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Section 13(1)(i-a) Hindu Marriage Act includes 'cruelty' as a ground for divorce. The interpretation now adopted by the Supreme Court (Samar Ghosh v Jaya Ghosh 2007) holds that mental cruelty

ARequires only physical violence
BIncludes sustained reprehensible conduct, persistent neglect, unilateral decisions affecting marriage, false complaints, unjustified withdrawal of conjugal relations and similar conduct that makes cohabitation insufferable; it cannot be exhaustively defined
CRequires conviction in a criminal court
DRequires that the cruelty be witnessed by third parties
Answer & Solution
Correct answer: B. Includes sustained reprehensible conduct, persistent neglect, unilateral decisions affecting marriage, false complaints, unjustified withdrawal of conjugal relations and similar conduct that makes cohabitation insufferable; it cannot be exhaustively defined
Samar Ghosh laid down illustrative categories of mental cruelty. Cruelty under s13(1)(i-a) is fact-specific and behavioural. Earlier doctrine had narrowly required apprehension of bodily harm; modern interpretation is broader.
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