The Madhya Pradesh High Court ruled that self-immolation and false allegations by a wife constitute mental cruelty, granting divorce to the husband under the Hindu Marriage Act provisions.
Thank you for reading this post, don't forget to subscribe!
MADHYA PRADESH: The Madhya Pradesh High Court, Jabalpur Bench, recently delivered a crucial judgment, granting divorce to a husband on the ground of mental cruelty.
A Division Bench of Justice Vishal Dhagat and Justice Anuradha Shukla held that the wife’s repeated attempts at self-immolation and subsequent false accusations against her husband’s family created an atmosphere of fear and distress, justifying the dissolution of the marriage.
Background of the Case
The marriage between the parties took place on April 29, 2003, and from this union, a daughter was born. The husband alleged that his wife’s behavior changed drastically soon after the wedding. According to him, she made two attempts at self-immolation, the first by setting fire to her clothes and the second by pouring kerosene on herself, which resulted in serious burn injuries. He further claimed that she deserted him without any valid justification.
On the other hand, the wife contended that it was not a case of self-inflicted harm but rather that her husband, along with his mother, brother, and sister-in-law, had poured kerosene on her and set her on fire. She also asserted that her husband was seeking a divorce solely because of the disfigurement she suffered from the burns.
The matter initially went before the trial court, which dismissed the husband’s divorce petition. Dissatisfied with that decision, the husband filed an appeal before the High Court.
Court’s Findings
The Bench rejected the ground of desertion since the couple had not lived separately for the continuous two-year period required under Section 13(1)(i-b) of the Hindu Marriage Act, 1955.
The Court focused on the ground of mental cruelty, observing:
- The wife failed to produce neighbors (allegedly present during the fire incident) as witnesses.
- She did not file an FIR against her in-laws despite accusing them of a serious crime.
- Her explanation—that community elders advised her against filing a case—was deemed unconvincing.
- There was no evidence proving that the husband sought a divorce because of her burn injuries.
The Court further noted that such acts of self-immolation, coupled with unsubstantiated allegations against close family members, caused grave mental agony and fear to the husband.
ALSO READ: Chhattisgarh High Court: Taunting Husband for Joblessness is Cruelty, Grants Divorce
The High Court strongly criticized the trial court for relying on confidential court-assisted mediation notes, stating that such reliance was illegal and contrary to the Supreme Court’s precedent in Motiram v. Ashok Kumar (2011) 1 SCC 466, which upholds confidentiality in mediation.
Relying on the landmark Supreme Court ruling in Samar Ghosh v. Jaya Ghosh (2007) 4 SCC 511, the Court emphasized that while normal marital quarrels cannot constitute cruelty, extreme acts like self-immolation and false allegations cross the threshold of mental cruelty.
The Bench allowed the husband’s appeal, set aside the trial court’s judgment, and dissolved the marriage under Section 13(1)(ia) of the Hindu Marriage Act, declaring it dissolved from the date of judgment (August 26, 2025).
Case Title:
Heeralal Meena vs Rama @Rameti
FIRST APPEAL No. 133 of 2007
Read Judgment:
Click Here to Read Our Reports on Cruelty
Click Here to Read Our Reports on Divorce
FOLLOW US ON YOUTUBE FOR MORE LEGAL UPDATES