In India, cruelty as a ground for divorce is recognized under Section 13(1)(ia) of the Hindu Marriage Act, 1955. It states that a spouse can seek divorce if they have been subjected to cruelty by their partner. Cruelty is defined broadly and includes both physical and mental cruelty. The law acknowledges that cruelty can be inflicted by either spouse, including the wife.

This elaboration will examine what constitutes cruelty and provide case references where courts have considered actions by a wife as constituting cruelty, thereby granting the husband divorce.

1. Understanding Cruelty under Hindu Marriage Act, 1955 Cruelty in the context of marital relations is interpreted as conduct that causes a reasonable apprehension in the mind of one spouse that it is harmful or injurious to continue living with the other. Cruelty includes:
   • Physical harm or abuse.
   • Mental suffering caused by actions, words, or conduct.
   • Creating an unbearable environment for the spouse through actions, threats, or behaviours.
2. Types of Cruelty: Physical and Mental
   • Physical Cruelty: Involves bodily harm or threats of harm.
   • Mental Cruelty: Involves conduct that causes psychological suffering. This could include constant insults, false accusations, indifference, public humiliation, or erratic behaviour that disturbs the other spouse.
3. Judicial Interpretation and Case Law Indian courts have significantly contributed to defining cruelty in marriage, particularly with respect to the actions of the wife that have been deemed cruel.
   1. Dr. N.G. Dastane v. S. Dastane, (1975) 2 SCC 326 In this landmark case, the Supreme Court held that for a ground of cruelty, it is not necessary to prove that the spouse intended to be cruel. What matters is whether the conduct was such that it caused a reasonable apprehension in the mind of the petitioner about the possibility of mental or physical injury. Here, the husband was granted divorce based on mental cruelty inflicted by the wife.
       
   2. Samar Ghosh v. Jaya Ghosh, (2007) 4 SCC 511 The Supreme Court elaborated on mental cruelty in this case, laying down specific circumstances that could constitute mental cruelty. These include:
      • Sustained abusive language.
      • Indifference or neglect.
      • Denying sexual relations without valid reasons.
      • False allegations and slander.
      This judgment has since been used to interpret cruelty as a ground for divorce, providing guidance for identifying mental cruelty inflicted by a wife in other cases.
       
   3. Narendra v. K. Meena, (2016) 9 SCC 455 In this case, the Supreme Court held that if the wife persistently makes false accusations or derogatory comments about the husband's character and his family, it can amount to cruelty. The wife had repeatedly accused her husband of having extramarital affairs without any evidence, and the husband was granted divorce based on these false accusations, which the court found to be mentally torturous.
       
   4. Vishwanath Sitaram Agrawal v. Sau Sarla Vishwanath Agrawal, (2012) 7 SCC 288 The Supreme Court granted the husband a divorce on the grounds of mental cruelty inflicted by his wife. In this case, the wife had filed a false criminal complaint against her husband and his family, alleging harassment. The court found that these false accusations, made with malice and without substantial evidence, amounted to cruelty.
       
   5. Shobha Rani v. Madhukar Reddi, (1988) 1 SCC 105 In this case, the Supreme Court held that cruelty is a matter of inference from the facts and circumstances of each case. The court highlighted that cruelty can be "inferred from the conduct, demeanour, or behaviour" and is not confined to physical violence. Here, unreasonable demands and abusive treatment by the wife were held to constitute cruelty.
       
4. What Constitutes Cruelty by the Wife? Based on the above cases and other legal precedents, the following actions by a wife have been deemed as cruelty sufficient to grant a husband divorce:
   • False Accusations of Infidelity or Other Criminal Allegations: Persistent false allegations against the husband, such as extramarital affairs or other crimes, which harm his reputation and mental peace. (Narendra v. K. Meena, 2016)
   • Public Insults or Indignities: Insulting the husband in public or belittling him in front of family or friends can be grounds for cruelty. (Samar Ghosh v. Jaya Ghosh, 2007)
   • Malicious Prosecution or False Complaints: Filing baseless criminal complaints against the husband and his family, which subjects them to harassment and legal trouble. (Vishwanath Sitaram Agrawal v. Sau Sarla Vishwanath Agrawal, 2012)
   • Refusal of Sexual Relations without Reason: Repeated denial of sexual intercourse without any medical or other justifiable reason. This can be a ground for cruelty as it causes mental suffering. (Samar Ghosh v. Jaya Ghosh, 2007)
   • Refusal to Cohabit: A wife's unjustified and prolonged refusal to live with her husband, without a reasonable cause, can constitute mental cruelty.
   • Mental Harassment through Abusive or Harsh Language: Consistent use of abusive language or derogatory remarks that harm the husband's mental well-being. (Shobha Rani v. Madhukar Reddi, 1988)
   • Isolation from Family: Restricting or discouraging the husband from interacting with his family members without a reasonable cause.

Chart Summary of Grounds for Cruelty

Types of Cruelty and Relevant Case Law

Type of Cruelty	Description	Case Law
False Criminal Allegations	Baseless accusations or cases filed against husband or his family	Vishwanath Sitaram Agrawal v. Sau Sarla Vishwanath Agrawal, 2012
Public Insults or Indignities	Humiliating husband in public or in front of family	Samar Ghosh v. Jaya Ghosh, 2007
Malicious Prosecution	Filing frivolous or malicious cases	Narendra v. K. Meena, 2016
Refusal of Sexual Relations	Unreasonable and consistent denial of sexual intercourse	Samar Ghosh v. Jaya Ghosh, 2007
Mental Harassment	Persistent abusive language or harsh treatment	Shobha Rani v. Madhukar Reddi, 1988
Restricting Family Interaction	Preventing the husband from meeting his family	Narendra v. K. Meena, 2016

Conclusion
Cruelty, as a ground for divorce, has evolved through judicial interpretation, with courts considering both objective actions and subjective impacts. Divorce due to cruelty by the wife must be substantiated with evidence showing a clear pattern of behavior that causes mental or physical suffering to the husband. As seen in the above cases, cruelty encompasses both mental and physical aspects, and each case's specifics are assessed in light of the facts presented.