As per your question : if you will not give divorce then she may file 498a case with you and your family member and also file Domestic violence Act , D.P 3 & 4 act ,r/w 34 ipc , it is better that her conduct and character is not good , you insist her to take Khula and you make MOU binding her not to file any criminal case and domestic violence case and maintenance case against you and your family and you proceed with the khula Mou is important you can show if at all she file the criminal cases against you in future . in MOU you take the witnesses of your father in Law with thumb impression and sing .