Saturday, 25 January 2025

Kerala HC: Muslim Wife Residing Separately From Husband On His Contracting Second Marriage Can Claim Maintenance Under CrPC /BNSS

 The Muslim Personal Law, though, permits the husband to contract a second marriage during the subsistence of the first marriage in exceptional circumstances, specifically mandates that the husband is bound to treat both wives equally and equitably. A Muslim wife who resides separately from her husband on his contracting a second marriage is not disentitled from claiming her statutory right of maintenance under CrPC/BNSS [See Badruddin v Aisha Begum (1957) All. LJ. 300]. The fact that the husband has a second wife and is liable to maintain her cannot be a factor in denying maintenance to the first wife or reducing the quantum of maintenance she is entitled to.

IN THE HIGH COURT OF KERALA AT ERNAKULAM

RPFC NO. 334 OF 2022

 HASEENA  Vs  SUHAIB

PRESENT

 DR. JUSTICE KAUSER EDAPPAGATH

Dated:  15TH DAY OF JANUARY 2025

Citation: 2025:KER:2953.

This revision petition has been filed challenging the order

passed in M.C.No.98/2015 on the files of the Family Court, Tirur

dated 25.8.2022.

2. The 1st petitioner is the wife of the respondent.

Petitioners 2 and 3 are the children of the 1st petitioner, born in

wedlock with the respondent. The petitioners filed a

maintenance case against the respondent under Section 125 of

Cr.P.C claiming maintenance at the rate of ₹10,000/- to the 1st

petitioner, ₹8,000/- to the 2nd petitioner and ₹6,000/- to the 3rd

petitioner. The Family Court, after trial, granted monthly

maintenance at the rate of ₹4,000/- to the 1st petitioner and

₹1,500/- each to the petitioners 2 and 3. Dissatisfied with the

quantum of maintenance granted, the petitioners have

approached this Court.

3. I have heard Sri Jamsheed Hafiz, the learned counsel

for the petitioners. Even though notice has been served on the

respondent, there is no appearance.

4. The marital relationship and paternity are not in

dispute. Admittedly, the 1st petitioner does not have any job or

source of income. According to the petitioners, the respondent is

working abroad in a supermarket and earns more than

₹1,00,000/- per month. It is also alleged that the respondent

earns ₹25,000/- per month from the landed property. The

respondent has admitted that he was employed in Gulf.

However, he has taken a contention that he has returned from

Gulf and now working as an employee in a bakery in Madras.

According to him, he is only getting ₹8,000/- per month. He has

also contended that he is suffering from various ailments and has

to maintain his second wife.

5. As stated already, the definite case of the petitioners

is that the respondent is employed at Gulf and earns ₹1,00,000/-

per month. The respondent has admitted that he was employed

at Gulf, but, according to him, he has returned from Gulf and

now working as an employee in a bakery in Madras. However,

absolutely no piece of evidence has been produced by the

respondent to prove where he works now and what his income is,

which is a fact within his exclusive knowledge. Even though the

respondent has taken up a contention that he is suffering from

various ailments, no document has been produced to prove the

same. An able-bodied husband must be presumed to be capable

of earning sufficient money to maintain his wife and children and

cannot contend that he is not in a position to earn sufficiently to

maintain his family. The onus is on the husband to establish with

necessary material that there are sufficient grounds to show that

he is unable to maintain the family and discharge his legal

obligations for reasons beyond his control. If the husband does

not disclose the exact amount of his income, an adverse

inference may be drawn by the Court [Rajnesh v Neha &

Another (2021)2 SCC 324].

6. The respondent is aged 40 years. He has no case

that he has any incapacity to earn. Nothing has been produced

to show his physical inability, if any. Since the respondent has

failed to produce any material to prove his present employment

and income, the adverse inference has to be drawn against him.

The petitioner has given positive evidence that the respondent is

earning ₹1,25,000/- per month.

7. The respondent has taken yet another contention

that the 1st petitioner left his company, refused to live with him

without any sufficient reason and hence not entitled to

maintenance. It is also contended that with the meagre income

he gets from his present job, he has to maintain his second wife

as well. The Muslim Personal Law, though, permits the husband

to contract a second marriage during the subsistence of the first

marriage in exceptional circumstances, specifically mandates that

the husband is bound to treat both wives equally and equitably. A

Muslim wife who resides separately from her husband on his

contracting a second marriage is not disentitled from claiming

her statutory right of maintenance under CrPC/BNSS [See

Badruddin v Aisha Begum (1957) All. LJ. 300]. The fact that

the husband has a second wife and is liable to maintain her

cannot be a factor in denying maintenance to the first wife or

reducing the quantum of maintenance she is entitled to.

Considering the entire facts and circumstances of the case,

the means of the respondent and the requirement of the

petitioners, I am of the view that monthly maintenance granted

by the Family Court is too low. Hence, the monthly maintenance

granted by the Family Court is enhanced to ₹8,000/- to the 1st

petitioner and ₹3,000/- each to the petitioners 2 and 3. The

revision petition is allowed as above.


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