Cruelty under Section 13(1)(ia) has been interpreted broadly by Indian courts to encompass physical violence, mental harassment, emotional abuse, and persistent conduct that makes living together intolerable. The Supreme Court in Samar Ghosh vs. Jaya Ghosh (2007) provided illustrative categories of mental cruelty. Importantly, intention to be cruel is not required — the test is whether the conduct is such that the petitioner cannot reasonably be expected to live with the respondent.