The Bombay High Court has ruled that filing a false complaint under Section 498A of the Indian Penal Code (IPC) with the intent to “correct” a spouse’s behavior amounts to cruelty under Section 13(1)(i-a) of the Hindu Marriage Act, 1955. 

A division bench of Justice G.S. Kulkarni and Justice Advait M. Sethna delivered this judgment while upholding a Family Court's decree granting divorce to the husband. 

The case stemmed from an appeal filed by the wife challenging the Family Court's March 5, 2018, decree dissolving their marriage. The couple, married in 2006, had been living separately shortly after their wedding. The husband sought divorce on grounds of cruelty, citing the wife’s false criminal complaint under Section 498A of the IPC, accusing him and his family of harassment.

The Family Court had determined that the allegations were baseless, noting the wife’s admission during cross-examination that her intent in filing the case was not punitive but corrective. 

The wife argued that the Family Court had misinterpreted her intentions and emphasized that she had challenged her husband's acquittal in the criminal case before the High Court. She contended that labeling her complaint as false was unjust and that the evidence presented did not sufficiently establish cruelty.  

The husband, however, claimed that the false allegations inflicted severe mental anguish and irreparably damaged his social and familial relationships, breaching the foundation of their marriage.  

The High Court upheld the Family Court’s findings, observing that the wife’s actions constituted cruelty. Highlighting her admission that the complaint was meant as a corrective measure, the court noted the grave impact of falsely implicating the husband and his family in serious criminal charges. “The appellant failed to recognize the ramifications of dragging the respondent and his relatives into a false prosecution. The social stigma and unwarranted harassment suffered by the respondent and his family were significant and justified granting divorce,” the court stated.  

In conclusion, the High Court affirmed the Family Court’s decree of divorce and dismissed the wife’s appeal.