Court cannot be compelled to entertain repetitive applications for reporting cash transactions to tax authorities in maintenance proceedings.

The respondent (wife) initiated maintenance proceedings under Section 125 of the Cr.P.C. against the petitioner (husband) at the Family Court, Sehore.

During proceedings, the petitioner filed an application alleging that the respondent and her father admitted in pleadings to cash transactions exceeding Rs. 10,00,000/-, which violates the statutory threshold of Rs. 2,00,000/- under the Income Tax Act.

Relying on a Supreme Court precedent (The Correspondent, RBANMS Educational Institution vs. B. Gunashekar and Others), the petitioner sought a direction to the Family Court to intimate the Income Tax Department.

The Family Court rejected this application on 12.01.2026, noting that a similar application had already been dismissed on 21.11.2025.

The petitioner subsequently challenged this rejection before the High Court.

1. Whether the Family Court committed a jurisdictional error or illegality in refusing to intimate the Income Tax Department regarding alleged cash transaction admissions made during maintenance proceedings.

2. Whether the inherent powers of the High Court under Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, should be invoked to interfere with an interlocutory order of the Family Court.

Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023 (formerly Section 482 Cr.P.C.), which governs the inherent powers of the High Court to prevent abuse of process or secure the ends of justice.

Interpretation of directions issued in The Correspondent, RBANMS Educational Institution vs. B. Gunashekar and Others 2025 INSC 490, regarding judicial intimation to tax authorities.

The principle of finality regarding repetitive interlocutory applications on the same foundational facts.

The High Court reasoned that the primary objective of the pending litigation is the adjudication of maintenance, and the tax issue raised by the petitioner is collateral.

The Court found that since a prior application for the same relief had been dismissed on 21.11.2025 and remained unchallenged, the Family Court was correct in declining to entertain a repetitive application.

The Court observed that the petitioner failed to show any prejudice to his substantive rights in the maintenance case.

It held that Supreme Court directions for tax intimation do not create an independent cause of action for a litigant to repeatedly stall proceedings or challenge interlocutory orders in collateral matters.

The Court emphasized that maintenance proceedings should not be converted into tax inquiries, and statutory authorities remain free to act independently if they receive information through appropriate channels.

The court ruled that the refusal to grant the requested relief did not amount to a failure of justice or an abuse of process warranting the exercise of inherent powers under Section 528 BNSS and dismissed the petition.