High Court’s supervisory jurisdiction under Article 227 precludes reappreciating evidence or substituting plausible findings of fact.

The petitioner (husband) filed a civil proceeding (C.P. No.246 of 2020) for divorce under Section 13(1)(i-a) of the Hindu Marriage Act

The opposite party (wife) filed an application under Section 24 of the Hindu Marriage Act seeking pendente lite maintenance

The learned Family Court, Bhubaneswar, directed the petitioner to pay ₹6,000 per month as maintenance, taking into account a previous order under the D.V. Act

The petitioner challenged this order via a writ petition under Articles 226 and 227 of the Constitution, contending the Family Court ignored relevant materials and failed to properly account for prior payments

1. Whether the Family Court failed to consider relevant materials and prior maintenance payments while awarding pendente lite maintenance under Section 24 of the Hindu Marriage Act

2. Whether the High Court, in exercise of its supervisory jurisdiction under Article 227, should interfere with the discretionary findings of the lower court regarding the quantum of maintenance

Section 24 of the Hindu Marriage Act regarding pendente lite maintenance

Section 20(2) of the D.V. Act regarding fair monetary relief

Rajnesh v. Neha (2021), which established that while adjustment of maintenance from different proceedings is not a mandatory "thumb rule," a just balance must be drawn based on the parties' status and the wife's needs

Nandi Infrastructure Corridor Enterprises Ltd. v. B. Gurappa Naidu (2026), which limits supervisory jurisdiction to cases of "grave dereliction of duty" or "flagrant violation of fundamental principles of law," prohibiting the High Court from acting as a court of appeal

The Court observed that the Family Court had explicitly taken note of the existing ₹6,000 maintenance order under the D.V. Act when passing the current order

It noted that the petitioner failed to provide clear evidence in his affidavits regarding the exact total amount paid pursuant to the Section 24 order

Applying the Rajnesh v. Neha criteria, the Court found that the minor daughter’s maintenance and the wife’s lack of independent income justified the award, which was neither extravagant nor oppressive

Under the Nandi Infrastructure doctrine, the Court reasoned that it could not re-evaluate evidence or substitute its view for that of the Family Court unless the decision was "perverse" or "apparent on the face of the record," which was not the case here

The Court affirmed that its supervisory jurisdiction under Article 227 is correctional, not appellate, and found no gross abuse of jurisdiction. Consequently, the writ petition was dismissed as devoid of merit