Court’s Decision
The Supreme Court upheld the divorce decree granted by the Family Court and confirmed by the High Court. However, it modified the maintenance order, directing the respondent-husband to pay ₹10,00,000 as a one-time settlement to the appellant-wife.
The Court noted that the respondent had not been forthright about his income and assets and was attempting to evade his financial obligations post-divorce. Taking into account the husband’s financial status, remarriage, and the wife’s needs, the Court concluded that ₹10,00,000 would be a fair and equitable amount to settle all maintenance claims.
Facts of the Case
The appellant-wife and the respondent-husband got married on June 27, 2012, in Nagpur according to Hindu customs. The marriage lasted only two months, as the appellant-wife left the matrimonial home soon after.
Key Events:
- The respondent-husband filed for divorce in 2014 under Section 13 of the Hindu Marriage Act, 1955, citing cruelty and desertion by the wife.
- He claimed that the wife left the matrimonial home because she was unwilling to live in a joint family.
- The appellant-wife filed a separate petition seeking annulment of the marriage, alleging that the husband had married her for money and had committed fraud.
- The Family Court dismissed the wife’s petition and granted divorce to the husband on July 31, 2017, on the ground of mental cruelty.
- The wife challenged the divorce decree before the Bombay High Court, which dismissed her appeal on April 25, 2018 and upheld the divorce.
- The appellant then approached the Supreme Court challenging the divorce decree and seeking maintenance.
- During the proceedings, the respondent informed the Court that he had remarried in 2019.
Mediation Attempts:
- The Supreme Court referred the parties to mediation to negotiate a financial settlement.
- Mediation failed, and the matter proceeded on merits, focusing on maintenance and financial settlement.
Issues Before the Court
- Should the Supreme Court interfere with the divorce decree?
- What is the appropriate amount of maintenance for the appellant-wife?
- Was the respondent-husband truthful about his income and assets?
Petitioner’s (Wife’s) Arguments
The appellant-wife opposed the divorce decree and claimed maintenance.
She argued that:
- The respondent falsely accused her of cruelty and desertion to obtain a divorce.
- She was subjected to domestic violence and verbal abuse, forcing her to leave the matrimonial home.
- The respondent misrepresented his financial position, falsely claiming to be a daily-wage laborer.
- The respondent owned a gym, earned rental income, and worked as an electrical engineer, making over ₹1,30,000 per month.
- Given the husband’s financial status, she was entitled to adequate financial support.
Respondent’s (Husband’s) Arguments
The respondent-husband supported the divorce decree and opposed the maintenance claim.
He argued that:
- The marriage had irretrievably broken down, and both parties no longer wished to reconcile.
- He had already remarried in 2019, making the question of divorce irrelevant.
- He was a daily-wage worker earning only ₹16,612 per month.
- He had four dependents (his parents, brother, and second wife) and could not afford to pay high maintenance.
- The appellant ran a salon in Nagpur, earning ₹2,00,000 per month, and did not need financial support.
Analysis of the Law
The Court examined key precedents on maintenance and financial settlements in divorce cases, including:
- Rajnesh v. Neha [(2021) 2 SCC 324] – Established factors for determining maintenance, including:
- Financial status of both spouses
- Living standards during the marriage
- Husband’s financial capacity
- Wife’s ability to support herself
- Kiran Jyot Maini v. Anish Pramod Patel (2024 SCC OnLine SC 17824) – Reaffirmed that maintenance should be fair and reasonable.
- Manish Jain v. Akanksha Jain [(2017) 15 SCC 801] – Maintenance should ensure that the dependent spouse does not suffer financial hardship.
The Court emphasized that attempts to hide financial details will not be tolerated and that maintenance should not be punitive but fair.
Precedent Analysis
The Court considered past rulings that emphasize:
- A dependent spouse should not be left in financial distress post-divorce.
- Husbands must truthfully disclose their income and assets.
- Courts should award maintenance that reflects the lifestyle during the marriage.
Court’s Reasoning
- The Court refused to interfere with the divorce decree, as both parties had agreed to the separation.
- The Court found that the respondent concealed his financial status and had multiple sources of income, including:
- A gym earning at least ₹80,000 per month.
- A job at SPANCO earning ₹50,000 per month.
- Rental income of ₹30,000 per month.
- The husband’s claim that the wife earned ₹2,00,000 per month was unsubstantiated.
- Considering the husband’s multiple income sources and obligations, the Court held that ₹10,00,000 as a one-time settlement was reasonable.
Conclusion
- Divorce decree upheld – The marriage had irretrievably broken down, and both parties accepted separation.
- ₹10,00,000 awarded as a one-time settlement – To cover all pending and future claims of the wife.
- Payment deadline set at three months – Failure to comply could result in legal consequences.
Implications of the Judgment
- Strengthens the principle of financial transparency in maintenance cases.
- Discourages spouses from hiding assets to avoid paying maintenance.
- Sets a precedent for one-time settlements in divorce cases, reducing prolonged litigation.
- Protects the financial rights of dependent spouses while preventing unfair financial burdens.
