The Madhya Pradesh High Court at Jabalpur has granted divorce to Manoj Kumar, setting aside a lower court’s order that had dismissed his plea. The division bench of Justice Vishal Dhagat and Justice Anuradha Shukla ruled that false accusations by the wife - including claims of alcoholism - amounted to mental cruelty. The court observed that such baseless allegations could “damage a person’s dignity in society,” particularly when both partners were government employees.
Background
Manoj Kumar and Mamta Arsiya were married in June 2004 and have two children. The couple, both public servants, began living separately in 2017 after years of marital discord. Manoj Kumar filed for divorce citing desertion and cruelty, alleging that his wife had made false allegations and withdrawn from the marriage.
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Mamta, on the other hand, accused her husband of physical and mental harassment, claiming she had filed a case under the Domestic Violence Act in 2005, which was later compromised. She said she never wanted divorce and was ready to live with him if he “mended his ways.”
The Family Court in Mandla dismissed Manoj’s petition, prompting him to approach the High Court.
Court’s Observations
The bench carefully examined the timeline and noted that the couple’s separation in June 2017 meant the mandatory two-year period for claiming desertion had not elapsed when the divorce petition was filed in July 2018. Hence, that ground failed automatically.
The focus then shifted to the allegation of cruelty. Justice Anuradha Shukla, writing for the bench, scrutinized evidence presented by both sides. The court found that documents from the earlier compromise did not establish that the husband was an alcoholic. In fact, the bench remarked that the Family Court had “relied on evidence beyond pleadings,” which was impermissible in civil law.
“The wife’s baseless accusation that her husband was addicted to liquor and violent in nature, despite no supporting evidence, caused social humiliation,” the bench observed. It further said, “A persistent effort to ridicule one’s spouse before others, particularly in a professional circle, shakes the very foundation of a marriage.”
Citing precedents from the Supreme Court, including Samar Ghosh v. Jaya Ghosh and V. Bhagat v. D. Bhagat, the court noted that unfounded allegations can constitute mental cruelty when they impact a person’s mental health and reputation.
Decision
The bench concluded that the wife’s conduct amounted to mental cruelty and that the Family Court had erred in rejecting the husband’s plea. It observed that by “making unfounded allegations and yet refusing to resume marital life,” the wife had effectively destroyed the relationship.
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Allowing the appeal, the court set aside the Mandla Family Court’s decree and declared the marriage dissolved. “The marriage solemnized on 23 June 2004 stands dissolved from the date of this judgment,” the bench ordered, directing the registry to draw up the decree accordingly.
With this ruling, the High Court reaffirmed that baseless allegations that tarnish a spouse’s reputation can be as damaging as physical abuse - a reminder that respect and truth remain the cornerstones of marital life.
Case Title: Manoj Kumar v. Smt. Mamta Arsiya
Court: High Court of Madhya Pradesh, Jabalpur Bench
Case Type: First Appeal No. 334 of 2021
Judges: Justice Vishal Dhagat and Justice Anuradha Shukla
Appellant: Manoj Kumar (Husband)
Respondent: Smt. Mamta Arsiya (Wife)
Date of Judgment: 15 October 2025
