Education Alone Not a Ground to Deny Maintenance: Madhya Pradesh High Court

In a significant ruling, the Madhya Pradesh High Court has upheld the decision of a lower court to award maintenance to a woman despite her educational qualifications. The court emphasized that being educated does not negate the right to maintenance if the spouse is unemployed and without means of income.

Background of the Case

The cas (Criminal Revision No. 3801 of 2024) was brought before the High Court following an order by the Principal Judge, Family Court, Neemuch, District Neemuch, Madhya Pradesh. The Family Court had directed the applicant to pay a monthly maintenance of Rs. 9,000 to the respondent.

Legal Issues Involved

The primary legal issue revolved around the entitlement of maintenance under Section 19(4) of the Family Courts Act, 1984. The applicant contended that the respondent, being educated, should not be entitled to maintenance. The applicant’s counsel, Shri Balkrishna Royal, argued that the respondent’s educational qualifications should suffice for her to support herself.

Court’s Decision

Justice Binod Kumar Dwivedi presided over the case and delivered the judgment. After hearing the arguments, the court found no merit in the applicant’s contention. The court observed that the mere fact that the respondent is educated cannot be a sufficient ground to deny her maintenance. 

Justice Dwivedi stated, “A mere ground that the respondent is educated, cannot be a ground not to award any maintenance amount to her.” The court further noted that the applicant earns approximately Rs. 80,000 per month, while the respondent is currently unemployed and without any source of income.

Important Observations

In its detailed order, the court made several critical observations:

“From the very perusal of the impugned order, there is nothing apparent to point out any illegality, irregularity or impropriety in the order, which is required for invoking the revisional jurisdiction of this Court.”

“Education alone does not equate to financial independence, especially when the individual is currently unemployed.”

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The applicant was represented by Shri Balkrishna Royal on behalf of Shri Nilesh J. Dave, while the respondent’s legal representation details were not disclosed in the judgment.

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