Jharkhand High Court ruled that mental illness claims in divorce need solid proof like medical records. Mere allegations without evidence are not sufficient under the Hindu Marriage Act.
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RANCHI: In a significant ruling, the Jharkhand High Court has reiterated that mere allegations of mental illness, cruelty, or desertion without adequate proof cannot be grounds for divorce under the Hindu Marriage Act, 1955.
The judgment underscores the evidentiary threshold required for such serious claims, particularly when mental health is cited as a reason for dissolution of marriage.
Background of the Case
The appellant-husband married the respondent-wife on 16 February 2017 in accordance with Hindu rites. Shortly after marriage, the wife allegedly developed abdominal pain and was taken to Delhi for treatment, where a tumor was detected.
The husband claimed that the wife and her family had fraudulently concealed her medical condition prior to the marriage.
He further alleged instances of cruelty, including:
- Threats of suicide by the wife
- Absconding from home without information
- Verbal and physical abuse
- Ill-treatment of in-laws
The husband claimed that the wife had deserted him since May 2017 and was suffering from a mental disorder, making it impossible for him to continue cohabitation.
Based on these allegations, he filed for divorce under Sections 13(1)(i-a), (i-b), and (iii) of the Hindu Marriage Act, 1955, invoking cruelty, desertion, and unsoundness of mind.
Arguments by the Parties
Appellant (Husband):
- Claimed the marriage was a fraud due to concealment of illness.
- Alleged repeated acts of cruelty and threats.
- Argued that the respondent was mentally ill, making cohabitation untenable.
- Asserted desertion and lack of physical relationship post six months of marriage.
Respondent (Wife):
- Denied all allegations as false and fabricated.
- Claimed she was subjected to dowry harassment and ousted from the matrimonial home.
- Expressed her willingness to resume conjugal life.
- Denied any history of mental illness or misconduct.
- Filed a dowry harassment case under Section 498A IPC.
Findings of the Court
The Jharkhand High Court, after carefully analyzing the pleadings, oral and documentary evidence, and applying the legal standards laid down by the Supreme Court, concluded that the appellant-husband had failed to substantiate any of the grounds pleaded for seeking divorce under Section 13(1)(i-a), (i-b), and (iii) of the Hindu Marriage Act, 1955.
“Mental illness alone, without adequate clinical or expert proof, cannot justify a decree of divorce under Section 13(1)(iii) of the Hindu Marriage Act.”
The Court held that allegations of cruelty, including threats of suicide and misbehavior by the respondent-wife, were vague, uncorroborated, and lacked documentary or independent evidence. No FIRs, medical records, or complaints had been produced to demonstrate that such alleged conduct had occurred or amounted to legal cruelty.
“Except the vague and omnibus allegations made by the husband, no concrete documentary evidence has been led to substantiate the charges of cruelty, desertion and mental illness.”
Similarly, the ground of desertion was rejected, as the Court found that the wife was willing and desirous to resume conjugal life, and her living separately was a result of being ousted rather than voluntary abandonment.
On the issue of mental illness, the Court categorically held that no medical records, psychiatric evaluations, or expert testimony were produced to support the claim of the wife being of unsound mind or suffering from a mental disorder of such severity that it would justify a divorce.
As such, the Court upheld the findings of the Family Court and found no reason to interfere, concluding that none of the statutory grounds had been proven by the husband, and thus, the appeal was dismissed.
The Jharkhand High Court’s ruling reinforces the importance of evidentiary integrity in matrimonial disputes. Allegations, especially those involving mental health, must be backed by expert or documentary proof.
Divorce is a serious legal remedy and cannot be granted on the basis of conjecture or personal dissatisfaction. This judgment also sends a clear message that courts will not entertain attempts to misuse mental illness as a blanket ground for marital dissolution.
The decision is a reaffirmation of judicial prudence, balancing the sanctity of marriage with the rights and dignity of individuals.
Case Title: X vs Y
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