MP High Court Grants Divorce to Husband After Wife's Self-Immolation Attempts, False Blame on In-Laws

The Madhya Pradesh High Court at Jabalpur bench recently granted divorce to a man whose wife attempted self-immolation and subsequently accused his relatives of causing the incident.

The division bench comprising Justice Vishal Dhagat and Justice Anuradha Shukla concluded that the wife's actions amounted to mental cruelty, justifying the dissolution of the marriage.

The husband filed an appeal before the High Court, challenging the judgment of the First Additional District Judge of Hoshangabad. The trial court had dismissed his divorce petition, which was based on allegations of cruelty and desertion by his wife.

The case revolved around a contentious history between the couple, who were married on April 29, 2003, and have a daughter from the wedlock. The husband alleged that his wife's behavior had changed after the marriage and that she had made two attempts at self-immolation. In the first incident, she allegedly set fire to her clothes, and in the second, she sustained burn injuries after pouring kerosene on herself. He also claimed she had deserted him without a valid reason.

The wife, on the other hand, contended that she was being harassed by her husband, his mother, his brother and his sister-in-law and that they were the ones who had set her on fire. She further claimed that her husband was seeking a divorce due to her disfigured appearance following the burn injuries.

After hearing both parties, the High Court bench meticulously examined the evidence on record. It dismissed the husband’s plea of 'desertion', noting that the couple had not lived separately for the continuous two-year period required by Section 13(1)(i-b) of the Hindu Marriage Act, 1955.

However, the court’s decision hinged on the finding of 'mental cruelty'. The bench observed that the wife had failed to produce her neighbours, the key witnesses in the case, who she claimed had saved her from the fire. Furthermore, she had not lodged a First Information Report (FIR) against the family members she accused of the heinous act.

Court deemed her explanation for not filing a report that, on the advice of reputed members of society, she decided not to initiate any criminal proceeding, as unconvincing. The High Court also found no evidence to substantiate her claim that the husband was seeking a divorce because of her burns.

Moreover, in a strong rebuke to the trial court, the High Court pointed out that it had improperly used notes from a "court assisted mediation" in its judgment. The bench underscored that such proceedings are confidential and cannot be used in court, citing the Supreme Court’s precedent in Motiram and another Vs. Ashok Kumar and another. The High Court stated that the trial judge’s reliance on these confidential notes and his "perceived notions" was an error in law.

Drawing on the principles established in the Supreme Court’s judgment in Samar Ghosh Vs. Jaya Ghosh, the High Court concluded that a dreadful act like self-immolation, coupled with the unproven allegation against the husband and his relatives, was sufficient to constitute mental cruelty.

Court stated that the trial court was wrong in not appreciating the facts and that a good case for interference with the judgment had been made out.

Consequently, the High Court set aside the court below’s order and granted the divorce, declaring the marriage dissolved from the date of the judgment. 

Case Title: Heeralal Meena vs Rama @Rameti

Order Date: August 26, 2025

Bench: Justice Vishal Dhagat and Justice Anuradha Shukla