Manish Jain v Akanksha Jain

Facts

• During the pendency of matrimonial proceedings, the wife sought maintenance pendente lite and litigation expenses under Section 24 of the Hindu Marriage Act. A dispute arose over the husband's actual income and financial capacity, and whether the wife's own income or resources disentitled her to interim maintenance.

Issue

1. What factors govern the assessment of maintenance pendente lite under Section 24 HMA, and whether a wife having some independent income is automatically disqualified from claiming interim maintenance.

Held

• The court must assess the income and financial capacity of the respondent spouse realistically, rather than accepting bare assertions of low income at face value. The reasonable needs of the claimant spouse, having regard to the standard of living during the marriage, are a relevant consideration. A spouse's limited independent income does not, by itself, disentitle them to maintenance pendente lite; the objective is to ensure the claimant is not left without support during the pendency of proceedings and can adequately prosecute or defend the case. Maintenance pendente lite is intended to provide for subsistence and litigation expenses, and courts should adopt a practical, need-based approach rather than a mechanical one.

Ratio Decidendi

Section 24 of the Hindu Marriage Act requires a realistic and holistic assessment of both spouses' financial circumstances, with the objective of ensuring a dependent spouse is not deprived of the means to litigate and sustain themselves; independent income of modest scale does not defeat an otherwise valid claim for interim maintenance.