itself, since living under constant fear of being blamed for a spouse's death or suicide is a grave source of mental anguish for the other partner. It further held that a wife's insistence that her husband abandon his duty to support his dependent parents, contrary to normal Hindu family practice, can itself constitute cruelty when not justified by any real grievance, and that baseless allegations of an extramarital affair are also a recognised form of mental cruelty. On these findings, the Court restored the Family Court's divorce decree and allowed the appeal.
Lesson Learnt
Repeated threats or an actual attempt at suicide by one spouse, insisting the other spouse abandon support of elderly parents without justification, and making unsubstantiated infidelity allegations can each independently amount to "cruelty" sufficient to grant a divorce under Indian matrimonial law.