Income concealment justifies adverse inference and does not warrant revisional interference with maintenance.

The Family Court, in proceedings under Section 125 of the Code of Criminal Procedure, 1973, assessed the petitioner-husband’s monthly income at ₹30,000 and ordered him to pay maintenance of ₹7,500 each per month to his wife and minor child

The husband challenged the income assessment, seeking that his income be treated as ₹25,000 per month

The Family Court had noted that he gave inconsistent accounts of his employment, concealed an SBI bank account, and did not produce evidence substantiating his claimed current salary

In revision, his counsel accepted that he had not filed an updated affidavit of income and liabilities

1. Whether the Family Court’s assessment of the petitioner’s monthly income at ₹30,000, rather than his admitted income of ₹25,000, disclosed an error warranting interference in revision

2. Whether the difference in maintenance resulting from those competing income assessments constituted a material irregularity warranting revisional interference

Section 397 CrPC confers limited revisional jurisdiction to correct, among other things, patent legal or jurisdictional errors, findings based on no evidence, or arbitrary or perverse exercises of discretion; it does not ordinarily permit reappreciation of evidence or reassessment of factual findings (*Amit Kapoor v. Ramesh Chander*, as quoted at pp.4–5, para. 9; *State of Gujarat v. Dilipsinh Kishorsinh Rao*, p.5, para. 9).

Revisional jurisdiction is discretionary and not claimable as of right (*Girish Kumar Suneja v. CBI*).

In maintenance proceedings, the principles concerning disclosure of income and assets in *Rajnesh v. Neha* support drawing an adverse inference where a party fails to make complete financial disclosure.

The High Court found that the husband had taken inconsistent positions about his employment, first claiming that he had been terminated and remained unemployed, but later admitting that he had worked for Onkar International and then joined Rama Vision

His concealed SBI account, failure to file an updated affidavit, and failure to produce current salary slips justified the Family Court’s adverse inference and its assessment of income at ₹30,000

It also observed that, even on the husband’s claimed income of ₹25,000, the difference in the total monthly maintenance would be only ₹2,500, which, in the circumstances, did not amount to a material irregularity

The High Court dismissed the revision petition and pending applications. The Family Court’s order requiring payment of ₹7,500 per month to each respondent remained undisturbed.