False Criminal Complaints As Mental Cruelty: A Judicial Analysis Of P. Sreeramulu V. P. Lakshmi
- IJLLR Journal
- May 23
- 1 min read
Dr. Vandita Chahar, Asst.Professor, Jaipur National University
Subject: Family Law – Divorce on Grounds of Mental Cruelty – False 498A Allegations
Case Name: P. Sreeramulu v. P. Lakshmi
Citation: (2025) INSC 614
Judges: Hon’ble Justice B. Krishna Mohan
Date: May 16, 2025
Court: Andhra Pradesh High Court
Parties: P. Sreeramulu v. P. Lakshmi,
Introduction
The concept of cruelty as a ground for divorce under Indian matrimonial law has undergone significant judicial evolution, expanding from overt physical abuse to encompass emotional and psychological dimensions. Among the most contentious aspects of this evolution is the judicial interpretation of mental cruelty, particularly when it arises from false legal accusations made by one spouse against another. The case of P. Sreeramulu v. P. Lakshmi, decided by the Andhra Pradesh High Court in 2025, offers a critical perspective on this issue. It underscores the legal system’s growing recognition of the traumatic effects that baseless criminal complaints—such as those under Section 498A of the Indian Penal Code—can have on the accused spouse.
In this case, the husband and his parents were subjected to arrest and criminal trial based on dowry harassment allegations, only to be acquitted due to lack of evidence. The husband subsequently sought divorce on the ground of mental cruelty, arguing that the false accusations caused severe emotional and reputational harm. The court not only granted the divorce but also articulated a broader principle: that misuse of protective legal provisions can amount to cruelty under Section 13(1)(ia) of the Hindu Marriage Act, 1955.
