Tuesday, 30 November 2021

Whether court can impose an imprisonment for more than one month U/S 125(3) of CRPC?

The question which arises for determination before this

Court is as to whether a Court can in exercise of its powers under Section 125(3) Cr.P.C. impose composite civil imprisonment in case of default in payment of maintenance arrears/allowances, for a period of more than one month, in a single stroke.

The relevant provisions of Section 125(3) Cr.P.C. are

extracted as under:-

“125(3). If any person so ordered fails without

sufficient cause to comply with the order, any such

Magistrate may, for every breach of the order, issue a

warrant for levying the amount due in the manner

provided for levying fines, and may sentence such person,

for the whole or any part of each month' s allowances

remaining unpaid after the execution of the warrant, to

imprisonment for a term which may extend to one month

or until payment if sooner made: Provided that no warrant

shall be issued for the recovery of any amount due under

this section unless application be made to the Court to levy

such amount within a period of one year from the date on

which it became due: Provided further that if such person

offers to maintain his wife on condition of her living with

him, and she refuses to live with him, such Magistrate may

consider any grounds of refusal stated by her, and may

make an order under this section notwithstanding such

offer, if he is satisfied that there is just ground for so

doing.

Explanation.- If a husband has contracted marriage with

another woman or keeps a mistress, it shall be considered

to be just ground for his wife' s refusal to live with him.”

A perusal of the aforementioned leaves no manner of doubt

that for breach of payment of maintenance for each month, the Court can impose a maximum sentence of one month only, unless of course, if the payment of the arrears is made sooner. In Shahada Khatoon's case (Supra), the Supreme Court while dealing with a similar question held in no uncertain terms that the powers of the Magistrate are restricted and no sentence exceeding the maximum i.e. one month, can be imposed for default, and if at all the default persists even after the

expiry of one month the only remedy available to the aggrieved party would be to approach the Magistrate concerned again after the expiry of one month for enforcing her claim of maintenance for sending the delinquent husband to civil imprisonment. Therefore, what flows from Shahada Khatoon's case (supra) is that the defaulter can under no circumstances be ordered to undergo composite civil imprisonment for a period beyond one month irrespective of the fact that the arrears etc.

claimed in a single application by the aggrieved party may be for more than one month.

 IN THE HIGH COURT OF PUNJAB & HARYANA

AT CHANDIGARH


CRR-1218-2021 (O&M)

Date of decision: 12.11.2021

Bal Raj  Vs Priya 

CORAM: MRS. JUSTICE MANJARI NEHRU KAUL



The instant revision petition has been filed to assail the

order dated 16.03.2020 passed by the Family Court, Jagadhri in an

application moved under Section 125(3) Cr.P.C. vide which the

petitioner was ordered to undergo a composite sentence of civil

imprisonment for a period of twelve months for default of payment of

maintenance allowance of 66 months (w.e.f. 27.05.2014 to 27.02.2020),

amounting to Rs.2,74,000/-.

Learned counsel for the petitioner has vehemently urged

that the Family Court gravely erred while passing the impugned order

without appreciating that for default of payment of arrears, no

composite sentence could have been ordered. In support, he placed

reliance upon the judgment of Supreme Court in Shahada Khatoon

and others Vs. Amjad Ali and others : (1999) 5 SCC 672. It was also

submitted that respondents No.1 to 3 were not even his wife and

children. Besides, they were already getting widow and destitute


children pension from the Government of Haryana. It was submitted

that soon after the passing of the impugned order the petitioner was

sentenced to civil imprisonment on 16.03.2020. On account of the

outbreak of the pandemic, he was released on parole but subsequently

he was directed by the jail authorities to surrender back, which he did

on 10.10.2021. Ever since then he was confined in the District Prison at

Yamuna Nagar.

On being put to notice Mr. Munish, Mittal, Advocate has

put in appearance and opposed the prayer and submissions made by the

counsel opposite.

Heard learned counsel for the parties and perused the

material on record.

The question which arises for determination before this

Court is as to whether a Court can in exercise of its powers under

Section 125(3) Cr.P.C. impose composite civil imprisonment in case of

default in payment of maintenance arrears/allowances, for a period of

more than one month, in a single stroke.

The relevant provisions of Section 125(3) Cr.P.C. are

extracted as under:-

“125(3). If any person so ordered fails without

sufficient cause to comply with the order, any such

Magistrate may, for every breach of the order, issue a

warrant for levying the amount due in the manner

provided for levying fines, and may sentence such person,

for the whole or any part of each month' s allowances

remaining unpaid after the execution of the warrant, to

imprisonment for a term which may extend to one month


or until payment if sooner made: Provided that no warrant

shall be issued for the recovery of any amount due under

this section unless application be made to the Court to levy

such amount within a period of one year from the date on

which it became due: Provided further that if such person

offers to maintain his wife on condition of her living with

him, and she refuses to live with him, such Magistrate may

consider any grounds of refusal stated by her, and may

make an order under this section notwithstanding such

offer, if he is satisfied that there is just ground for so

doing.

Explanation.- If a husband has contracted marriage with

another woman or keeps a mistress, it shall be considered

to be just ground for his wife' s refusal to live with him.”

A perusal of the aforementioned leaves no manner of doubt

that for breach of payment of maintenance for each month, the Court

can impose a maximum sentence of one month only, unless of course, if

the payment of the arrears is made sooner. In Shahada Khatoon's case

(Supra), the Supreme Court while dealing with a similar question held

in no uncertain terms that the powers of the Magistrate are restricted

and no sentence exceeding the maximum i.e. one month, can be

imposed for default, and if at all the default persists even after the

expiry of one month the only remedy available to the aggrieved party

would be to approach the Magistrate concerned again after the expiry of

one month for enforcing her claim of maintenance for sending the

delinquent husband to civil imprisonment. Therefore, what flows from

Shahada Khatoon's case (supra) is that the defaulter can under no

circumstances be ordered to undergo composite civil imprisonment for


a period beyond one month irrespective of the fact that the arrears etc.

claimed in a single application by the aggrieved party may be for more

than one month.

As a sequel to the above, the impugned order dated

16.03.2020 is set aside being wholly unsustainable and against the

settled law. The petitioner shall be forthwith set at liberty, if not

required in any other case.

Before parting with this order, liberty is granted to the

respondents to file a fresh application, if they so wish, asserting noncompliance

of the order passed under Section 125 Cr.P.C.

12.11.2021 (MANJARI NEHRU KAUL)


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