Marriage certificate and admitted signatures establish marital status for maintenance despite unsubstantiated claims of fraud or intoxication.

The respondent (wife) filed an application for maintenance under Section 144 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), claiming she was driven out of the matrimonial home following her marriage to the applicant on April 24, 2022.

The applicant (husband) denied the marriage, contending he was intoxicated and coerced into signing documents at Arya Samaj, Raipur, and noted the pendency of a civil suit for a declaration that no marriage exists.

On February 10, 2026, the Family Court, Balod, partly allowed the respondent's application, directing the applicant to pay ₹8,000 per month as maintenance.

The applicant challenged this order via criminal revision before the High Court of Chhattisgarh.

1. Whether the Family Court erred in granting maintenance despite the applicant's challenge to the validity of the marriage and the pendency of a civil suit.

2. Whether the quantum of maintenance awarded (₹8,000) was justified based on the financial status and earning capacity of the parties.

The Court primarily applied Section 144 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), which corresponds to Section 125 of the Code of Criminal Procedure (CrPC), regarding the maintenance of wives, children, and parents.

The court relied on the principle that the presence of a marriage certificate and admitted signatures creates a presumption of a valid marriage for the purpose of summary maintenance proceedings.

It further applied the doctrine that an "able-bodied" person with sufficient means (such as agricultural land) is legally obligated to maintain a spouse who is unable to maintain themselves.

The Court evaluated the applicant's claim of fraud and intoxication and found it unsubstantiated by cogent evidence, noting that the applicant failed to lodge any timely complaints or legal challenges against the marriage registration.

The Court observed that the marriage was supported by a certificate from Arya Samaj and the applicant's admitted signatures.

Applying the facts to the statutory requirements for maintenance, the Court found that the respondent demonstrated a reasonable cause for separate residence due to cruelty and neglect.

Regarding financial capacity, the Court determined that the applicant possessed agricultural land and other income sources, while the respondent lacked independent means, thereby justifying the Family Court's assessment of the applicant's neglect despite having sufficient means.

The Court affirmed that ₹8,000 per month was a reasonable amount and not excessive given the applicant's status.

Consequently, the criminal revision was dismissed for being devoid of merit.