### Disputed Disclosures in Maintenance Affidavits are Matters of Trial and Do Not Mandate Document Discovery Orders

The petitioners (applicants) challenged an order dated 25.04.2024 passed by the Family Court in a maintenance proceeding under Section 125 of the CrPC.

The Family Court had rejected two applications filed by the petitioners: (i) for a direction to the respondent to produce documents regarding agricultural properties and a specific ICICI bank account, and (ii) for admission/denial of documents under Order XII Rule 2 CPC read with Section 294 CrPC.

The petitioners alleged the respondent suppressed agricultural income and falsely claimed his mother was a dependent.

The respondent contended that he had already filed the mandatory affidavit of assets and liabilities per Supreme Court guidelines and that the applications were a delayed attempt to prolong trial.

1. Whether the Family Court is obligated to direct the production of specific bank and property documents when an affidavit of assets and liabilities has already been filed.

2. Whether the rejection of applications for discovery and admission/denial of documents at an advanced stage of trial constitutes a jurisdictional error.

The court applied the guidelines established by the Supreme Court in Rajnesh v. Neha (2021) 2 SCC 324, which mandate the filing of an affidavit of assets, liabilities, and sources of income in maintenance cases.

It further relied on the discretionary nature of the court's power to direct discovery or production of documents, which should only be exercised when necessary for effective adjudication.

Procedurally, the court applied Section 294 of the CrPC and Order XII Rule 2 of the CPC regarding the admission and denial of documents to curtail unnecessary proof.

The High Court observed that while maintenance determination requires assessing the respondent’s overall financial capacity, the filing of a Rajnesh v. Neha affidavit does not grant an automatic right to the opposite party to demand every document.

The court reasoned that the correctness of the respondent's affidavit is a matter of trial; the petitioners can test its veracity through cross-examination and by confronting the respondent with evidence.

The court characterized the demand for the entire bank passbook without a foundational factual link to suppressed income as a "fishing enquiry".

Regarding the procedural applications, the court held that rejection does not prejudice the petitioners, as they remain free to prove disputed documents through admissible evidence.

Since the trial had progressed to the stage of cross-examination, the court found no patent illegality or failure of justice warranting interference with an interlocutory procedural order.

The court clarified that the petitioners maintain the liberty to confront the respondent during cross-examination with any material regarding suppressed assets or income, and the Family Court may draw an adverse inference if suppression is established.

The Family Court was directed to determine maintenance based on the entire evidence on record, uninfluenced by the observations in this order.