Revisional courts shall not interfere with maintenance awards absent clear perversity or legal irregularity.

The applicant (wife) and the non-applicant (husband) solemnized their marriage on May 15, 2024, following a prior love affair and a criminal report lodged by the applicant under Sections 376 and 506 of the IPC

Following the marriage and the non-applicant’s release on bail, the applicant alleged she was subjected to physical and mental harassment by the non-applicant and his family, leading her to reside at her parental home

In March 2025, the applicant filed for maintenance under Section 144 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS)

The Additional Principal Judge, Family Court, Janjgir, partly allowed the application on November 22, 2025, directing the non-applicant to pay ₹3,000 per month

The applicant preferred this criminal revision seeking enhancement of the maintenance amount, asserting the non-applicant earns approximately ₹28,000 per month as a Guest Teacher

1. Whether the maintenance amount of ₹3,000 per month awarded by the Family Court is inadequate and warrants enhancement under revisional jurisdiction.

2. Whether the Family Court’s order suffered from illegality, irregularity, or perversity in its appreciation of the evidence regarding the non-applicant’s income and liabilities.

The court primarily applied Section 144 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS), which governs the grant of maintenance to wives, children, and parents

It further relied on the principles governing revisional jurisdiction, which restrict interference to cases involving manifest illegality, irregularity, or perversity in the lower court's findings

The High Court observed that the Family Court had passed a "reasoned and speaking order" after duly considering the material evidence, the testimony of both parties, and the specific financial income and liabilities of the non-applicant

Although the applicant contended that the non-applicant’s income as a Guest Teacher justified a higher award, the Court found that the Family Court had properly assessed the facts and circumstances

The Court emphasized that in exercise of its revisional jurisdiction, it would not substitute its own view for that of the trial court unless the findings were arbitrary or failed to appreciate the evidence

The Court concluded that the awarded amount of ₹3,000 per month was not so grossly inadequate as to necessitate judicial interference

The Court found the revision to be devoid of merit and dismissed the application for enhancement of maintenance

The order of the Additional Principal Judge, Family Court, Janjgir, was upheld