In a landmark ruling, the Supreme Court of India reinstated the Family Court’s decision to award ₹1.75 lakh per month as interim maintenance to a wife in a contentious matrimonial dispute. The Court emphasized that during separation, a wife cannot be deprived of the standard of living she enjoyed during the marriage. The judgment underscores the judiciary’s commitment to ensuring financial equity and dignity for non-earning spouses amidst marital discord.
Background of the Case
The couple, married in 2008 under Christian customs, faced marital discord, leading to a divorce petition filed by the husband in 2019. Alleging cruelty and irreconcilable differences, the husband sought dissolution of the marriage. The wife, who had left her job after marriage, claimed interim maintenance, arguing that she lacked financial resources to maintain herself. She contended that the husband, a prominent professional, had substantial income from his medical practice, real estate, and other ventures.
The Family Court initially awarded ₹1.75 lakh per month as interim maintenance in 2022, considering the husband’s high income and assets. However, the Madras High Court later reduced the amount to ₹80,000 per month, citing insufficient evidence of income. Dissatisfied, both parties approached the Supreme Court—the wife seeking a higher amount and the husband challenging the interim maintenance entirely.
Key Legal Issues
The Supreme Court delved into two primary questions:
1. The Quantum of Maintenance: How should the interim maintenance amount be determined, balancing the wife’s need to maintain her standard of living with the husband’s ability to pay?
2. Evaluation of Income: Did the High Court adequately assess the husband’s income and financial obligations?
Supreme Court’s Observations
The bench, comprising Justice Vikram Nath and Justice Prasanna B. Varale, criticized the High Court for an incomplete assessment of the husband’s financial resources. The apex court emphasized that maintenance decisions should reflect the lifestyle enjoyed during the marriage and the financial disparity between the spouses.
– On Standard of Living: The Court observed that a wife is entitled to “enjoy the same standard of living as she would have in her matrimonial home” during separation. The judgment highlighted that the wife had been accustomed to significant comforts, including domestic help, and such privileges could not be denied post-separation.
– On Financial Transparency: The Court noted that the husband failed to provide complete financial disclosures, including income from various properties and business ventures. “The respondent did not produce his income tax returns or other substantial evidence, undermining his claims of financial constraints,” the Court remarked.
– On Legal Principles: Citing established legal principles, the Court reiterated that maintenance ensures financial stability and dignity for the dependent spouse. It further acknowledged the wife’s sacrifice of employment after marriage as a factor warranting higher maintenance.
Supreme Court’s Decision
The Supreme Court restored the Family Court’s original order, directing the husband to pay ₹1.75 lakh per month as interim maintenance, retroactively applicable from 2019 until the resolution of the divorce proceedings. It dismissed the husband’s appeal for a further reduction, reinforcing that financial stability for the wife during separation is paramount.
