Maintenance to Wife & Children — S.144 BNSS / HMA — ASK Law Xperts
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Maintenance to Wife & Children भरण-पोषण — धारा 144 BNSS / धारा 125 CrPC / HMA धारा 24-25 / DV Act 2005

A complete guide to maintenance claims in India — under Section 144 BNSS (formerly S.125 CrPC) for wife, children and parents of all religions; Sections 24 & 25 of the Hindu Marriage Act for interim and permanent alimony; and Section 20 of the DV Act 2005. Covers who can claim, quantum determination, Rajnesh v. Neha (2021) comprehensive guidelines, Shah Bano (1985), and the latest 2025 SC ruling on maintenance in void marriages.

S.144 BNSS / S.125 CrPC HMA Sections 24-25 DV Act 2005 — S.20 All Religions Rajnesh v. Neha 2021 Shah Bano 1985

Bar Council of India Disclaimer: This page is for general informational purposes only and does not constitute legal advice. Maintenance quantum depends on specific facts. Always consult a qualified advocate before filing or defending a maintenance application.

Maintenance Framework — भरण-पोषण ढाँचा
Three Parallel Maintenance Laws in India
Three Maintenance Laws in India — BNSS S.144, HMA S.24-25, DV Act S.20 MAINTENANCE IN INDIA — THREE PARALLEL PROVISIONS S.144 BNSS / S.125 CrPC Who: Wife, children, parents All religions — secular Forum: Family Court / Magistrate Interim order within 60 days Quick remedy — criminal procedure HMA Sections 24 & 25 Who: Hindu spouses only S.24: Pendente lite (during proceedings) S.25: Permanent alimony post-decree Forum: Family Court 2025 SC: void marriages also covered DV Act 2005 — Section 20 Who: Aggrieved woman (all relations) Includes live-in relationships Monetary relief — broad scope Forum: Magistrate / Family Court All religions — urgent interim relief Key: All three provisions can run simultaneously — choose the forum based on urgency, religion, and stage of proceedings BNSS S.144 | HMA S.24-25 | DV Act S.20 | Rajnesh v. Neha 2021 | ASK Law Xperts — asklawxperts.com
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Maintenance in India — Legal Frameworkभरण-पोषण — कानूनी ढाँचा

Maintenance means monthly financial support paid by one spouse to the other (or by a parent to children, or children to parents) when they are not living together or after separation/divorce. In India, there are three separate laws for this: (1) Section 144 BNSS — for all religions, quick remedy before a Magistrate; (2) HMA Sections 24-25 — for Hindus, during and after matrimonial cases; (3) DV Act Section 20 — for women in any domestic relationship including live-in. All three can run simultaneously. The amount depends on the income of the person paying and the needs of the person claiming.
भरण-पोषण का मतलब है कि एक पक्ष दूसरे पक्ष को मासिक वित्तीय सहायता दे — जब वे साथ नहीं रहते या तलाक के बाद। भारत में तीन अलग-अलग कानून हैं: (1) धारा 144 BNSS — सभी धर्मों के लिए, मजिस्ट्रेट के सामने जल्दी राहत; (2) HMA धारा 24-25 — हिंदुओं के लिए, वैवाहिक मामलों के दौरान और बाद में; (3) DV Act धारा 20 — सभी महिलाओं के लिए, लिव-इन सहित। तीनों एक साथ चल सकते हैं। राशि का निर्धारण पक्षकारों की आय और आवश्यकताओं के आधार पर होता है।

Who Can Claim Maintenance?

Under S.144 BNSS (All Religions)
Wife — unable to maintain herself
Legitimate children — minor
Illegitimate children — minor
Major children with physical/mental disability
Parents — unable to maintain themselves
Under HMA S.24-25 (Hindus)
S.24: Either spouse — pendente lite — no independent income
S.25: Spouse without sufficient means — post-decree permanent alimony
2025 SC: S.25 available even in void marriages (2025 INSC 197)
DV Act S.20: Any aggrieved woman — domestic relationship incl. live-in

Old Position vs Current Lawपुराना कानून बनाम नया कानून

AspectEarlier PositionCurrent Position
Maintenance provisionSection 125 CrPC, 1973Section 144 BNSS, 2023 — in force from 1 July 2024. Same substance, new numbering.
Divorced Muslim wife — S.125 CrPCDisputed — some courts held S.125 not available to divorced Muslim wife after iddatShah Bano (1985 SC): S.125 applies to all persons regardless of religion. Daniel Latifi (2001): 1986 Muslim Women Act must be read to ensure adequate maintenance beyond iddat.
Maintenance in void marriage — HMA S.25Conflicting HC views — many denied S.25 to wife of void marriage2025 INSC 197 (SC 3-judge bench): S.25 maintenance available even in void marriages. S.24 interim also available.
Overlapping maintenance ordersCourts took inconsistent views on adjusting/deducting overlapping ordersRajnesh v. Neha (2021 SC): Comprehensive guidelines — overlapping orders to be adjusted; one consolidated order preferred; crediting amounts paid under one provision against another.
Affidavit of assetsNo uniform requirement — parties often suppressed incomeRajnesh v. Neha (2021): Mandatory affidavit of assets and income by both parties at the outset of maintenance proceedings.
Interim maintenance timelineNo statutory timeline — often delayed for yearsBNSS S.144 / Rajnesh guidelines: First maintenance order ideally within 60 days of notice; courts to expedite.

Filing a Maintenance Application — Step by Stepभरण-पोषण आवेदन — चरण-दर-चरण

1
Choose the Right Forum and Provision
Decide which provision to invoke: S.144 BNSS before the Family Court / Judicial Magistrate for a quick interim order applicable to all religions; HMA S.24 during pending HMA proceedings; DV Act S.20 if domestic violence is involved. All three can run simultaneously — choose based on urgency and facts. In Delhi — Family Courts at Rohini, Karkardooma, Tis Hazari, Saket, Dwarka handle maintenance.
2
Prepare Affidavit of Assets and Petition
As per Rajnesh v. Neha (2021) guidelines — both parties must file a comprehensive affidavit of assets, income, liabilities, and expenditure. The petition / application must state: relationship of parties, date of marriage, reasons for living separately, the claimant's income and expenses, the respondent's income and assets, and the amount of maintenance claimed. Attach all supporting documents.
3
Filing and Service of Notice
File the application in the Family Court / Magistrate's Court with the prescribed court fee. Court issues notice to the respondent. Respondent must file a reply. Under Rajnesh v. Neha guidelines — the court should ideally pass the first maintenance order within 60 days of notice. If respondent evades service — substituted service / publication may be ordered.
4
Interim Maintenance Application
File an urgent application for interim maintenance simultaneously with the main application. Under S.144 BNSS — the Magistrate has wide discretion to pass interim maintenance orders. Under HMA S.24 — the court may order interim maintenance and litigation expenses (vakalatnama fees and court expenses). The interim order operates until the final order is passed.
5
Evidence and Hearing
Both parties lead evidence — income documents (ITR, salary slips, bank statements), expense details, property and asset information. The court assesses the reasonable needs of the claimant and the paying capacity of the respondent. Lifestyle evidence is relevant — if the respondent lives well but claims low income, the court may infer suppression of income. Rajnesh guidelines: court may take judicial notice of high-standard lifestyle.
6
Maintenance Order and Enforcement
The court passes a maintenance order specifying the monthly amount, payable by a fixed date each month. If the respondent defaults — the claimant can file an execution application. Under S.144 BNSS — warrant of arrest can be issued for default; jail up to 1 month for non-payment. Rajnesh guidelines: uniform enforcement mechanism across all courts; courts to give effect to orders regardless of which forum passed them.

Documents Required

Claimant (Wife / Child / Parent):

💍Marriage certificate / proof of marriage
🪪Aadhaar Card — original + photocopies
📋Affidavit of assets and income (Rajnesh format)
💰Bank statements — last 6-12 months
📄Proof of expenses — rent, school fees, medical bills
📋Birth certificate of children (if claiming for children)
📝Evidence of respondent's income — salary slips, ITR, property
⚠️Evidence of cruelty / DV (if DV Act route)

Respondent (Person Paying):

💰Salary slips / ITR last 3 years
📄Bank statements — last 6-12 months
📋Affidavit of assets, income and liabilities
🏠Property / investment documents — for accurate asset disclosure

Limitation & Key Points

⏱ Key Points — Maintenance Law
Limitation — S.144 BNSS applicationNo fixed time limit
Interim order — target timeline (Rajnesh)Within 60 days of notice
Maintenance from date of applicationYes — courts may award from date of filing
HMA S.24 — pendente liteDuring pending matrimonial proceedings only
HMA S.25 — permanent alimonyAfter final decree — also in void marriages (2025 SC)
Muslim wife — S.144 BNSS applicabilityYes — Shah Bano 1985 + Daniel Latifi 2001
Default in payment — consequenceWarrant of arrest — up to 1 month jail
Modification of orderOn change of circumstances — either party can apply
DV Act S.20 — also available toWomen in live-in relationships

Relevant Statutes

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Bharatiya Nagarik Suraksha Sanhita, 2023 — Section 144
Replaces Section 125 CrPC from 1 July 2024. Secular provision — applicable to all persons regardless of religion. Covers maintenance of: wife unable to maintain herself; legitimate and illegitimate minor children; major children with physical or mental disability; parents unable to maintain themselves. Magistrate / Family Court jurisdiction. Order enforceable by warrant of arrest for default.
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Hindu Marriage Act, 1955 — Sections 24 & 25
S.24: Maintenance pendente lite — either spouse without sufficient independent income can claim during pending matrimonial proceedings. S.25: Permanent alimony — court may order gross sum or monthly amount at time of passing any decree under HMA. 2025 SC (2025 INSC 197): S.25 available even when marriage declared void under S.11 HMA. Modification: either party can apply to vary the S.25 order on change of circumstances.
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Protection of Women from Domestic Violence Act, 2005 — Section 20
Monetary relief to the aggrieved woman — covers loss of earnings, medical expenses, loss due to destruction of property, maintenance of the woman and her children. Available to women in domestic relationships — including live-in relationships. Can be claimed alongside other maintenance proceedings. Section 23: Magistrate may pass interim monetary relief order at any stage.
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Muslim Women (Protection of Rights on Divorce) Act, 1986
Enacted after Shah Bano controversy — was intended to restrict Muslim divorced women to iddat maintenance. However, SC in Daniel Latifi v. Union of India (2001) 7 SCC 740 interpreted the Act purposively — holding that the husband's obligation is to make provision for the entire future of the divorced woman, not just iddat period. Muslim Women (Protection of Rights on Marriage) Act 2019 also provides for maintenance to woman in talaq-ul-biddat cases.
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Hindu Adoptions and Maintenance Act, 1956
Sections 18-28: Maintenance of Hindu wife (S.18), maintenance of widowed daughter-in-law (S.19), maintenance of children and aged parents (S.20). These provisions are distinct from S.125 CrPC / S.144 BNSS — governed by civil law. The wife's right to separate residence and maintenance under S.18 HAMA is independent of matrimonial proceedings.
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Family Courts Act, 1984
Family Courts in Delhi have exclusive jurisdiction over maintenance matters. All applications under S.144 BNSS, HMA S.24-25, DV Act S.20, and HAMA S.18 should be filed in the Family Court having jurisdiction over the area where the claimant resides. Family Courts are expected to proceed expeditiously — in the spirit of Rajnesh v. Neha (2021) guidelines on timely disposal.

Landmark & Recent Judgments

Landmark — All Religions Mohd. Ahmed Khan v. Shah Bano Begum Supreme Court of India | AIR 1985 SC 945 | (1985) 2 SCC 556 | CJI Y.V. Chandrachud
The most debated maintenance judgment in Indian legal history. SC held that a divorced Muslim woman is entitled to maintenance under Section 125 CrPC — a secular provision applicable to all persons regardless of religion. The court held S.125 applies even if personal law provides differently — it is a measure to prevent destitution and vagrancy. Parliament thereafter passed the Muslim Women (Protection of Rights on Divorce) Act, 1986. However, SC in Daniel Latifi v. Union of India (2001) 7 SCC 740 held the 1986 Act must be interpreted to ensure adequate future maintenance — not just iddat period payment.
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Landmark — Comprehensive Guidelines Rajnesh v. Neha & Anr. Supreme Court of India | (2021) 2 SCC 324 | Decided: 04.11.2020 | Justices Indu Malhotra & R. Subhash Reddy
The most comprehensive SC judgment on maintenance procedure. Issued binding guidelines: (1) Mandatory affidavit of assets and income by both parties at the start of proceedings; (2) Overlapping maintenance orders to be adjusted — one consolidated order preferred; (3) First maintenance order should ideally be passed within 60 days of notice; (4) Uniform enforcement mechanism across all courts; (5) Maintenance from the date of application; (6) Modification on change of circumstances. These guidelines apply to all maintenance proceedings — S.125 CrPC/BNSS, HMA S.24-25, and DV Act S.20.
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Landmark — Quantum Determination Vinny Parmvir Parmar v. Parmvir Parmar Supreme Court of India | (2011) 13 SCC 112 | Decided: 2011
SC laid down factors for determining quantum of maintenance: (1) Status of the parties and their lifestyle; (2) Needs and requirements of the claimant; (3) Income and earning capacity of the respondent; (4) Obligations of the respondent towards dependants; (5) Standard of living enjoyed during marriage; (6) Whether respondent has concealed income. The court emphasised that maintenance should enable the claimant to maintain a standard of living similar to what they enjoyed during the marriage — not just a bare subsistence amount.
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Recent — 2025 SC Sukhdev Singh v. Sukhbir Kaur — Maintenance in Void Marriage Supreme Court of India | 2025 INSC 197 | Decided: 12.02.2025 | Justices A.S. Oka, Amanullah & A.G. Masih
3-judge bench settled the long-disputed question: Maintenance under Section 25 HMA can be granted even when the marriage is declared void under Section 11 HMA. Similarly, interim maintenance under Section 24 HMA is available during pendency of nullity proceedings — regardless of whether the marriage is void or voidable. The court held that the conduct of the party seeking relief is always relevant and the court exercises discretion. Overruled earlier conflicting HC decisions that had denied maintenance in void marriages.
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Landmark — Muslim Women Daniel Latifi v. Union of India Supreme Court of India | (2001) 7 SCC 740 | Constitution Bench | Decided: 28.09.2001
Constitution Bench upheld the Muslim Women (Protection of Rights on Divorce) Act, 1986 — but interpreted it purposively: held that the obligation to pay "maintenance" under the 1986 Act extends to the husband making provision for the entire future of the divorced wife — not merely iddat period maintenance. The amount must be sufficient to cover the reasonable wants and needs for the rest of the woman's life. This reading substantially restored the practical effect of Shah Bano and the S.125 CrPC right for Muslim divorced women.
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Landmark — Income Suppression Kalyan Dey Chowdhury v. Rita Dey Chowdhury Nee Nandy Supreme Court of India | (2017) 14 SCC 200 | Decided: 2017
SC held that courts should not accept a respondent's suppressed or understated income at face value. Where the respondent's lifestyle, assets, and expenditure pattern reveal a standard of living inconsistent with claimed income — the court may make a reasonable inference about actual income and compute maintenance accordingly. Directed that 25% of the husband's net salary is an appropriate starting benchmark for maintenance to wife — though this is not a rigid formula and depends on all circumstances of the case.
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Recent Developments

2024 — BNSS in Force
S.125 CrPC Replaced by S.144 BNSS
From 1 July 2024, the Bharatiya Nagarik Suraksha Sanhita 2023 replaced CrPC 1973. S.125 CrPC is now S.144 BNSS — same substance, new numbering. All pending S.125 cases continue under BNSS. Courts transitioned seamlessly.
2019 — Muslim Women
Triple Talaq Act — Maintenance Provision
Muslim Women (Protection of Rights on Marriage) Act 2019 — makes talaq-ul-biddat (instant triple talaq) void and criminalises it. Also provides for maintenance to the wife during the period she is separated. Complements the 1986 Act and Shah Bano / Daniel Latifi framework.

Frequently Asked Questions

Yes — the SC in Shah Bano Begum (1985) settled that Section 125 CrPC (now S.144 BNSS) is a secular provision applicable to all persons regardless of religion. A divorced Muslim woman unable to maintain herself can claim maintenance under S.144 BNSS. The Muslim Women (Protection of Rights on Divorce) Act 1986 was enacted in response, but Daniel Latifi (2001) held it must be read to provide adequate future maintenance, not just iddat period payment. Both routes are available.

The key factors are: (1) Income and earning capacity of the respondent — including hidden or suppressed income; (2) Needs and requirements of the claimant — rent, food, medical, education; (3) Standard of living during the marriage; (4) Assets and liabilities of both parties; (5) Number of dependants of the respondent; (6) Any independent income of the claimant. The SC in Kalyan Dey Chowdhury (2017) indicated 25% of husband's net salary as a starting benchmark — but this is not a rigid formula. Courts consider all facts.

Under S.144 BNSS — maintenance is typically awarded from the date of application, not from the date of the final order. Rajnesh v. Neha (2021) guidelines confirm that courts should award maintenance from the date of filing. Any arrears from the application date to the order date must be paid. Under HMA S.24 — pendente lite maintenance runs from the date of the application for S.24 relief. The court may, in its discretion, award maintenance from an earlier date in appropriate cases.

Yes — having some income does not automatically disentitle a wife to maintenance. The relevant question is whether her income is sufficient to maintain herself at the standard she enjoyed during the marriage. If there is a significant disparity in income between husband and wife — the court may award maintenance to bridge the gap. Under HMA S.24 — the standard is "no sufficient independent income" which is a relative concept. Under S.144 BNSS — the wife must be "unable to maintain herself" which courts interpret broadly.

If the respondent defaults in paying the maintenance ordered by the court — the claimant can file an execution application. Under S.144 BNSS — the Magistrate can issue a warrant of arrest for default; the defaulter can be sentenced to imprisonment up to 1 month. The warrant can be issued each time there is default. Rajnesh v. Neha guidelines: uniform enforcement mechanism across courts; courts must ensure execution of maintenance orders. Under civil provisions (HMA S.25) — civil execution — attachment of salary, property, or bank accounts.

Yes — under S.144 BNSS, maintenance of legitimate and illegitimate minor children is a separate ground from spousal maintenance. The parent having custody of the child (typically the mother) can claim maintenance from the other parent for the child's needs — education, medical, food, clothing. Under HMA — during matrimonial proceedings, S.24 includes litigation expenses and the court also deals with children's maintenance. The Guardian and Wards Act and Hindu Minority and Guardianship Act also have provisions for child maintenance. Major children with physical or mental disability can also claim maintenance.

Yes — Section 144 BNSS explicitly covers maintenance of parents unable to maintain themselves. Any person whose father or mother is unable to maintain themselves can be directed by the Magistrate to pay maintenance to the parent. Additionally, the Maintenance and Welfare of Parents and Senior Citizens Act, 2007 provides a faster, more accessible route — Maintenance Tribunals (typically the SDM in Delhi) can pass orders for maintenance of senior citizen parents / grandparents within 90 days. The amounts are modest but the process is simpler.

Yes — maintenance orders are not final forever. Either party can apply for modification on a change of circumstances. Examples of changed circumstances: the respondent's income has increased significantly (claimant can seek enhancement); the claimant has remarried (respondent can seek cancellation); the claimant has started earning substantially (respondent can seek reduction); medical needs of the claimant have changed. Under S.144 BNSS — the Magistrate can alter, modify or rescind the order on proof of change of circumstances. Under HMA S.25 — similarly, the court has power to vary.

Key differences: (1) S.144 BNSS — for all religions, criminal forum (Magistrate/Family Court), available independently without any matrimonial proceedings pending. HMA S.24 — only during pending HMA proceedings (divorce, nullity, restitution etc.); S.25 — only after a decree is passed. (2) S.144 BNSS is a criminal proceeding — default leads to arrest. HMA is civil — default leads to civil execution. (3) S.144 BNSS covers wife, children, and parents. HMA covers only spouses. (4) Both can run simultaneously — but amounts must be adjusted per Rajnesh guidelines.

Yes — as per the Supreme Court's binding guidelines in Rajnesh v. Neha (2021) 2 SCC 324 — both parties in maintenance proceedings are required to file a comprehensive affidavit of assets, income, and liabilities at the commencement of the proceedings. The format prescribed in the judgment should be used. Filing a false affidavit amounts to contempt of court and perjury. Courts take note of discrepancies between the lifestyle/assets and the declared income — and may infer suppressed income to determine quantum of maintenance.

Test Your Knowledge — Maintenance Law Quiz

⚖️ Maintenance to Wife & Children — 10 Questions

Key Legal Terms

Section 144 BNSS
Secular maintenance provision in BNSS 2023 (replaces S.125 CrPC from 1 July 2024). Covers wife, children (legitimate + illegitimate), and parents. All religions. Magistrate/Family Court jurisdiction. Default: arrest up to 1 month.
HMA Section 24
Pendente lite maintenance — interim maintenance to either spouse without sufficient independent income, during pending matrimonial proceedings under the Hindu Marriage Act. Also covers litigation expenses (vakalatnama fee, court expenses).
HMA Section 25
Permanent alimony and maintenance — at time of passing any decree under HMA or later. Available even in void marriages (2025 INSC 197). Court may award gross lump sum or monthly maintenance. Subject to modification on change of circumstances.
DV Act Section 20
Monetary relief under Protection of Women from Domestic Violence Act 2005 — covers maintenance, loss of earnings, medical expenses. Available to all women in domestic relationships including live-in. Magistrate may pass interim order under S.23 DV Act at any stage.
Rajnesh v. Neha (2021)
Landmark SC judgment issuing comprehensive guidelines on maintenance — mandatory asset affidavit, 60-day interim order, overlapping orders adjustment, enforcement. Binding on all Family Courts across India.
Pendente Lite
Latin: "during litigation." Pendente lite maintenance is interim maintenance paid during the pendency of matrimonial proceedings — before the final decree. Governed by HMA S.24 for Hindus. Ensures the dependent spouse is not left without means while the case is pending.
Quantum of Maintenance
The amount of monthly maintenance ordered by the court. Determined based on: respondent's income, claimant's needs, standard of living during marriage, assets of both parties, number of dependants. No fixed formula — courts exercise discretion.
Affidavit of Assets
Mandatory disclosure document required by both parties in maintenance proceedings (Rajnesh v. Neha 2021). Contains details of income, salary, business income, property, investments, liabilities, and monthly expenses. Filing a false affidavit constitutes perjury and contempt.

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