Routine marital frictions and financial expectations do not constitute mental cruelty under the Hindu Marriage Act.

The appellant (husband) and respondent (wife) married on 06.12.2013 as per Hindu rituals

Following matrimonial discord during their stay in Pune, the appellant filed for divorce under Section 13(1)(i-a) of the Hindu Marriage Act, 1955, alleging mental cruelty

The appellant’s allegations included the respondent’s rude behavior toward his parents, pressure to earn more, demands for paternal property, and threats of suicide

The respondent denied these allegations, counter-alleging that the appellant demanded a car and financial assistance from her family

Originally filed in Pune, the Supreme Court transferred the case to the District Judge, Morigaon, Assam

The Trial Court dismissed the petition on 28.02.2022, characterizing the disputes as "normal tit-bits of conjugal life"

1. Whether the conduct of the respondent—including demands for better financial status and household items—amounted to "cruelty" under Section 13(1)(i-a) of the Hindu Marriage Act, 1955

2. Whether the respondent's statements in her written statement regarding the appellant’s suspicious behavior with his mobile phone constituted an allegation of an illicit relationship amounting to mental cruelty

3. Whether the irretrievable breakdown of marriage due to a ten-year separation serves as a sufficient ground for a decree of divorce in the absence of proven statutory grounds

Section 13(1)(i-a) of the Hindu Marriage Act, 1955, which permits divorce if the petitioner is treated with cruelty

K. Srinivas Rao v. D.A. Deepa, defining cruelty as conduct that causes a reasonable apprehension of harm or injury to the spouse

A. Jayachandra v. Aneel Kaur, which distinguish between mental cruelty and the "ordinary wear and tear of married life"

Vijay Kumar Ramachandra Bhate v. Neela Vijay Kumar Bhate, which established that unfounded allegations of unchastity or illicit relationships in a written statement can constitute cruelty

irretrievable breakdown is not a standalone statutory ground under the Act

The Court held that the appellant failed to prove mental cruelty by a preponderance of evidence, noting a lack of corroborative testimony from family members regarding the alleged misbehavior

Applying the standard of a "prudent person," the Court found that the respondent's demands for furniture, a flat, or financial progress were "tit-bits" of a normal marriage and represented the standard expectations of a spouse rather than sustained reprehensible conduct

Regarding the written statement, the Court analyzed Paragraph 13 and determined that the respondent did not actually impute an illicit relationship; rather, she narrated a neighbor's query and described the appellant's secretive phone usage

Therefore, the rule in Vijay Kumar Ramachandra Bhate did not apply as no specific allegation of unchastity was made

Lastly, the Court addressed the ten-year separation, concluding that while the marriage may have functionally ended, the High Court cannot grant a divorce solely on the ground of "irretrievable breakdown" if the underlying statutory ground of cruelty is not established

The Court affirmed that "trivial irritations" and "normal wear and tear" do not justify the dissolution of marriage

The appeal was dismissed with costs, and the Trial Court's judgment dated 28.02.2022 was upheld