Lack of matrimonial harmony or attention to parents does not constitute "sufficient reason" for separate living under Section 125(4) Cr.P.C.

The applicant (husband) and non-applicant No. 1 (wife) were legally wedded and had two children.

Following matrimonial disputes, the wife began residing with her parents and filed for maintenance under Section 125 Cr.P.C.

The husband contended the wife left voluntarily, registered a false case under Section 498-A IPC (in which the husband and his family were subsequently acquitted), and leveled scandalous allegations of an illicit relationship between him and his sister-in-law.

The Family Court, Ratlam, granted maintenance of Rs. 10,000 to the wife and Rs. 5,000 each to the two children, totaling Rs. 20,000 per month.

The husband challenged this order, arguing the wife was barred from maintenance under Section 125(4) Cr.P.C. for living separately without sufficient cause.

1. Whether a lack of harmony or a husband paying more attention to his parents constitutes a "sufficient reason" for a wife to live separately under Section 125(4) Cr.P.C.

2. Whether the wife is entitled to maintenance despite being found to have committed mental cruelty and leveling false character-assassinating allegations.

3. Whether the disqualification of the wife under Section 125(4) Cr.P.C. affects the maintenance rights of the minor children.

Section 125(4) of the Cr.P.C., which mandates that no wife is entitled to maintenance if she refuses to live with her husband without sufficient reason.

Narendra v. K. Meena (2016), establishing that a wife’s insistence on a husband separating from his parents without strong justification constitutes cruelty.

Vijaykumar Ramchandra Bhate v. Neela Vijaykumar Bhate (2003), which holds that leveling false allegations of unchastity or extra-marital relations constitutes the worst form of mental cruelty.

Rina Kumari v. Dinesh Kumar Mahto (2025) regarding the statutory disqualification under Section 125(4).

The Court found the Family Court’s reasoning—that a lack of harmony or the husband’s devotion to his parents justified separate living—to be legally unsustainable and perverse.

The Court noted that in Indian ethos, a son has a moral and legal obligation to care for his parents.

Evidence showed the wife lodged a false 498-A IPC case (resulting in acquittal) and made scandalous accusations against the husband regarding his sister-in-law, which the Court deemed severe mental cruelty.

Consequently, the wife’s refusal to live with the husband lacked "sufficient reason" under Section 125(4) Cr.P.C.

The Court clarified that the wife's personal disqualification does not absolve the father of his liability to maintain his minor children.

The High Court partly allowed the revision, setting aside the maintenance of Rs. 10,000 for the wife and dismissing her application, but modified the order for the children, increasing their maintenance from Rs. 5,000 each to Rs. 7,500 each, totaling Rs. 15,000 per month, payable from the date of the application.