Rinky Singh vs Deepak Singh Ari on 6 August, 2026

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    Jharkhand High Court

    Rinky Singh vs Deepak Singh Ari on 6 August, 2026

    Bench: Sujit Narayan Prasad, Sanjay Prasad

                                              2026:JHHC:23501-DB
    
    
    
          IN THE HIGH COURT OF JHARKHAND AT RANCHI
                  First Appeal No. 216 of 2025
                              ------
      Rinky Singh, Aged about 36 years, D/o-Mahendra Singh,
      R/o - House 5, 13/5 Priyadarshini Parisar west, Motilal
      Nehru Nagar, Bhilai, Durg, P.O. Nehru Nagar, & P.S. -
      Supela, District-Durg, Chattisgarh-490020.
                                              ...       ...     Appellant
                                 Versus
         1. Deepak Singh Ari, aged about 37 years, Son of Late
           Pritam Singh Ari, R/o Ram Bhawan, Tata Road, Ward
           No. 22, P.O. & P.S. Mofussil, Chaibasa, District West
           Singhbhum.
         2. The State of Jharkhand through D.C. Chaibasa.
                                          ...       ...       Respondents
                             -------
       CORAM: HON'BLE MR. JUSTICE SUJIT NARAYAN PRASAD
                 HON'BLE MR. JUSTICE SANJAY PRASAD
                             -------
       For the Appellant  : Mr. Amit Kumar Das, Sr. Advocate
                          : Mr. Vineet Sinha, Advocate
       For the Resp. No.1 : Mrs. Oishi Das, Advocate
       For the State      : Mr. Bhola Nath Ojha, Spl. P.P.
                                  ------
    C.A.V. on 07.07.2026        Pronounced on 06/08/2026
    
    Per Sujit Narayan Prasad, J.
    

    1. The instant appeal, under Section 19(1) of the Family

    Court Act, 1984, is directed against the order/judgment dated

    SPONSORED

    25.03.2025 and decree signed on 05.04.2025 passed by the

    learned Principal Judge, Family Court, West Singhbhum at

    Chaibasa in Original Suit No.81 of 2024, whereby and

    whereunder, the suit filed by the respondent-husband for

    dissolution of marriage by decree of divorce u/s 13(1)(i-a) and

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    (i-b) of Hindu Marriage Act, 1955 against the appellant-wife,

    has been allowed.

    Factual Matrix

    2. The marriage between the respondent herein/petitioner

    and the appellant/ respondent was solemnized on 28.12.2016

    according to Sikh rites and ceremonies at Nehru Nagar

    Gurudwara, Bhilai, District Durg, Chhattisgarh. The marriage

    was an arranged marriage initiated through the matrimonial

    website Jeevansathi.com.

    3. After marriage, the parties started residing together as

    husband and wife. Out of the wedlock, one daughter was

    born.

    4. The petitioner alleges that after the marriage, differences

    arose between the parties on account of incompatibility of

    temperament and repeated matrimonial discord. According to

    him, the respondent frequently stayed at her parental home

    and despite repeated requests, did not return to the

    matrimonial home. The petitioner visited the parental house

    of the respondent on 18.07.2018 to bring the respondent and

    the minor daughter back, but he was allegedly misbehaved

    with by the respondent and her family members and

    ultimately returned on 22.07.2018.

    5. The petitioner has alleged that on different occasions he

    transferred amounts of Rs.10,000/- each to the accounts of

    the respondent’s mother and brother to meet the respondent’s

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    requirements. Despite such efforts, the respondent allegedly

    refused to resume cohabitation.

    6. Consequently, the petitioner instituted proceedings under

    Section 9 of the Hindu Marriage Act for restitution of conjugal

    rights before the Court,Chaibasa which was registered as

    Original Suit No.20 of 2019. During pendency thereof, the

    respondent sought transfer of the proceeding before the

    Hon’ble Supreme Court by filing Transfer Petition (Civil)

    No.1167 of 2020. The Hon’ble Supreme Court stayed the

    proceedings and thereafter transferred the case to the

    Principal Judge, Family Court, Durg.

    7. Thereafter, several litigations came to be instituted

    between the parties. The respondent lodged Supela Police

    Station Case No.660 of 2019 under Sections 498A/34 IPC

    against the petitioner, his mother and married sister. The

    petitioner and his family members obtained anticipatory bail

    and subsequently charge-sheet was submitted giving rise to

    Criminal Case No.2666 of 2021 before the learned Chief

    Judicial Magistrate, Durg.

    8. The petitioner further alleges that on 23.07.2019 the

    respondent along with her family members came to his

    residence and forcibly entered the house, assaulted his

    mother and removed jewellery from the house. On the basis

    of the complaint lodged by the petitioner’s mother, Muffasil

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    P.S. Case No.84 of 2019 under Sections 323, 341, 342, 379,

    504, 506 read with Section 34 IPC was registered.

    9. The respondent also initiated proceedings under Section

    125 Cr.P.C. seeking maintenance for herself and the minor

    daughter, claiming monthly maintenance of Rs.40,000/-

    along with litigation expenses. She also instituted proceedings

    under Section 12 of the Protection of Women from Domestic

    Violence Act before the competent Court at Durg.

    10. The petitioner, on the other hand, filed proceedings

    under Sections 10 and 25 of the Guardians and Wards Act

    seeking custody and guardianship of the minor daughter.

    11. During pendency of the aforesaid proceedings, with

    the intervention of elders, well-wishers and learned counsel

    appearing for both sides, the parties amicably resolved all

    their disputes. The terms of the settlement are as follows:

    (a) the parties agreed to dissolve their marriage by

    mutual consent;

    (b) the petitioner-husband (respondent herein)

    agreed to pay a consolidated sum of Rs.20,00,000/-

    (Rupees Twenty Lakhs only) as one-time permanent

    alimony towards full and final settlement of all claims

    of the respondent and the minor daughter;

    (c) on presentation of the joint petition, the petitioner

    paid Rs.10,00,000/- through demand

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    drafts/cheques, which the respondent/appellant

    herein accepted and encashed;

    (d) the petitioner handed over all jewellery belonging

    to the respondent except one diamond ring and one

    gold ring, which were agreed to be delivered at the

    time of second motion;

    (e) custody of the minor daughter shall permanently

    remain with the respondent;

    (f) the petitioner shall have visitation rights, if

    mutually agreed between the parties;

    (g) both parties agreed to withdraw all pending civil

    and criminal proceedings against each other and

    their respective family members.

    12. Pursuant to the settlement, the petitioner withdrew

    the proceedings under Section 9 of the Hindu Marriage Act

    and under Sections 10 and 25 of the Guardians and Wards

    Act. Likewise, the respondent withdrew the proceedings under

    Section 125 Cr.P.C. and under the Protection of Women from

    Domestic Violence Act.

    13. The petitioner complied with all the terms and

    conditions agreed between the parties for dissolution of

    marriage, he paid the half of the permanent alimony amount

    agreed and was ready and willing to pay the remaining half

    amount agreed. However, the respondent started

    blackmailing the petitioner by demanding additional amount

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    as permanent alimony and threatened that she would not give

    her consent for dissolution of marriage during second motion

    and when the petitioner refused to accede to illegal and unjust

    demands of respondent, she acted on her threats and refused

    to give her consent for dissolution of her marriage and

    withdrew her consent. As such the proceeding under Section

    13(1)B was dismissed by the learned Principal Judge, Family

    Court, Durg, vide order dated 25.11.2023 and the respondent

    also did not return the sum of Rs. 10,00,000/- and jewelry

    taken by her as per terms and conditions agreed between

    them in proceeding under Section 13(B) of the HMA 1955 and

    has kept the criminal proceeding bearing Criminal Proceeding

    Case No. 2666/2021, pending before the court of the learned

    CJM Durg, Chattisgarh.

    14. The respondent/ petitioner-husband, on the ground

    of cruelty and desertion, had filed an application under

    Section 13(1) (i-a) (i-b), of the Hindu Marriage Act, 1955 before

    the Family Court for a decree of divorce against his lawfully

    wedded wife and the same was numbered as the Original Suit

    No. 81 of 2024.

    15. Notice was issued to the respondent through speed

    post as well as the petitioner himself served the notice upon

    respondent wife but she did not appear before the court.

    16. Thereafter, learned Family Court ordered to publish

    the notice in daily newspaper widely circulated in Bhilai-

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    Raipur, so the notice was published in Dainik Bhaskar

    newspaper on 24.11.2024 published from Bhilai-Raipur but

    the respondent again did not appear before the court.

    17. The court found that all the notices were duly served

    upon respondent and the notice was also published in daily

    newspaper in Dainik Bhaskar on 24.11.2024 despite that the

    respondent evaded herself from court proceeding, so the court

    was of the view that notice was presumed to be duly served

    upon respondent. The court initiated ex parte proceeding on

    20.12.2024 against respondent-wife and the petitioner was

    directed to produce evidence documentary and oral, if any.

    18. The learned Principal Judge, after hearing learned

    counsel for the petitioner and taking into consideration the

    material available on record, has framed four issues for

    adjudication of the lis, which are being referred as under:-

    ” (i) Whether the suit is maintainable in its present form?

    (ii) Whether there is any cause of action for filing the suit?

    (iii) Whether the respondent wife committed subjected to
    physical and mental cruelty with her husband by misbehaving
    with him and her mother-in-law and has deserted her
    husband permanently to bring cohabitation to an end (animus
    deserendi)?

    (iv) Whether the petitioner is entitled visitation right to meet
    with his daughter within the scope of section 26 of Hindu
    Marriage Act?”

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    19. Thereafter, the case proceeded for evidence during

    which the respondent-husband has examined five witnesses

    including himself as well as exhibited some documents.

    20. The learned Principal Judge, Family court, after

    appreciating the evidence adduced on behalf of petitioner,

    came to the conclusion that the respondent-husband, has

    been able to prove and substantiate the factum of cruelty

    meted out to him by the defendant-wife and that the

    appellant-wife has deserted him, as such it was held that the

    husband, the respondent herein, is entitled to get a decree of

    divorce, against which, the instant appeal has been preferred

    by the wife-appellant.

    Submission of the learned counsel for the appellant:

    21. Learned counsel for the appellant has submitted that

    though the appellant intends to reside with the respondent

    but since the respondent/husband is adamant not to live with

    the appellant-wife, as such, the only question remains for

    alimony.

    22. Learned counsel for the appellant has submitted that

    he will not argue the case on merit and prayed that the matter

    may be resolved by providing the alimony for one time

    settlement.

    23. Lastly, he has submitted that the appellant-wife has

    no source of income to survive.

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    Submission of the learned counsel for the respondent:

    24. Learned counsel appearing for the respondent has

    submitted that he also does not want to go into the merit of

    issue and the matter may be decided taking into consideration

    the fact that a compromise was arrived at between the parties,

    whereby and where under the parties agreed to file an

    application for dissolution of their marriage by mutual

    consent and the respondent-husband agreed to pay a

    consolidated sum of Rs.20,00,000/- as one-time permanent

    alimony towards full and final settlement of all claims of the

    respondent and the minor daughter, out of which the

    respondent-husband paid Rs.10,00,000/- through demand

    drafts/cheques, which the respondent accepted and

    encashed.

    25. Learned counsel for the respondent-husband has

    submitted that the respondent-husband is still ready to pay

    25,00,000/- as one-time permanent alimony.

    Analysis:

    26. Being aggrieved with the impugned judgment passed

    by the learned family court, the appellant-wife has preferred

    the present appeal.

    27. Thereafter, the matter was heard by this Court on

    09.04.2026 and on that date, learned counsel for both parties

    have consented that in order to explore the possibility of

    settlement through reunion, the parties may be called upon.

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    28. In view of such submission, this Court called upon

    both the parties on the next date of hearing.

    29. On 05.05.2026, both parties appeared before this

    Court. The Court interacted with them, however, the

    respondent-husband remained adamant in his refusal to

    reside with the appellant-wife.

    30. Accordingly, both the parties were directed to file

    their respective affidavits in view of the judgment rendered in

    the case of Rajnesh v. Neha & Anr. [(2021) 2 SCC 324]

    giving therein the details of their source of income both

    movable and immovable.

    31. The Deputy Commissioner, Chaibasa was also

    directed to submit a report regarding the entire assets of the

    respondent-husband and the known/unknown source of

    income.

    32. In pursuance to the direction of this Court, the

    appellant-wife, has filed affidavit dated 09.06.2026 stating

    inter alia therein that she has no source of income and she is

    completely dependent upon her parents for the expenses of

    self and the child.

    33. The respondent-husband has also filed affidavit

    disclosing his income etc. and accordingly the matter has

    been heard on the point of determination of permanent

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    alimony without going in to the merit of the impugned

    judgment.

    34. In pursuance to the direction of this Court dated

    05.05.2026, the Deputy Commissioner, Chaibasa has also

    filed affidavit giving therein the details of movable property

    and the income of the respondent.

    35. However, after appearance of the respondent-

    husband, the parties have agreed for permanent alimony and

    accordingly submission has been made in support thereof.

    36. It is evident from record that during the pendency of

    the suit before the learned Family Court, the appellant-wife

    has expressed her willingness to accept dissolution of

    marriage, provided she is paid Rs.20,00,000/- as permanent

    alimony in full and final settlement. The respondent-husband

    had also agreed and accordingly Rs. Ten Lakh has been

    accepted in form of demand draft and the said demand draft

    was encashed by the wife (appellant herein) but later on the

    appellant wife withdrew her consent and the matter could not

    be settled finally.

    37. This Court in the aforesaid backdrop facts and

    submission requires to consider as to “what would be the

    quantum of permanent alimony to meet the needs of the

    appellant/wife and the female child on the basis of pleadings

    available on record?”

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    38. This Court, before considering the aforesaid issue,

    needs to refer herein the provision of law as contained under

    Section 25 of the Hindu Marriage Act, 1955, wherein it has

    been provided that any court exercising jurisdiction under

    this Act may, at the time of passing any decree or at any time

    subsequent thereto, on application made to it for the purpose

    by either the wife or the husband, as the case may be, order

    that the respondent shall pay to the applicant for her or his

    maintenance and support such gross sum or such monthly

    or periodical sum for a term not exceeding the life of the

    applicant as, having regard to the respondent’s own income

    and other property, if any, the income and other property of

    the applicant, it may seem to the court to be just, and any

    such payment may be secured, if necessary, by a charge on

    the immovable property of the respondent. For ready

    reference, Section 25 of the Act, 1955 is quoted as under:

    “25. Permanent alimony and maintenance.–(1) Any
    court exercising jurisdiction under this Act may, at the time
    of passing any decree or at any time subsequent thereto, on
    application made to it for the purpose by either the wife or
    the husband, as the case may be, order that the respondent
    shall pay to the applicant for her or his maintenance and
    support such gross sum or such monthly or periodical sum
    for a term not exceeding the life of the applicant as, having
    regard to the respondent’s own income and other property,
    if any, the income and other property of the applicant 1 [the
    conduct of the parties and other circumstances of the case],
    it may seem to the court to be just, and any such payment

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    may be secured, if necessary, by a charge on the immovable
    property of the respondent.

    (2) If the court is satisfied that there is a change in the
    circumstances of either party at any time after it has made
    an order under sub-section (1), it may, at the instance of
    either party, vary, modify or rescind any such order in such
    manner as the court may deem just.

    (3) If the court is satisfied that the party in whose favour an
    order has been made under this section has re-married or,
    if such party is the wife, that she has not remained chaste,
    or, if such party is the husband, that he has had sexual
    intercourse with any woman outside wedlock, 2 [it may at
    the instance of the other party vary, modify or rescind any
    such order in such manner as the court may deem just].”

    39. It is evident from the aforesaid provision that concept

    of permanent alimony as provided under Section 25 have been

    enacted with the object of removing the hardship of the wife

    or the husband with no independent income sufficient for

    living or meeting litigant expenses; such a leave can be

    granted as well who may also be deprived of the same on proof

    of having sexual intercourse outside the wedlock. It is also

    settled position of law that the Court may grant permanent

    alimony to the party while disposing of the main application

    even if application has been moved; meaning thereby the

    intent of the Act is to remove the handicap/hardship of a wife

    or husband by passing an appropriate order at the

    appropriate stage either under Section 24 or 25 of the Hindu

    Marriage Act, 1955. The basic behind this is to sustain the life

    of husband or wife, if having no sufficient source of income.

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    40. The Hon’ble Apex Court has also considered the

    intent of Section 25 of Hindu Marriage Act in catena of

    Judgments wherein it has been observed that Section 25 of

    Act 1955 is an enabling provision. It empowers the court in a

    matrimonial case to consider facts and circumstances of the

    spouse applying and deciding whether or not to grant

    permanent alimony. Sub-section (1) of Section 25 provides

    that a matrimonial Court exercising the jurisdiction under

    the Hindu Marriage Act may at the time of passing a decree

    or at any time subsequent thereto on an Application made to

    it, order to pay maintenance.

    41. Thus, a power is conferred on the Matrimonial Court

    to grant permanent alimony or maintenance on the basis of a

    decree of divorce passed under the Hindu Marriage Act even

    subsequent to the date of passing of the decree on the basis

    of an application made in that behalf. Sub-section (2)

    of Section 25 confers a power on the Court to vary, modify or

    rescind the order made under Sub-section (1) of Section 25 in

    case of change in circumstances. The power under Sub-

    section (3) of Section 25 is an independent power. The said

    power can be exercised if the Court is satisfied that the wife

    in whose favour an order under Subsection (1)

    of Section 25 of the Hindu Marriage Act is made has not

    remained chaste. In such event, at the instance of the other

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    party, the Court may vary, modify or rescind the order under

    Sub-section (1) of Section 25 of the Hindu Marriage Act.

    42. Reference in this regard may be made to the

    judgment rendered by the Hon’ble Apex Court in the case of

    Kalyan Dey Chowdhury v. Rita Dey Chowdhury Nee

    Nandy, (2017) 14 SCC 200. For ready reference, paragraph

    14 of the judgment is quoted as under:

    “14. Section 25 of the Hindu Marriage Act, 1955 confers
    power upon the court to grant a permanent alimony to either
    spouse who claims the same by making an application. Sub-
    section (2) of Section 25 of the Hindu Marriage Act confers
    ample power on the court to vary, modify or discharge any
    order for permanent alimony or permanent maintenance
    that may have been made in any proceeding under the Act
    under the provisions contained in sub-section (1) of Section

    25. In exercising the power under Section 25(2), the court
    would have regard to the “change in the circumstances of
    the parties”. There must be some change in the
    circumstances of either party which may have to be taken
    into account when an application is made under sub-section
    (2) of Section 25 for variation, modification or rescission of
    the order as the court may deem just.”

    43. We may note here that a substitution has been brought to

    Sub-section (3) of Section 25 of the Hindu Marriage Act with

    effect from 27th May 1976. Earlier, it was provided under Sub-

    section (3) of Section 25 that if the Court was satisfied that the

    party in whose favour an order has been made has not remained

    chaste, it shall rescind the order. The words “it shall rescind the

    order” appearing in Sub-section (3) of Section 25 were replaced

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    by the said amendment by the words “it may at the instance of

    the other party vary, modify or rescind any such order …..”. The

    legislature in its wisdom by the said substitution has provided

    that after the facts stated in Sub-section (3) of Section 25 of

    the Hindu Marriage Act are established, the Court may vary,

    modify or rescind any such order under Sub-section (1)

    of Section 25 of the Hindu Marriage Act. Thus, after 1976, there

    is a discretion conferred on the Court by Sub-section (3)

    of Section 25 of the Hindu Marriage Act of declining to rescind,

    vary or modify the order under Sub-section (1) of Section 25

    thereof, even if on an Application made by the husband/wife, it

    is established that the husband/wife has not remained chaste

    after the decree of maintenance is passed under Sub-section (1)

    of Section 25.

    44. The Hon’ble Apex Court in the case of Vinny Parmvir

    Parmar v. Parmvir Parmar, (2011) 13 SCC 112 while

    appreciating the core of Section 25 of the Act 1955 has observed

    that for permanent alimony and maintenance of either spouse,

    the respondent’s own income and other property, and the

    income and other property of the applicant are all relevant

    material in addition to the conduct of the parties and other

    circumstances of the case, for ready reference the relevant

    paragraph of the aforesaid judgment is being quoted as under:

    “12. As per Section 25, while considering the claim for
    permanent alimony and maintenance of either spouse, the

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    respondent’s own income and other property, and the
    income and other property of the applicant are all relevant
    material in addition to the conduct of the parties and other
    circumstances of the case. It is further seen that the court
    considering such claim has to consider all the above
    relevant materials and determine the amount which is to be
    just for living standard. No fixed formula can be laid for
    fixing the amount of maintenance. It has to be in the nature
    of things which depend on various facts and circumstances
    of each case. The court has to consider the status of the
    parties, their respective needs, the capacity of the husband
    to pay, having regard to reasonable expenses for his own
    maintenance and others whom he is obliged to maintain
    under the law and statute. The courts also have to take note
    of the fact that the amount of maintenance fixed for the wife
    should be such as she can live in reasonable comfort
    considering her status and mode of life she was used to live
    when she lived with her husband. At the same time, the
    amount so fixed cannot be excessive or affect the living
    condition of the other party. These are all the broad
    principles courts have to be kept (sic keep) in mind while
    determining maintenance or permanent alimony.

    45. It needs to refer herein that no arithmetic formula can be

    adopted for grant of permanent alimony to wife. However, status

    of parties, their respective social needs, financial capacity of

    husband and other obligations must be taken into account. The

    Hon’ble Apex Court in the case of U. Sree v. U. Srinivas, (2013)

    2 SCC 114 has observed that while granting permanent

    alimony, no arithmetic formula can be adopted as there cannot

    be mathematical exactitude. It shall depend upon the status of

    the parties, their respective social needs, the financial capacity

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    of the husband and other obligations. For ready reference the

    relevant paragraph is being quoted as under:

    “33. We have reproduced the aforesaid orders to highlight
    that the husband had agreed to buy a flat at Hyderabad.
    However, when the matter was listed thereafter, there was
    disagreement with regard to the locality of the flat arranged
    by the husband and, therefore, the matter was heard on
    merits. We have already opined that the husband has made
    out a case for divorce by proving mental cruelty. As a decree
    is passed, the wife is entitled to permanent alimony for her
    sustenance. Be it stated, while granting permanent
    alimony, no arithmetic formula can be adopted as there
    cannot be mathematical exactitude. It shall depend upon
    the status of the parties, their respective social needs, the
    financial capacity of the husband and other obligations.
    In Vinny Parmvir Parmar v. Parmvir Parmar [(2011) 13 SCC
    112 : (2012) 3 SCC (Civ) 290] (SCC p. 116, para 12) while
    dealing with the concept of permanent alimony, this Court
    has observed that while granting permanent alimony, the
    court is required to take note of the fact that the amount of
    maintenance fixed for the wife should be such as she can
    live in reasonable comfort considering her status and the
    mode of life she was used to when she lived with her
    husband. At the same time, the amount so fixed cannot be
    excessive or affect the living condition of the other party.

    46. In the case of Rajnesh v. Neha & Anr. [(2021) 2 SCC 324]

    the Hon’ble Apex Court has extensively dealt with the issue of

    granting interim/permanent alimony and has categorically held

    that the objective of granting interim/permanent alimony is to

    ensure that the dependent spouse is not reduced to destitution

    or vagrancy on account of the failure of the marriage, and not

    as a punishment to the other spouse. There is no straitjacket

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    formula for fixing the quantum of maintenance to be awarded.

    The Hon’ble Apex Court further held that the Court while

    considering the issue of maintenance, should consider the

    factors like the status of the parties; reasonable needs of the

    wife and dependent children; whether the applicant is educated

    and professionally qualified; whether the applicant has any

    independent source of income; whether the income is sufficient

    to enable her to maintain the same standard of living as she was

    accustomed to in her matrimonial home; whether the applicant

    was employed prior to her marriage; whether she was working

    during the subsistence of the marriage, for ready reference the

    relevant paragraph of the aforesaid judgment is being quoted as

    under:

    “77. The objective of granting interim/permanent alimony
    is to ensure that the dependent spouse is not reduced to
    destitution or vagrancy on account of the failure of the
    marriage, and not as a punishment to the other spouse.
    There is no straitjacket formula for fixing the quantum of
    maintenance to be awarded.

    78. The factors which would weigh with the court inter alia
    are the status of the parties; reasonable needs of the wife
    and dependent children; whether the applicant is educated
    and professionally qualified; whether the applicant has any
    independent source of income; whether the income is
    sufficient to enable her to maintain the same standard of
    living as she was accustomed to in her matrimonial home;
    whether the applicant was employed prior to her marriage;
    whether she was working during the subsistence of the
    marriage; whether the wife was required to sacrifice her
    employment opportunities for nurturing the family, child
    rearing, and looking after adult members of the family;

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    reasonable costs of litigation for a non-working wife. [ Refer
    to Jasbir Kaur Sehgal v. District Judge, Dehradun
    , (1997) 7
    SCC 7; Refer to Vinny Parmvir Parmar v. Parmvir Parmar,
    (2011) 13 SCC 112 : (2012) 3 SCC (Civ) 290]

    79. In Manish Jain v. Akanksha Jain [Manish
    Jain
    v. Akanksha Jain, (2017) 15 SCC 801 : (2018) 2 SCC
    (Civ) 712] this Court held that the financial position of the
    parents of the applicant wife, would not be material while
    determining the quantum of maintenance. An order of
    interim maintenance is conditional on the circumstance that
    the wife or husband who makes a claim has no independent
    income, sufficient for her or his support. It is no answer to a
    claim of maintenance that the wife is educated and could
    support herself. The court must take into consideration the
    status of the parties and the capacity of the spouse to pay
    for her or his support. Maintenance is dependent upon
    factual situations; the court should mould the claim for
    maintenance based on various factors brought before it.

    80. On the other hand, the financial capacity of the
    husband, his actual income, reasonable expenses for his
    own maintenance, and dependent family members whom
    he is obliged to maintain under the law, liabilities if any,
    would be required to be taken into consideration, to arrive
    at the appropriate quantum of maintenance to be paid. The
    court must have due regard to the standard of living of the
    husband, as well as the spiralling inflation rates and high
    costs of living. The plea of the husband that he does not
    possess any source of income ipso facto does not absolve
    him of his moral duty to maintain his wife if he is able-

    bodied and has educational qualifications.
    [ReemaSalkan v. Sumer Singh Salkan, (2019) 12 SCC 303 :

    (2018) 5 SCC (Civ) 596 : (2019) 4 SCC (Cri) 339]

    81. A careful and just balance must be drawn between all
    relevant factors. The test for determination of maintenance
    in matrimonial disputes depends on the financial status of
    the respondent, and the standard of living that the applicant
    was accustomed to in her matrimonial home.

    [Chaturbhuj v. Sita Bai, (2008) 2 SCC 316 : (2008) 1 SCC

    20
    2026:JHHC:23501-DB

    (Civ) 547 : (2008) 1 SCC (Cri) 356] The maintenance amount
    awarded must be reasonable and realistic, and avoid either
    of the two extremes i.e. maintenance awarded to the wife
    should neither be so extravagant which becomes oppressive
    and unbearable for the respondent, nor should it be so
    meagre that it drives the wife to penury. The sufficiency of
    the quantum has to be adjudged so that the wife is able to
    maintain herself with reasonable comfort.

    47. The Hon’ble Supreme Court in the case of Rajnesh v.

    Neha (supra), provided a comprehensive criterion and list of

    factors to be looked into while deciding the question of

    permanent alimony. This judgment lays down an elaborate

    and comprehensive framework necessary for deciding the

    amount of maintenance in all matrimonial proceedings, which

    specific emphasis on permanent alimony and the same has

    been reiterated by Hon’ble Supreme Court in Kiran Jyot

    Maini v. Anish Pramod Patel reported in 2024 SCC OnLine

    SC 1724.

    48. The Hon’ble Supreme Court in Kiran Jyot

    Maini (supra), while discussing the husband’s obligation to

    maintain the wife and the importance of his financial capacity

    in deciding the quantum, observed under para 26 that:-

    “26. Furthermore, the financial capacity of the husband is
    a critical factor in determining permanent alimony. The
    Court shall examine the husband’s actual income,
    reasonable expenses for his own maintenance, and any
    dependents he is legally obligated to support. His liabilities
    and financial commitments are also to be considered to
    ensure a balanced and fail maintenance award. The court

    21
    2026:JHHC:23501-DB

    must consider the husband’s standard of living and the
    impact of inflation and high living costs. Even if the
    husband claims to have no source of income, his ability
    to earn, given his education and qualifications, is to be
    taken into account. The courts shall ensure that the
    relief granted is fair, reasonable, and consistent with
    the standard of living to which the aggrieved party was
    accustomed. The court’s approach should be to balance
    all relevant factors to avoid maintenance amounts that are
    either excessively high or unduly low, ensuring that the
    dependent spouse can live with reasonable comfort post-
    separation.”

    49. The Hon’ble Supreme Court in the case of Pravin

    Kumar Jain v. Anju Jain reported in 2024 SCC OnLine SC

    3678 has taken note of the various judgments to clarify the

    position of law with regard to determination of permanent

    alimony and the factors that need to be considered in order to

    arrive at a just, fair, and reasonable amount of permanent

    alimony. In para 31 it is held as under:

    “31. There cannot be strict guidelines or a fixed formula for
    fixing the amount of permanent maintenance. The
    quantum of maintenance is subjective to each case and is
    dependent on various circumstances and factors. The
    Court needs to look into factors such as income of both the
    parties; conduct during the subsistence of marriage; their
    individual social and financial status; personal expenses
    of each of the parties; their individual capacities and duties
    to maintain their dependents; the quality of life enjoyed by
    the wife during the subsistence of the marriage; and such
    other similar factors. This position was laid down by this
    Court in Vinny Paramvir Parmar v. Paramvir Parmar,
    and Vishwanath Agrawal v. Sarla Vishwanath Agrawal.”

    22

    2026:JHHC:23501-DB

    50. Recently, the Hon’ble Apex Court in the case of

    Rakhi Sadhukhan Vs. Raja Sadhukhan [2025 SCC

    OnLine SC1259] has enhanced the amount of alimony

    subject to increase of alimony in every two years.

    51. This Court has considered the factual aspect of the

    said case and on perusal of the fact, referred therein, it is

    evident that in the said case, the appellant-wife and

    respondent-husband were married on 18.06.1997. A son was

    born to them on 05.08.1998. In July 2008, the respondent-

    husband filed Matrimonial Suit No. 430 of 2008 under

    Section 27 of the Special Marriage Act, 1954 seeking

    dissolution of marriage on the ground of cruelty allegedly

    inflicted by the appellant-wife. Subsequently, the appellant-

    wife filed Misc. Case No. 155 of 2008 in the same suit under

    Section 24 of the Hindu Marriage Act, 1955, seeking interim

    maintenance for herself and the minor son. The Trial Court,

    by order dated 14.01.2010, awarded interim maintenance of

    Rs. 8,000/- per month to the appellant-wife and Rs. 10,000/-

    towards litigation expenses. The appellant-wife then

    instituted Misc. Case No. 116 of 2010 under Section 125 of

    the Criminal Procedure Code, 1973. The Trial

    Court, vide order dated 28.03.2014, directed the respondent-

    husband to pay maintenance of Rs. 8,000/- per month to the

    appellant-wife and Rs. 6,000/- per month to the minor son,

    23
    2026:JHHC:23501-DB

    along with Rs. 5,000/- towards litigation costs. The Trial

    Court, vide order dated 10.01.2016, dismissed the

    matrimonial suit, finding that the respondent-husband had

    failed to prove cruelty. Aggrieved, the respondent filed FAT No.

    122 of 2015 before the High Court of Calcutta. During the

    pendency of the appeal, the appellant-wife filed CAN No. 4505

    of 2025 seeking interim maintenance of Rs. 30,000/- for

    herself and Rs. 20,000/- for the son, along with Rs. 50,000/-

    towards litigation expenses. The High Court, by order dated

    14.05.2015, directed the respondent-husband to pay interim

    maintenance of Rs. 15,000/- per month. Subsequently, by

    order dated 14.07.2016, the High Court noted that the

    respondent-husband was drawing a net monthly salary of Rs.

    69,000/- and enhanced the interim maintenance to Rs.

    20,000/- per month. Finally, the High Court, by the impugned

    order dated 25.06.2019, allowed the respondent’s appeal,

    granted a decree of divorce on the ground of mental cruelty

    and irretrievable breakdown of marriage, and directed the

    respondent-husband to redeem the mortgage on the flat

    where the appellant-wife was residing and transfer the title

    deed to her name by 31.08.2019; allowed the appellant-wife

    and their son to continue residing in the said flat; and

    continue to pay permanent alimony of Rs. 20,000/- per

    month to the appellant-wife, subject to a 5% increase every

    three years. Additionally, the High Court directed payment of

    24
    2026:JHHC:23501-DB

    educational expenses for the son’s university education and

    Rs. 5,000/- per month for private tuition.

    52. Aggrieved by the quantum of alimony awarded, the

    appellant-wife approached the Hon’ble Apex Court.

    53. The Hon’ble Apex Court, by interim order dated

    07.11.2023, noting the absence of representation on behalf of

    the respondent-husband despite proof of service, enhanced

    the monthly maintenance to Rs. 75,000/- with effect from

    01.11.2023. The respondent-husband subsequently entered

    appearance and filed an application seeking vacation of the

    said interim order.

    54. The appellant-wife contended that the amount of

    Rs.20,000/- per month, which the High Court made final, was

    originally awarded as interim maintenance. She submitted

    that the respondent-husband has a monthly income of

    approximately Rs. 4,00,000/- and the quantum of alimony

    awarded is not commensurate with the standard of living

    maintained by the parties during the marriage.

    55. In response, the respondent-husband submitted that

    his current net monthly income is Rs. 1,64,039/-, earned

    from his employment at the Institute of Hotel Management,

    Taratala, Kolkata. He has placed on record salary slips, bank

    statements, and income tax returns for the year 2023-2024.

    It is further stated that he was earlier employed with the Taj

    25
    2026:JHHC:23501-DB

    Hotel, drawing a gross annual salary of Rs. 21,92,525/-. He

    also submits that his monthly household expenses total Rs.

    1,72,088/-, and that he has remarried, has a dependent

    family, and aged parents. The respondent-husband contends

    that their son, now 26 years of age, is no longer financially

    dependent.

    56. The Hon’ble Apex Court taking note of the quantum

    of permanent alimony fixed by the High Court has come to the

    conclusion that it requires revision. The said revision is on the

    basis of the respondent-husband’s income, financial

    disclosures, and past earnings which establish that he is in a

    position to pay a higher amount. The Hon’ble Apex Court has

    observed that the appellant-wife, who has remained

    unmarried and is living independently, is entitled to a level of

    maintenance that is reflective of the standard of living she

    enjoyed during the marriage and which reasonably secures

    her future. It has also been observed, the inflationary cost of

    living and her continued reliance on maintenance as the sole

    means of financial support necessitate a reassessment of the

    amount.

    57. Therefore, Hon’ble Apex Court has held that, a sum

    of Rs. 50,000/- per month would be just, fair and reasonable

    to ensure financial stability for the appellant-wife. The said

    amount shall be subject to an enhancement of 5% every two

    26
    2026:JHHC:23501-DB

    years. As regards the son, now aged 26, the Hon’ble Apex

    Court has expressed its view that the Court is not inclined to

    direct any further mandatory financial support. However, it is

    open to the respondent-husband to voluntarily assist him

    with educational or other reasonable expenses. It has been

    clarified that the son’s right to inheritance remains

    unaffected, and any claim to ancestral or other property may

    be pursued in accordance with law.

    58. Accordingly, the appeal was allowed and the order of

    the High Court was modified to the extent that the permanent

    alimony payable to the appellant-wife shall be Rs. 50,000/-

    per month, subject to a 5% increase every two years, for ready

    reference the relevant paragraph of the said order is being

    quoted as under:

    “7. Having considered the submissions and materials on
    record, we are of the view that the quantum of permanent
    alimony fixed by the High Court requires revision. The
    respondent-husband’s income, financial disclosures, and
    past earnings establish that he is in a position to pay a
    higher amount. The appellant-wife, who has remained
    unmarried and is living independently, is entitled to a level
    of maintenance that is reflective of the standard of living she
    enjoyed during the marriage and which reasonably secures
    her future. Furthermore, the inflationary cost of living and
    her continued reliance on maintenance as the sole means of
    financial support necessitate a reassessment of the amount.

    8. In our considered opinion, a sum of Rs. 50,000/- per
    month would be just, fair and reasonable to ensure financial
    stability for the appellant-wife. This amount shall be subject
    to an enhancement of 5% every two years. As regards the

    27
    2026:JHHC:23501-DB

    son, now aged 26, we are not inclined to direct any further
    mandatory financial support. However, it is open to the
    respondent-husband to voluntarily assist him with
    educational or other reasonable expenses. We clarify that
    the son’s right to inheritance remains unaffected, and any
    claim to ancestral or other property may be pursued in
    accordance with law.

    9. In view of the above, the appeal is allowed. The
    impugned order of the High Court is modified to the extent
    that the permanent alimony payable to the appellant-wife
    shall be Rs. 50,000/- per month, subject to a 5% increase
    every two years, as noted above.”

    59. Further it needs to refer herein that in maintenance

    proceedings it is of primary importance that the income of the

    spouse is first assessed. Such assessment of income may be

    of two kinds. In cases where documentary evidence such as

    salary slips, bank statements, or income tax returns are

    available, the Court can take the actual income as discernible

    from the record. However, in many cases, husband either fail

    to disclose his true income, conceal relevant details, or claim

    to be unemployed despite indications to the contrary. In such

    circumstances, the Courts must make a reasonable and fair

    assessment of the husband’s income, taking into account his

    educational qualifications, professional background, past

    employment, lifestyle, bank transactions, and other material

    placed on record.

    60. Once the income, whether actual or notional, is

    determined, the Court must then proceed to apportion the

    28
    2026:JHHC:23501-DB

    same among the dependents, including the wife and any

    children, keeping in view their reasonable needs and standard

    of living. Therefore, assessing income is the first and most

    crucial step, as maintenance cannot be determined in

    vacuum. Only after establishing what the earning spouse

    actually earns, or can reasonably be expected to earn, can a

    just and proportionate amount be fixed towards the

    sustenance of those who are entitled to be maintained.

    61. The grant of maintenance ensures that a woman is

    not forced to rely on her parents or relatives for basic needs,

    but can live with dignity and autonomy. Only when adequate

    maintenance is granted, she can hope to secure independent

    accommodation, meet her daily expenses and denying or

    reducing maintenance on the assumption that her parents

    can support her effectively undermines the very purpose of

    law of maintenance, which seeks to protect a deserted or

    destitute spouse from financial helplessness. The duty to

    maintain a wife rests primarily on the husband, in case she is

    not earning for herself, and cannot be diluted on the ground

    that she is presently living with her parents or that her

    parents have means to assist her.

    62. In every proceeding of determination of alimony,

    there are two sides to a human story- that of the wife and that

    of the husband. Each brings forth a version shaped by their

    experiences, grievances, and perceptions. It is the duty of the

    29
    2026:JHHC:23501-DB

    Court to assess these narratives not mechanically but

    pragmatically, and to arrive at a conclusion that is grounded

    in both evidence and social reality.

    63. Thus, the principle governing grant of permanent

    alimony is that it must be fair, reasonable, and commensurate

    with the status of the parties, the income and capacity of the

    husband, and the needs of the wife. The Court cannot impose

    an amount which is beyond the paying capacity of the

    husband, nor can it leave the wife without adequate financial

    security.

    64. In the backdrop of the aforesaid settled position of

    law this Court is now re-adverting to the factual aspects of the

    instant case.

    65. It is admitted fact that the marriage between the

    petitioner and the respondent was solemnized on 28.12.2016

    according to Sikh rites and ceremonies at Nehru Nagar

    Gurudwara, Bhilai, District Durg, Chattisgarh and the

    respondent-husband has filed the suit for divorce on

    04.09.2024 i.e., after 08 years of marriage, on the ground of

    cruelty and desertion.

    66. The suit filed for divorce by the respondent-husband

    has been allowed, against which the present appeal has been

    filed.

    67. Before this Court, the learned counsel for the parties,

    on instruction, has submitted that there is no chance of re-

    30

    2026:JHHC:23501-DB

    union since the respondent/husband is adamant not to live

    with the appellant-wife.

    68. Learned counsel for the appellant-wife has submitted

    that since the respondent/husband is adamant not to live

    with the appellant-wife and did not want to live with her, as

    such the parties agreed for settlement by way of permanent

    alimony.

    69. At this juncture, learned counsel appearing for the

    respondent-husband has canvassed that the issue of

    permanent alimony ought to be adjudicated by the learned

    Family Court, and hence the matter be relegated to the

    original forum for determination thereof.

    70. In this context, it is apposite to advert to Section 25

    of the Hindu Marriage Act, 1955, which expressly confers

    jurisdiction upon the Court to grant permanent alimony and

    maintenance at the time of passing a decree of dissolution of

    marriage.

    71. It is indisputable that while adjudicating upon

    dissolution of marriage, evidence is adduced, and

    simultaneously the Family Court is vested with competence

    to determine the quantum of alimony necessary for the

    sustenance of the spouse who suffers separation consequent

    upon such decree.

    72. Reference must be made to the authoritative

    pronouncement of the Hon’ble Supreme Court in Rajnesh v.

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    2026:JHHC:23501-DB

    Neha (supra), wherein comprehensive guidelines and

    procedural parameters have been delineated for assessing the

    quantum of alimony. The said guidelines, already adverted to

    in the preceding paragraphs, constitute binding precedent

    and must govern the present adjudication.

    73. Insofar as the submission advanced on behalf of the

    respondent-husband that the issue of alimony be remitted to

    the Family Court is concerned, we are unable to accede

    thereto. Once the Apex Court has prescribed the format of

    affidavit of disclosure of assets and liabilities for both parties,

    the determination of alimony must proceed on the basis of

    such affidavits, without relegating the matter afresh.

    74. The legislative object underlying Section 25 is

    sustenance of the separated spouse. To remit the matter

    back, as prayed, would inflict further trauma upon the

    appellant-wife, who has already endured the rigours of

    litigation since 2019 culminating in dissolution of marriage.

    75. Remand to the Family Court would not only be

    dilatory but also oppressive for the appellant-wife, prolonging

    her ordeal unnecessarily.

    76. From the order dated 29 June 2026, it is manifest

    that learned counsel for the respondent had agreed to

    determination of alimony and even offered a sum of

    ₹25,00,000/-, which was duly recorded in the said order,

    though not accepted by learned counsel for the

    32
    2026:JHHC:23501-DB

    appellant-wife, for ready reference, the order dated 29th June,

    2026 is being referred herein :-

    “10/Dated:29th June, 2026
    Heard learned counsel for both the parties.

    2. As a last resort, Mr. Indrajit Sinha, learned counsel
    appearing for the respondent has submitted that his client
    is ready for settlement at the amount of Rs.25,00,000/-
    (Rs.Twenty Five Lakhs) by way of lump sum amount which
    has not been agreed by Mr. Amit Kumar Das, learned senior
    counsel appearing for the appellant.

    3. Learned counsel for the respondent-husband has sought
    for a week’s time to interact with his client on the issue of
    enhancement of the said amount.

    4. As prayed for by the learned counsel for the respondent,
    list this case on 07.07.2026.”

    77. The pivotal question that arises is whether, once this

    Court has proceeded to determine the issue of alimony on the

    basis of the consent recorded from learned counsel for the

    respondent in the various orders referred hereinabove, it

    remains open to the respondent at this stage to seek

    relegation of the matter to the Family Court for adjudication

    of alimony. In our considered view, such a course is

    impermissible.

    78. It is further pertinent to note that affidavits in terms

    of the directions of this Court have already been filed, and at

    that juncture no plea for remand was advanced. Indeed, from

    the order dated 29 June 2026, it is evident that learned

    counsel for the respondent-husband unequivocally submitted

    that the respondent was prepared to pay a sum of

    33
    2026:JHHC:23501-DB

    ₹25,00,000/- as one-time permanent alimony. In light of this

    recorded statement, the contention now urged–that the issue

    be remitted to the Family Court–cannot be countenanced

    and is liable to be rejected.

    79. In order to adjudicate upon the quantum of

    permanent alimony, this Court has meticulously examined

    the affidavit filed by the respondent-husband. It is disclosed

    therein that the respondent is engaged in business as sole

    proprietor of Indian Trading Company, which undertakes

    supply of motor parts and allied equipment. The affidavit

    furnishes particulars of his movable assets and is

    accompanied by the Income Tax Return for the Assessment

    Year 2025-26, thereby evidencing his financial worth and

    capacity.

    80. It has been stated in the affidavit that the

    respondent’s monthly income is Rs.1,80,000/- which is

    supported by his Income Tax Return for the Assessment Year

    2025-26.

    81. The respondent has also annexed documents

    showing repayment of loan which he has obtained for his

    personal and official use. He has shown total loan of Rs.

    1,30,00,000/- (Rupees One Crore Thirty Lakhs)

    approximately and the total EMI which he pays is

    Rs.2,80,000/- (Rupees Two Lakhs Eight Thousand) per

    month.

    34

    2026:JHHC:23501-DB

    82. The affidavit filed by the Deputy Commissioner,

    Chaibasa contains a notarized affidavit given by the

    respondent-husband wherein he has stated that against a

    loan of Rs.11,57,998/- which has been taken for purchase of

    Hyundai Creta car an EMI of Rs.23,204/- is being paid but

    that amount is being paid by his brother-in-law since the said

    vehicle is being used by him.

    83. Considering this statement of the respondent-

    husband to be true, then also the total loan against his name

    come to Rs.1,18,00,000/- approximately and the monthly

    repayment (EMI) comes to Rs.2,56,000/- approximately.

    84. Now the question arises that when the respondent

    has stated that he has monthly income of Rs.1,80,000/- how

    can he deposit the monthly installment of Rs.2,56,000/-

    towards repayment of loan. From the documents annexed

    with the affidavit, it is also evident that the respondent has

    not defaulted in making repayment of loan.

    85. From the documents available on record, it is also

    evident that 90% of the total loan has been procured after

    filing of the suit for dissolution of marriage.

    86. In view of the aforesaid, this Court is of the view that

    the respondent-husband has not shown his actual income in

    the affidavit and his actual income is much more than what

    he has stated in his affidavit.

    35

    2026:JHHC:23501-DB

    87. At this juncture it needs to refer herein the settled

    position of law that the impact of a loan taken by a husband

    for “future wealth construction” during the pendency of a

    matrimonial suit which consequently reduces his total income

    due to loan payments, on the amount of alimony payable to

    his wife is a matter that courts scrutinize carefully. Generally,

    such voluntary financial commitments are not permitted to

    diminish the husband’s primary obligation to maintain his

    wife.

    88. The husband’s duty to maintain his wife is

    paramount. Any voluntary financial liability, such as a loan

    for “future wealth construction,” should not be allowed to

    diminish this fundamental duty. The wife’s right to

    maintenance is often considered paramount. The court will

    scrutinize the genuineness and purpose of the loan. If the loan

    is taken primarily to reduce disposable income and thereby

    evade maintenance obligations, or if the “future wealth

    construction” is speculative or solely for the husband’s benefit

    without any direct or indirect benefit to the wife or children,

    the court may disregard the reduction in income caused by

    EMI payments.

    89. Courts often consider not just the actual income but

    also the earning capacity of the husband. If the loan is

    perceived as a deliberate act to reduce visible income despite

    a healthy earning capacity, the court may fix maintenance

    36
    2026:JHHC:23501-DB

    based on his potential earnings rather than his artificially

    reduced net income. Courts have consistently held that

    voluntary deductions or liabilities incurred by the husband,

    which are not necessary for his sustenance or statutory

    obligations, cannot be used to reduce maintenance payable to

    the wife. Repayments of loans, particularly those for asset

    creation, are considered voluntary capital investments rather

    than essential or unavoidable expenditures.

    90. In the case of Deepa Joshi v. Gaurav Joshi, (2026)

    INSC 370 the Hon’ble Apex Court has categorically observed

    that deductions arising from financial commitments such as

    loan repayments, particularly when they contribute towards

    the creation of assets, cannot be treated on the same footing

    as necessary expenditure to substantially reduce the

    husband’s liability for maintenance. The Court emphasized

    that the liability to maintain a spouse is a primary obligation

    and cannot be subordinated to such financial arrangements.

    It clarified that repayments of loans, especially those resulting

    in the creation or acquisition of assets, partake in the

    character of capital investment and cannot be equated with

    essential or unavoidable expenditure. Such financial

    commitments, being voluntary in nature, cannot be given

    precedence over the statutory and legally enforceable

    obligation of maintenance. For ready reference the relevant

    37
    2026:JHHC:23501-DB

    paragraphs of the aforesaid judgment are being quoted as

    under:

    “13. However, deductions arising out of financial
    commitments such as loan repayments, particularly where
    they contribute towards creation of assets, cannot be placed
    on the same footing as necessary expenditure so as to
    substantially reduce the liability of maintenance. The
    liability to maintain a spouse is a primary obligation and
    cannot be subordinated to such financial arrangements.

    14. It is also not in dispute that the appellant ha no
    independent source of income and has been residing
    separately shortly after the marriage. The maintenance
    awarded must therefore enable her to sustain herself with
    a reasonable degree of dignity, consistent with the status of
    the parties. At the same time, it is necessary to ensure that
    the determination remains fair and reasonable and does not
    impose an excessive burden upon the respondent. The
    exercise is one of achieving a just balance between
    competing considerations.

    15. Insofar as the financial capacity of the respondent is
    concerned, it is borne out from the compliance affidavit filed
    pursuant to the order dated 06.02.2026 that the respondent
    is employed as a Manager with Canara Bank and is
    drawing a gross monthly income of ₹1,15,670/-. The Courts
    below have taken note of certain deductions from the said
    income, including repayments towards loans. However, it
    is well settled that repayments of loans, particularly
    where such repayments result in creation or
    acquisition of assets, partake the character of
    capital investment and cannot be equated with
    essential or unavoidable expenditure. Such financial
    commitments, being voluntary in nature, cannot be
    accorded precedence over the statutory and legally
    enforceable obligation of maintenance.

    16. The obligation of the husband to maintain his
    spouse is a primary and continuing duty, which must
    be discharged in a manner that enables the wife to

    38
    2026:JHHC:23501-DB

    live with dignity and in a standard commensurate
    with that enjoyed during the subsistence of the
    marriage. Viewed thus, deductions on account of
    asset-generating repayments cannot be permitted to
    substantially dilute the respondent’s real earning
    capacity for the purpose of determining
    maintenance.

    91. Based on the consistent judicial pronouncements,

    particularly the Supreme Court’s ruling in Deepa Joshi v.

    Gaurav Joshi (supra) a loan taken by the husband for “future

    wealth construction” during the pendency of a matrimonial

    suit, which reduces his income, will generally not affect the

    amount of alimony to the wife adversely. Courts view such

    loans as voluntary financial commitments or capital

    investments that cannot take precedence over the husband’s

    primary and statutory obligation to maintain his wife. The

    court will assess the husband’s actual earning capacity and

    ensure that the wife receives adequate maintenance

    commensurate with her needs and the marital standard of

    living.

    92. This Court, taking into consideration the aforesaid,

    is of the view that the respondent-husband has constant

    source of income but the appellant-wife is to survive on the

    amount of interest to be received from the amount of

    permanent alimony and the future inflation etc. is also

    39
    2026:JHHC:23501-DB

    required to be kept in mind before allowing the permanent

    alimony.

    93. The appellant-wife, as per her affidavit, is only 36

    years of age and taking into consideration the life expectancy

    of a female in India is 70 years approximately and, therefore,

    the permanent alimony is to be calculated for next 34 years.

    94. The learned Family Court, in Original Maintenance

    Case No.9 of 2020 has awarded maintenance of Rs.10,000/-

    per month and if Rs.10,000/- per month is calculated for next

    34 years, it would come to Rs.40,00,000/- approximately.

    95. This Court, upon due consideration of the rival

    submissions and the law enunciated by the Hon’ble Apex

    Court as adverted to hereinabove, has once again scrutinized

    the affidavit filed by the respondent-husband. The

    respondent, being a businessman and sole proprietor of

    Indian Trading Company, has disclosed his financial

    particulars and produced acknowledgment of filing of Income

    Tax Return for the Assessment Year 2025-2026. From the

    said material, it emerges that the respondent’s actual annual

    income is ₹21,68,774/- per year. Conversely, the

    appellant-wife is left to subsist solely upon the quantum of

    permanent alimony to be awarded, her livelihood being

    entirely dependent thereon.

    96. This Court is conscious that the respondent-

    husband is also to survive and he has other liability and

    40
    2026:JHHC:23501-DB

    responsibility but it is also his utmost duty to maintain the

    standard of life of the appellant-wife, she would have enjoyed

    during subsistence of the marriage as per income and status

    of her husband, the respondent herein.

    97. It needs to refer herein that there is no rigid

    mathematical formula to determine maintenance. However,

    the Supreme Court in Kalyan Dey Chowdhury vs Rita Dey

    Chowdhury (Supra) observed that around 25 per cent of the

    husband’s net salary may serve as a reasonable benchmark,

    though this is not a universal rule. Courts generally assess

    the paying spouse’s “free income”, allowing deductions only

    for statutory liabilities such as income tax or provident fund,

    while disregarding voluntary expenses like equated monthly

    instalments (EMIs) on loans or insurance premiums.

    98. This Court, taking life expectancy of the wife and the

    status of the parties, their respective needs, the capacity of

    the husband to pay, having regard to reasonable expenses for

    his own maintenance and others whom he is obliged to

    maintain under the law and statute vis-à-vis the fact that the

    amount of maintenance fixed for the wife should be such as

    she can live in reasonable comfort considering her status and

    mode of life she was used to live when she lived with her

    husband, is of the view that a minimum amount of Rs. 30

    lakhs would be just and proper for her sustenance.

    41

    2026:JHHC:23501-DB

    99. In regard to the future welfare of the minor daughter,

    aged about eight years, particularly her education and health,

    it has been averred in the affidavit filed by the appellant-wife

    that the child is suffering from the ailment of urticaria

    occasioned by dust allergies. Having given anxious

    consideration to the matter, this Court is of the considered

    view that a sum of Rs. 30,00,000/- (Rupees Thirty Lakh only)

    shall be secured by the respondent in the form of a fixed

    deposit, to be created in the name of the said daughter, within

    a period of one year from the date of this order so as to

    safeguard her interests.

    100. This amount balances the financial capacity of the

    husband with the legitimate entitlement of the wife to secure

    the future of the minor daughter and appellant-wife, who has

    no other source of income other than the amount of alimony

    so received from the respondent-husband for their livelihood

    and sustenance.

    101. In view of the admitted position that, through the

    intervention of well-wishers, a settlement had earlier been

    arrived at between the parties, pursuant whereto the

    respondent-husband paid a sum of ₹10,00,000/- by way of

    demand drafts/cheques, which the appellant-wife accepted

    and encashed, therefore, it is hereby directed that the

    respondent-husband shall pay a further sum of ₹20,00,000/-,

    42
    2026:JHHC:23501-DB

    out of the total ₹30,00,000/- towards permanent alimony to

    the appellant-wife.

    102. The aforesaid sum of ₹20,00,000/- shall be

    disbursed by the respondent-husband in four equal

    instalments within a period of twelve months from the date of

    this order. The first instalment shall be paid within two

    months from today, and the remaining instalments shall

    follow at equal intervals thereafter.

    103. Further, the respondent shall also ensure that the

    instrument of fixed deposit amounting to Rs.30,00,000/-

    (Rupees Thirty Lakhs only), created in the name of the minor

    daughter pursuant to the directions of this Court, is duly

    handed over to the appellant within a period of one year.

    104. This Court, upon consideration of the factual matrix

    of the case, and particularly bearing in mind that the financial

    constraints faced by the respondent-wife ought not to imperil

    the sustenance of either herself or the minor daughter, grants

    liberty to the respondent-wife that, in the event the aforesaid

    amount is not credited to her account or the fixed deposit is

    not duly created in the name of the daughter in terms of the

    directions herein, she shall be at liberty to seek appropriate

    relief before a court of competent jurisdiction, in accordance

    with law.

    105. This Court, however, entertains the hope and trust

    that the respondent husband shall not occasion any default

    43
    2026:JHHC:23501-DB

    or invite such situation and will scrupulously abide by the

    directions herein issued for payment of permanent alimony in

    favour of the appellant-wife.

    106. Accordingly, the order dated 25th March 2025 and the

    decree drawn on 5th April 2025 by the learned Principal

    Judge, Family Court, West Singhbhum at Chaibasa in

    Original Suit No. 81 of 2024, stand modified to the extent

    indicated hereinabove, so as to incorporate the directions of

    this Court with respect to permanent alimony.

    107. In light of the foregoing directions and observations

    recorded hereinabove, the instant appeal stands disposed of

    and decreed in the terms set forth, with the modification of

    the impugned judgment and decree to the extent indicated.

    108. Pending Interlocutory Application, if any, stands

    disposed of.

             I Agree                      (Sujit Narayan Prasad, J.)
    
    
    
        (Sanjay Prasad, J.)                 (Sanjay Prasad, J.)
    
    Dated: 06/08/2026
    
    Birendra/A.F.R.
    
    
    Uploaded on 07.08.2026
    
    
    
    
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