Case Summary: Naveen Kohli vs Neelu Kohli
Citation: (2006) 03 SC CK 0017 | (2006) 4 SCC 558
Case No: Civil Appeal No. 812 of 2004
Date of Decision: 21 March 2006
Bench: Hon'ble Justices Dalveer Bhandari, B.N. Agrawal, A.K. Mathur
Final Decision: Marriage Dissolved (Divorce Granted)
[Judgment Source] https://www.courtkutchehry.com/Judgement/Search/AdvancedV2?docid=263378
Law Points Raised
- Interpretation of 'Cruelty' under Section 13(1)(i-a) of the Hindu Marriage Act, 1955.
- Whether repeated false criminal allegations amount to mental cruelty.
- Whether long separation with no chance of reunion qualifies for granting divorce.
- Scope of Article 142 for complete justice in matrimonial matters.
Ratio Decidendi
The Supreme Court held that when the marriage has broken down irretrievably and there is no possibility of the spouses cohabiting again, the court must consider granting divorce. Mental cruelty includes false accusations, repeated legal harassment, and sustained humiliation.
Final Ruling
The Court allowed the appeal, set aside the High Court judgment, and granted a decree of divorce under Article 142 of the Constitution in the interest of justice. [Paras 89-92]
Relevant Paragraphs
Para 71, 72, 89, 91 – On cruelty, false FIRs, and irretrievable breakdown of marriage.
Summary
This landmark case reaffirmed that prolonged mental cruelty, sustained litigation, and breakdown of marital trust are valid grounds for divorce. The judgment stressed that in situations where a marriage is beyond salvage, the law must prioritize justice and dignity of both parties.