false complaint

In this blogpost, Harsha Jeswani, Student, National Law Institute University, Bhopal, writes about how a false complaint by a wife entitles the husband the right to seek divorce.

INTRODUCTION

Marriage in India is regarded as the institution of unification of a girl and a boy to acclaim the social status in the society. It is often like an institution created by itself. But sadly these days, this institution of marriage is easily broken. There has been an increase in the number of the breakdown of wedlocks each year either due to the fault of the husband or the wife. The wife can file a complaint against husband under Section 498A, IPC, The Hindu Marriage Act, 195 and the Domestic Violence Act, 2005. However, there were instances where a wife instituted a false complaint against her husband. In such cases, the husband had no remedy since the laws of India are tilted towards in favour of women.

It is clear from this unfair nature of laws that unlike other laws of India, the Burden of Proof in laws dealing with protection of women lies on the accused to prove his innocence which means that the husband and his family members are immediately apprehended as soon as wife lodges an FIR that is without an opportunity of being heard, they are considered as accused.

But recently, the verdict given by the High Court of Bombay in the case of Shri Mangesh Balkrushna Bhoir  v. Sau. Leena Mangesh Bhoir decided on 23rd December, 2015 provided some relief to the husband in such cases of false complaints. The Court held that whenever a wife institutes a false complaint against her husband and his family members and the husband and his family members get acquitted, and no case is made out against them, then such an act of wife would constitute cruelty. The judgment was delivered by Justice R.D. Dhanuka wherein he said that on such a ground, the husband is entitled to file a petition for divorce from her wife.

IPC does not define the term cruelty. The courts in India have regarded cruelty as an inhuman act that causes mental sufferings and threatens the health and life of another person. There can be mental as well as physical cruelty either by husband or wife. Section 13(1) (i-a) of The Hindu Marriage Act, 1955 provides cruelty as one of the grounds for divorce and party seeking divorce must prove that it has become impossible for husband and wife to live together.

FACTS OF THE CASE

In the above matter, the complaint was filed by the wife against her husband and his family members under Section 498A[1] read with Section 34[2] of Indian Penal Code. Thereafter, the Husband filed a petition praying for divorce on the ground of cruelty and on other grounds. The petition of the wife was dismissed as the prosecution failed to provide sufficient evidence to the court, and hence the court acquitted the accused. In the meantime, the divorce petition of the Husband was allowed on the ground on cruelty. The first appellate court set aside the order for divorce. The Husband filed an appeal against it.

ISSUE RAISED

The question which came before the High Court was whether the appellate Court was justified in reversing the order of the Trial Court granting a divorce to husband on the ground of cruelty especially when the husband has been acquitted under Section 498A, IPC?

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JUDGMENT

The Court referred to the case of K.Srinivas v. K.Sunita[3] where the Apex Court held that it is a settled point of law that if either spouse lodges a false complaint, it would invariably amount to cruelty and would enable the other spouse to file a petition for divorce. The Court said that whenever a complaint filed by the wife against her husband under Section 498A, IPC is rejected, and the husband and his family members are subsequently acquitted; then it can be said that the complaint filed by the wife is fraudulent. This is contrary to the judgement of the Patna High Court in Bhola Kumar v. Seema Devi[4] where the court said any criminal complaint filed by the wife would not constitute cruelty as a ground for seeking a divorce. Justice R.D. Dhanuka made a distinction holding that in the said case, the petition by the wife against her husband was still pending before the Criminal Court when the petition for divorce was heard by the Family Court. However in instant case, the husband and his family members were acquitted.  .

CRITICAL ANALYSIS

The Supreme Court after receiving a lot of false complaints by the wives against their husbands has settled the law related to cruelty against the Husband. In Mrs. Deepalakshmi Saehia Zingade v. Sachi Rameshrao Zingadeṅ[5], the wife filed a complaint against her husband stating that he has an extra-marital affair which later was proved. Court considered such act of wife cruelty against her husband. Similarly, in Anil Bharadwaj v. Nimlesh Bharadwaj[6], the court held that the refusal of the wife to have sexual intercourse with the husband amounts to cruelty against the husband. Other grounds of cruelty against the husband are-

  1. Adultery by wife during the lifetime of marriage.
  2. Misuse of Section 498A, IPC, the Domestic Violence Act, 2005 and other laws.
  3. Desertion by wife
  4. The Cruel behaviour of a wife.
  5. Initiating criminal proceedings against the husband and his family members with malafide intention, etc.

Thus, looking to the glaring reality where wife often falsely implicates her husband, I am of the opinion that the verdict by the Bombay High Court is totally justified, and, therefore, such decision must be observed all over the country to prevent the institution of marriage and to punish those women who try to mislead the court by filing false complaints against their husbands.

 

[1] 498A. Husband or relative of husband of a woman subjecting her to cruelty.—Whoever, being the husband or the relative of the husband of a woman, subjects such woman to cruelty shall be pun­ished with imprisonment for a term which may extend to three years and shall also be liable to fine. Explanation.—For the purpose of this section, “cruelty” means—(a) any wilful conduct which is of such a nature as is likely to drive the woman to commit suicide or to cause grave injury or danger to life, limb or health (whether mental or physical) of the woman; or (b) harassment of the woman where such harassment is with a view to coercing her or any person related to her to meet any unlawful demand for any property or valuable security or is on account of failure by her or any person related to her to meet such demand.

[2] 34. Acts done by several persons in furtherance of common intention.—When a criminal act is done by several persons in furtherance of the common intention of all, each of such persons is liable for that act in the same manner as if it were done by him alone.

[3] (2014) 16 SCC

[4] (2015) DMC 437 (DB) (Patna)

[5] AIR 2010 Bom 16

[6] AIR 1987 Del 111

 

Click on the links mentioned below to know more on the topics:

No Relief For Wife Under Domestic Violence Act Unless In ‘Relationship’

Does A Second Wife Has Right Of Maintenance In India

Does a husband have to pay alimony if the wife’s adultery is proved in…

 

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35 COMMENTS

  1. I am harrassed every day. I am threatened every day( Mahila samiti and police). I lost my dignity and mental peace. My 12 yrs old son is good in studies and sport. He is a sensitive boy. I feel sorry for him. I don’t when she will file false complain but she is threatening every day. It is because of my son I am suffering all this. I can’t ask her where she is going. I can’t ask her about food. My soul is torched every day. I don’t care for my self but my son will suffer. I don’t know how long this will drag on. I am doing further higher studies. But I am not able to fully concentrate.

  2. I am Shashank Srivastava, I am from Moradabad-244001 Uttar Pradesh, I am also suffering from the same for my brother, brother married in 22nd December 2018, she started showing true colours, and her mother also.
    Why these days women are getting married and after marriage they started showing there true colours. Why these type of women giving false complaints 498 A, 195, and to Mahila Utthan kendra ( Samiti ).
    I request you all to please connect me on this number ( 09634666961 ) we can make a difference and we will connect with more people who are suffering from the same. As you all know that if you have a public support we can win against any cruelty or any war. WhatsApp me AS SOON AS POSSIBLE.

  3. Hello,
    same thing happen with me since one year I am married but from 1st day my wife play with me like a ball, She can’t help me to run my home in proper manner, My family have only my mom, my mom have lots of health issue she avoid to take care of her, Last night she fill false case against me and my mom, there family involve lots into it, His family come in my home make big drama in front of my other society members, they all are seen with their naked eyes, I am in trouble, I want to finish this relation, Don’t want to cont. any thing with here, please help me how I can comup with this problem. that is big problem in front of me. Kindly help me to over come this situation.
    thanks
    kumud singh

  4. I lost my mother 1997 april in a year my family members arranged my marriage when iwas then just 22 in may 1998 however i have two sons i am facing lot of harrasment from my wife which is in credible loss to me by wealth and health still today i belive things go better but all is in vain i cannot understand what to do because i cannot the convince matter infront of others due to harresment since marriage which had affected my views to work for the family upholding the valuable viws for the soceity standup to acheive something

  5. Hi all,
    Indian laws are stupid.they are gender baised law.these laws not made for judgment.they are made for women only whether she is right or wrong.it does not matter at all.only thing is true that husbands are always culprits. These laws are made for harrassment of husband and his family.only fault of husband is that they born in this country india where judgment is made on blind basis that women is always true.

  6. @Priyanka
    We are facing same problem at our home. But we dont have that much proofs with us. She dis same..run away in night . But My brother and few relatives bring her back after 1month. But now she is doing more cruelty then before. Even we lost our Father due to her…
    Hope you able to find any solution. Please be in tough with me at [email protected]

    So that we share options.with each other, as our problem.is same.

  7. My brother got married in November 2017. They were good. They didn’t had problem with each other. But her mom dad n brother n other relatives of her wasn’t letting them live happily . They used to call her everyday n talk around 4 hrs even at night n asking her to do some rubbish with our family. They asked her to record the things we talk at home as she is from village she didn’t know how to operate the smartphone. She recorded her calls. One day my brother got them n listened to all of them but still he or our family members didn’t said anything to her. Her family was telling her to cut my brothers mustache while he is sleeping, n my mom is diabetic they said to put lot of sugar in tea so she will die soon . N say fight everyday while they are having dinner.and quarrel everyday so that my dad get heart attack n die. and some personal things about me and my one more brother.One day even my sister in law said that she wanna kill my mom. And soo on ….. N she went to her family 3months after marriage n she didn’t returned yet. It’s been more than a year now. They want my brother to go n call her. But he is not interested in that coz when is was leaving he said not to go if u go I won’t come to take you. But still my parents went to take her 6-7 times they they disrespected my parents after some months her relative took her to us but we had a condition that she will not talk to her family because they are the reason for all problems. But she didn’t obyed it she took mobile from neighbors n called her family they planned something. And asked her to ran out of home at 4 pm but she couldn’t at that time she went at 5:50 pm. Her parents said to all our relatives that she ran away while she was still at home one of my relative called us asked about it we let her to talk to him. She talked n run away from home. They lied n married my brother. Her mom n dad was a murderer they killed a child working down them n they were in jail. This whole marrige scene was a plan for our property n wealth. We have those recording as the proof. Will my brother get rid of her n her family? They don’t have anything against us cos we were good to her always n loved her lot. But not now. Please say some solution to get out of this devilness. How can we file a case or apply devorce mention the sections too.

  8. Hi All,

    I am Manish, my wife had file case for maintance, domestic violence, and 498A and police complain against me and my family and I know all false case are which are filled against me and I am now getting mentally tourched now… I really got pitched off with situation and I got blessed with cute son and I am asking my wife to meet my parents but she is refusing that… Please help me I am confused with current situation….i am facing huge cruelty from my wife towards me and my family my wife is beating me whenever she angry i am so much scare as she always threatening to us to file 498 we are living in so much fear she always abuse to my mother and i tried to calm her by trying to touching her feet and keep on saying please dont abuse my father but she dont care anything even worse she abuse to my whole family and every one in my family and me i dont know what to do i am on suicidal feeling when i reach to home i want to my house should be keep cool and calm but its not going to possible as she is never understand love

    Reply

  9. Hi All,

    I am Rajesh, my wife had file case for maintance, domestic violence, and 15(3) against me and I know all false case are which are filled against me and I am now getting mentally tourched now… I lost my mom be use of this depression, I lost my grandfather and several time I got admitted in hospital I really got pitched off with situation and I got blessed with cute daughter and I am asking my wife to come back but she is refusing that… Please help me I am confused with current situation.

    Regards
    Rajesh

  10. Alimony is a monetary indemnification granted to the spouse who is incapable to support himself/herself. Atleast 99% at time it’s Husband who pays the alimony.

  11. i give wrong complte on my husband and my husband mother in police station now 3 months happen my my husband taken bail what cani do now??

  12. I pray to god that it should not happen to anybody. Me and my parents suffered a lot because of my horrible wife and in fact my father died of heart attack due to the problems and for not having peace of mind. I truly believe that it became like a business in India. easy money, torturing husband and demanding money. If they get 2 marriages they are settled. I paid 50 Lakh rupees to get divorce. Otherwise she is black mailing me filing false cases against me and my parents, my sister and their husband. We didn`t not take even a single rupee as a dowry. She is well educated earning 80,000 rupees per month. still demanding money for tying knot with out any child for us. Indian laws are stupid. no protection for male. Its the country I don`t want live at all. just surviving for my mother. Otherwise I would have ended my life by killing her. Please imagine how much we are suffering. If everybody are equal. why the laws should be in favor of women not men.

    • Similar things happening with my brother. Her family asking 2cr for divorce. They were together only for three months . It is the first marriage of our family. We all are scared on marriage now. My brother has a wish of he will be one women man. But he thinks if at all he divorce her she get married to one more that would be great dishonor to him n our family. They don’t want to go for court. Can he file case on her and her family?

  13. I’m 35 years old and I had married since june 2009. And my parents are very old age they can’t help himself.And I also having five children three children are going to school two are at home. everything I give to him just they said I will manage from any where I give any things they want.But she always keep showing to everyone that my husband does not give any things. She keep new clothes and wear old and despite the new clothes the children also wear old clothes.if any guest is came our home then it’s more she don’t ask to guest do you need water and food just sit talking all bullshit I don’t have any thing because my husband is not able to earn money.
    If I said any thing then she told me I will kill you with an accident after getting your accent and also she did two three times with the help men and women by giving money and mahila mandal also help to her bcz she acting is very good weeping to the front of people.please please help to me what is solution. And what to do please give early as possible. And contact to me any further details 8149587129

  14. What if husband gives divorce by fraud by locking wife in sm shitty place go 7 months.can u plz unite mewith my husband n family ,doter.plz Hlp me plz Hlp me

  15. i am facing huge cruelty from my wife towards me and my mother my wife is beating me and my wife whenever she angry i am so much scare as she always threatening to us to file 498 we are living in so much fear she always abuse to my mother and i tried to calm her by trying to touching her feet and keep on saying please dont beat my mother but she dont care anything even worse she abuse to my whole family father and every one in my family and me i dont know what to do i am on suicidal feeling when i reach to home i want to my house should be keep cool and calm but its not going to possible as she is never understand love

  16. This is a letter about being an Indian Married Man. It’s not about In India always the woman who suffer in unsuccessful married life. There are so many men like me who has suffered or suffering from a past bad married life.
    This is letter to say “what I want now”. Couldn’t get a good married life, now I want a good future. I want my daughter to be with me to see and live a beautiful life rather than being a victim of our bad marriage
    It’s a fight I want or I am doing it only for my daughter who is also a part of my life and “very important part”.
    I want to move on in my life with her not without her. So would like to tell people what I have gone through and need support to come out from this issue and want to move ahead with my daughter with me.
    By writing all these in media I want to expose Rashmi and her Family how they have harassed me, my family. So it should be a lesson to all those kind of parents and the woman who should not do or attempt to do such kind of damage to any body’s life and misused the Indian women’s law.
    I got married in 20 Dec 2008 and just after 7 days of marriage I came to know that she was pregnant with someone else, it was just shocking for me then I asked her to go back home but she said I will not go back home but I will abort the child and if you tell my parents then I will commit suicide there was no option left with me so I accepted her, that was the blunder I committed even when I asked her why you got married to me if you were into relationship with someone else then she said my parent did my marriage forcefully. On 3rd Jan 2009 we went to Australia and there she aborted child in Woman & Children Hospital (which I have a proof).
    Even after marriage no physical contact established between us for long as she refused initially.
    I felt after aborting everything will be all right. I forgive her and was expecting my marriage life should go smoothly and happily. But things became worse and worse.
    Her parents were just diffusing her mind with all the negative thoughts and their main aim was to extract money from me and they always withdraw money from Rashmi’s account in which I always deposit for saving purpose but they used my all money which I deposited in her account.
    With her behavior I always had a feel that she was mentally unstable, still I managed with her and tried my level best to make a peaceful married life, though she had never shown any kind of interest in taking care of house or of me as a husband.
    When we came back to Pune in 2011, she never had shown any interest in taking care of house .The house used to be taken care by house help, still her parents used to interfere in all our family matters and with only one intension to grab money from me.
    With that fear factor I never attempted to buy a house, as I always used to feel they will snatch the property from me.
    It was not only her parents who had misused me and my money. I was the victim by her brother also. Her brother had killed a man by driving without license and to curb the case they had taken money from Rashmi’s account without my knowledge.
    Her parents used to asked Rashmi to pay their bills by using my card and she paid their bills several times without asking me.
    Her parents used to come to my place and used to flicked things from my house without my knowledge. Being a parents they used to take things from daughter’s house without any shame.
    She was least interested in my family members and she never wanted me to have a good relationship with my family member’s.
    The worse thing was happened, when they got my daughter’s surgery done without my knowledge. My daughter had a birth problem of ankylosed tongue, I had consulted several doctors regarding this, but as per doctor’s suggestion this surgery supposed to be done after 4yrs of age to avoid any side effects of anesthesia which would have impact her brain development. As it was not an issue in verbal communication, so as per doctor’s advice I had thought to get this surgery done after her 4yrs of age completion, but Rashmi and her parents got this surgery done at age of 2.5yrs without consulting me.
    When I was in UK her parents come to my home and they have taken all the gold, diamond, silver and all expensive items (most of the gold items are given to me by my family) with them. Also they had taken my daughter with them by spoiling her half year study.
    During my stay in UK for daily expenses I had given my ATM card to her to avoid facing any kind of financial issue, where as she used to withdraw money frequently and used to give it to her family, when I used to ask her the reason, she never used to share the reason of these withdrawal, so forcefully in Apr’15 I had to block my card.
    In April 2015 when I came back to India I requested Rashmi and her family several times to allow me to meet my daughter , they never allowed me to meet my daughter not even allowed her to talk to me over on phone.
    Rashmi’s parents and her brother threatened me to kill if I will try to meet my daughter. Then I tried to go to their place again along with few of my relatives to request to allow me to meet my daughter and to close this separation process ass a mutual divorce, but they asked me to give us Rs.20 Lkhs, then we will allow you to meet your daughter ….. What kind of justice is this that to meet my own daughter I have pay Rs 20 Lkhs.
    Now I am fighting for divorce in Pune court which is going from last 1+ years but I am unable to see any conclusion, as I have been getting only dates no action is being taken by court, by buying this time its only me and my daughter who are suffering and I am getting mentally harassed by all these things, which is impacting my, my family and my career.
    Apart from all the above things which I have gone through, there are so many other things which I have faced but cannot write down here.
    I would request now to publish my story , so that Rashmi and her family will get exposed and I am hoping and believing our Indian justice will consider this as a strong reason to give my daughter’s custody and give a end to this divorce process. So that I can live a peaceful life.
    With my current mental state I am feeling completely helpless and harassed by a lady and which is making me weak and pushing me to commit suicide
    With such influencing parents I feel my daughter’s future is not safe there, so to secure her future and give her a better life I need my daughter’s custody.
    I need media’s help to get justice for myself and for “MY DAUGHTER “. By doing this I am sure we can save life of so many such helpless kids and helpless FATHER.

    Rakesh Wani
    Mobile Number – 7722005655

    Her Details:
    Rashmi (D/O Eknath Lotan Wani)
    4 Pushplata Apt, Chauhan Colony, Near Pumping Station, Gangapur Road
    Nashik Phone – 9130084055 / 0253 2314893

  17. HI
    My mother in law filed a complaint against my husband under Delhi Women commission 1994.
    My father in law died 21 years ago & after that my husband being eldest in the family started working along with his studies as his two little sisters & one brother were studying.
    My husband earned & bought house in the name of my mother in law (my MIL does not have any source of income), later post our wedding I supported my husband financially & got his siblings settle down & married.
    My mother in law had a little fight with my husband & left our home in Mar 17 & started staying with my brother in law in different house which in my name also (50% share). Later in Jun 17 she had a fight with my brother in law also & she left his house & wanted to come back to us but wanted a partition in house as she said the first house is in her name. We were ready to take her in but did not support of her demand of having a wall & separate entrance. She went to stay with her younger daughter after giving a threaten to my brother in law & his wife that she will make a police complain against them. Both these brothers are united against mother’s inappropriate acts, they both tried to make her understand but she didn’t listen
    Now from no where she filed a complaint against my husband in Delhi Women Commission. Before leaving our house in Mar she & her youngest daughter stole a gold bali also which was fell down from my husband’s ear without his notice & they found it & decided to keep it with them, we have audio recording proof when this happened. we did not take any action for this now this complaint made by her
    Pls advise us where do we stand.

  18. If the wife is not allowing our child to meet the childs grandparents from the time the child is born can be termed as cruelty against the husband and his parents. Please do give me your suggestions on the above.

  19. Hi all, in my case my whole family cruelly tourture by my wife & her family in all aspects of cases, maintenance, divorce, cruelty, police complaint against dowry.

    Indian law is begging to paid tax, but nothing is imporved to save a person for the past 60+ year.
    After marriage on the 7th day I asked her password for uploading the marriage photo.
    during that time I saw a conversation between her ex-boy friend & my wife. I was shocked to see that..I had a back up of everything and even hacked the email id.

    One more thing was my wife parents also knows about this before marriage that their daughter was in love. They blackmailed her daughter to Marry me. I was not know that before marriage until my honeymoon was scattered into Peace’s. I had given many chance to change herself but each time she planning to torture mentally & corner me to the entire family that I was telling a lie. On daily basis she is talking to her lover.

    Even after all the torture she gave finally. In case also doing all the torture…If she continues to do so. I had made up my mind to live or die.

    Regard
    Dynesh

  20. If taking money (dowry) during marriage is CRIME then why not claiming money (alimony /maintainance / compensation) after marriage breakup is consider as Crime ?

    Although every women is now educated and wants equal rights in society,and able to stand on his feet .

    I feel alimony / mtn / compensation should only been consider when wife is illiterate or for child upbringing , else each individual is sufficient to stand on his feet. This may lead to avoid false dowry cases, 498 etc and also change the thinking of women to get husband hard earned money easily in form of compensation / alimony /mtn towards marriage .

    It is a big question for india whether to bring MONEY TERMS between two Soul /family under marriage ?

  21. Mr Harsha Jeswani. Good article. But, getting divorce is no big deal sir. Looking at the title of your article, I was hoping that you had mentioned some incisive points about how to prosecute such wives and what are the strongest possible punishments they are entitled to. Everyone generally says that a husband can file cases like defamation, perjury against such wives. But as you mentioned, the judiciary is soft towards women and these cases like defamation or perjury hardly make these women shiver.

    Anyway, if you have any such knowledge of how to prosecute and send these false women to jail, please do let me know. False cases by women is spreading like virus, and if we properly punish one lady for falsity, then they will wake up and be alert about the consequences.

    • Courts must pass strict punishment against persons filing false complaints, then only it will deter them. Because of women organizations the courts do not give strict punishments to persons who file false cases against husbands. Like women organizations, there must be an organization to support husbands and voice must be heard whenever husbands are harassed by the police.

  22. After my 1st wife died ( after 31 years of marriage ) , my 2nd wife ( married thru matrimonial site contact ) of 7 years marriage has physically , verbally , mentally tortured , abused and assaulted my very old parents and me , in every possible manner .
    My parents filed complaint against her u/s 324 and the case is going on .
    I filed for divorce and the case is going on.
    This 2nd wife ( younger to me by 13 years ) has filed complaints / cases of Domestic Violence , Alimony and also criminal case u/s 498A/34 ahainst me and my very old parents.
    She has her own income , whereas I am unemployed ( senior citizen ) .
    She left the left our house for many months , and thereafter keeps coming and going whenever she feels like .
    Sometimes , she comes back home late at night alone and we have to keep the house door unlocked , so she may enter , otherwise she files complaint that we don’t let her in.
    Please advise how best we can get rid of this very evil , wicked and shameless wife from our house & family.

    • file maintenance case against wife as she is working and you are not. i dont know how come she asks for alimony. make general diaries every time she creates problem. use your mobile phone to record all voice and conversations. for woman no evidence is required for case, but men need strong evidence. so start collecting evidence as much as possible.

  23. Hi,

    this side manish, can someone provide me for CRUELTY AGAINST HUSBAND by wife and her parents i married on last november and from the day first they make false blame me and on my family and her parent also support and ignoring thier daughter mistake.

    please confirm

    thanks

    • Hello,
      same thing happen with me since one year I am married but from 1st day my wife play with me like a ball, She can’t help me to run my home in proper manner, My family have only my mom, my mom have lots of health issue she avoid to take care of her, Last night she fill false case against me and my mom, there family involve lots into it, His family come in my home make big drama in front of my other society members, they all are seen with their naked eyes, I am in trouble, I want to finish this relation, Don’t want to cont. any thing with here, please help me how I can comup with this problem. that is big problem in front of me. Kindly help me to over come this situation.
      thanks
      kumud singh

  24. I have been tortured by wife for last 7 years but know it’s to much. She filled a false blame against me in mahila samithi.I have already been called and again next date is given to me to attend.My mind is not working what to do.Please help me in this regard.

  25. Can someone provide me any material on CRUELTY AGAINST HUSBAND. Am having it as my dissertation topic and already accumulated everything on net. So beyond that if anyone has anything regarding that please convey. Would be highly appreciated..THANKS

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