A Division Bench of Justice Sujit Narayan Prasad and Justice Akhil Kumar held that where mental illness and refusal of treatment are pleaded as grounds for matrimonial relief, courts must carefully examine the medical evidence, surrounding circumstances and the actual effect of the alleged conduct on the marital relationship.

The case arose from a marriage solemnised in 2019. According to the husband, the couple initially lived peacefully, but the wife subsequently began quarrelling with him and allegedly misbehaving with his family members.

The husband claimed that his wife had been medically examined at Kanke, Ranchi, where she was diagnosed with schizophrenia, bipolar disorder and seizures, and prescribed medication. He alleged that she refused to take the medicines despite her mental health condition. He further claimed that several panchayat meetings had been held to resolve the matrimonial dispute, but without success. The husband subsequently instituted proceedings under Section 13(1)(ia) of the Hindu Marriage Act, 1955, seeking dissolution of the marriage on the ground of cruelty.

On January 5, 2026, the Principal Judge, Family Court, Koderma, allowed the husband's suit ex-parte and granted a decree of divorce, which was signed on January 17, 2026. Aggrieved, the wife approached the High Court. The wife disputed the husband's allegations and, in turn, alleged that he and his family members had demanded additional dowry. She claimed that she was assaulted and expelled from her matrimonial home on February 16, 2025, and had since been residing with her daughter at her parental home without financial support from her husband.

Examining the Family Court's judgment, the High Court noted that the divorce decree was primarily founded on the allegation that the wife had refused prescribed treatment, allegedly worsening her mental condition, which the Family Court treated as mental cruelty.

However, the Bench found that the husband had not examined the doctor who allegedly treated his wife. No medical officer or expert witness had been produced to substantiate the alleged diagnosis or establish the nature, severity or extent of the illness and its impact on the matrimonial relationship.

The Court held that matrimonial courts could not proceed merely on the basis of medical labels or unsubstantiated allegations concerning a spouse's mental condition. It further observed that the alleged refusal to take medication, without establishing the underlying medical condition and the circumstances surrounding that refusal, could not by itself constitute sufficient proof of mental cruelty.

Emphasising the need to avoid stigmatising spouses on account of alleged mental health conditions, the Court observed:

“The refusal or inability of a person to undergo medical treatment, particularly in relation to an alleged mental health condition, cannot automatically be characterised as an act of cruelty. The Court is required to examine the conduct in its entirety, the circumstances in which such conduct occurred and its actual effect upon the matrimonial relationship. Mental illness cannot, by itself, be made a ground for stigmatizing a spouse or dissolving the marriage.”

The Bench held that where a spouse's mental illness is alleged to have been aggravated by refusal of treatment, the court is obligated to scrutinise those allegations carefully and make an effort to verify the underlying medical facts.

In the present case, the Family Court had undertaken no such exercise and had relied upon the husband's testimony without examining the treating doctor or obtaining cogent medical evidence.

The High Court further held that the Family Court was required to determine whether the alleged conduct had been established by reliable evidence and whether, viewed in its entirety, it amounted to cruelty under Section 13(1)(ia) of the Hindu Marriage Act.

Accordingly, the High Court allowed the wife's appeal and set aside the Family Court's judgment dated January 5, 2026, and the divorce decree signed on January 17, 2026.

Appearance:

For the Appellant: Mr. Pradeep Kumar, Advocate

For Respondent No. 1: Mr. Dhirendra Kr. Das, Advocate