The Bombay High Court has ruled that a wife's act of filing a false criminal complaint against her husband under Section 498A of the Indian Penal Code (IPC) with the intent of "correcting his behavior" amounts to cruelty under Section 13(1)(i-a) of the Hindu Marriage Act, 1955. 

The Bench comprising Justice G.S. Kulkarni and Justice Advait M. Sethna observed that such conduct undermines the trust and harmony essential in a marriage, thereby eroding its foundational values and rendering the relationship untenable.

The court further noted that the act of filing a false criminal case against a spouse demonstrates a loss of rationality and reason, making it untenable to sustain the marital relationship.

"Also, once the mind of a spouse is corrupted to resort to a false prosecution against a spouse, it is certain that the spouse has lost all reasonableness and rationality to maintain solemnity of the marriage. Once there is a dent to such essential values, on the foundation of which a marriage rests, by a false and draconian action of a criminal prosecution being resorted by either spouse, it is in the realm of cruelty which would be a ground for divorce," the judgment stated.

The couple in this case married in March 2006 but separated within a few months. Subsequently, the wife filed a complaint under Section 498A of the Indian Penal Code (IPC), accusing her husband of cruelty. However, both the trial and appellate courts dismissed the case. Despite her husband's acquittal, the wife continued to pursue an appeal before the High Court. 

The family court observed that the husband was not informed about the appeal, as the wife failed to provide any details or case number, mentioning only that she had filed it. Noting that the wife persisted with the case and showed no interest in reconciling, the family court granted a divorce in March 2018. 

The court cited the wife’s false prosecution as the primary reason for dissolving the marriage, highlighting her admission that the complaint was not intended to punish her husband but to alter his behavior. It characterized her actions as a misuse of legal proceedings. 

The Bombay High Court upheld the family court's decision, agreeing that the wife’s conduct constituted cruelty.

"We are in agreement with the findings recorded and the view taken by the Family Court in the impugned judgment. As clearly seen, the appellant had lodged a false prosecution against the respondent, which has been concurrently affirmed by the Criminal Court. This would certainly amount to cruelty in terms of Section 13(1)(i-a) of the Hindu Marriage Act, 1955," the Court observed.