Naveen Kohli v. Neelu Kohli's case dealt with:

Naveen Kohli discussed a marriage that had irretrievably broken down and recommended adding breakdown as a statutory divorce ground. The actual decree also rested on the case’s cruelty findings; the recommendation did not itself amend the Hindu Marriage Act.

Current law: Shilpa Sailesh (2023) confirmed the Supreme Court’s Article 142 power to dissolve a marriage on irretrievable breakdown in appropriate cases, including without mutual consent. This is a discretionary Supreme Court power, not a general new statutory ground available to every matrimonial court.