Maintenance Defined

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MAINTENANCE

Maintenance defined

Maintenance includes — (i) in all cases, provisions for food, clothing, residence, education and
medical attendance and treatment; (ii) in the case of an unmarried daughter also the reasonable
expenses of and incident to her marriage, Section 3(b), Hindu Adoption and Maintenance Act,
1956.

Maintenance necessarily must encompass a provision for residence. Maintenance is given so that
the lady can live in the manner, more or less, to which she was accustomed. The concept of
maintenance must, therefore, include provision for food and clothing and the like and take into
account the basic need of a roof over the head, Mangat Mal v. Punni Devi, (1995) 6 SCC 88.

Sustenance defined

Maintenance of wife for her ‘sustenance’ does not mean animal existence but signifies leading
life in a similar manner as she would have lived in the house of her husband. Husband is duty
bound to enable his wife to live life with dignity according to their social status and
strata, Bhuwan Mohan Singh v. Meena, (2015) 6 SCC 353.

Temporary Maintenance (pendente lite)

Temporary maintenance is granted by the court during the pendency of proceeding for divorce or
separation to meet the immediate needs of the petitioner.

Under Section 24 of Hindu Marriage Act, 1955 either of the spouses, husband or wife can be
granted relief if the court is satisfied that the applicant has no independent income sufficient for
his or her support and necessary expenses of the proceedings pending under the Act.

Interim maintenance may also be claimed under Section 125 CrPC by the wife during the
pendency of proceeding for regarding monthly allowance for maintenance under Section 125(1)
CrPC.

Furthermore, Section 36 of Special Marriage Act, 1954 also makes provision for the wife to seek
expenses from the husband if it appears to the district court that she does not have independent
income sufficient for her support and necessary expenses of proceedings under Chapters V or VI
of that Act.

Permanent Maintenance

It is the maintenance granted permanently after the disposal of the proceeding for divorce or
separation.

Hindu Marriage Act, 1955, Section 25 – Applicant, either wife or husband is entitled to receive
from the spouse for his/her maintenance and support a gross sum or monthly or periodical sum
for a term not exceeding the applicant’s lifetime or until he/she remarries or remains chaste.

Hindu Adoption and Maintenance Act, 1956, Section 18 – Hindu wife is entitled to be
maintained by her husband during her lifetime. Wife also has a right to separate residence and
maintenance if any of the condition in Section 18(2) [desertion, cruelty, leprosy, any other wife/
concubine living in the same house, conversion of religion or any other reasonable cause] is
fulfilled until she remains chaste or does not convert to other religion. It may also be noted
that Section 19 of this Act makes a provision for a widowed wife to be maintained by her father-
in-law.

Criminal Procedure Code, 1973, Section 125 – This section provides for maintenance not only
to the wife but also to child and parents. Court may order a husband who has sufficient means
but neglects or refuses to maintain his wife who is unable to maintain herself to provide monthly
maintenance to her. However, wife shall not be entitled to receive maintenance if she is living in
adultery, or refuses to live with husband without any sufficient reasons, or living separately with
mutual consent.

Muslim Women (Protection of Rights on Divorce) Act, 1986, Section 3 – A divorced Muslim
woman is entitled to a reasonable and fair provision and maintenance to be paid to her within the
iddat period by her former husband; an amount equal to the sum of mahr or dower agreed to be
paid to her at the time of her marriage or at any time thereafter according to Muslim law; and all
the properties given to her before or at the time of marriage or after her marriage by her relatives
or friends or the husband or any relatives of the husband or his friends. If husband fails to
provide her the above mentioned then Magistrate can order for payment of the same.
Special Marriage Act, 1954, Section 37 – This section is also similar to Section 40 of the Parsi
Marriage and Divorce Act. The difference being that under this section maintenance may be
claimed only by a wife against the husband from a court exercising jurisdiction under Chapters V
or VI of the Act. An order made under this section may be modified or rescinded by the district
court at the instance of the husband if it is shown that the wife has remarried or is not leading a
chaste life.

Wife defined

“Wife” Includes a woman who has been divorced by or has obtained a divorce from, her husband
and has not remarried, Section 125(1) Explanation (b), CrPC 1973.

“Wife” in Section 125 CrPC means a legally wedded wife and also includes a divorced wife, D.
Velusamy v. D. Patchaiammal, (2010) 10 SCC 469.

Maintenance only to legally wedded wife

Only a legally wedded wife is entitled to maintenance. A Hindu woman marrying a Hindu male
having a living wife, is not entitled to maintenance as this marriage is void, Yamunabai Anantrao
Adhav v. Anantrao Shivram Adhav, (1988) 1 SCC 530.

Wife ‘living separately with mutual consent’ does not include divorced wife

The meaning of ‘wife’ under Sections 125(1) and 125(4) CrPC is different. Section 125(4)
contemplates a married woman. Wife living separately from husband with mutual consent does
not mean wife who obtains divorce by mutual consent and lives separately and therefore cannot
be denied maintenance on this ground, Vanamala v. H.M. Ranganatha Bhatta, (1995) 5 SCC
299.

Is an earning wife entitled to maintenance?

Wife having a school of her own and possessing wet lands is in a better financial position than
husband who is not doing well in his profession and has no land. Hence, it is unnecessary to pay
any maintenance to the wife, Rosy Jacob v. Jacob A. Chakramakkal, (1973) 1 SCC 840.
Wife’s income to be accounted for determining maintenance

Wife’s income has to be taken into account while determining the amount of maintenance
payable to her. It is not an absolute right of a neglected wife to get maintenance nor it is an
absolute liability of husband to support her in all the circumstances, Bhagwan Dutt v. Kamla
Devi, (1975) 2 SCC 386.

Maintenance to woman in a live-in relationship

The Supreme Court expressed its opinion that a broad interpretation of “wife” should include
cases where man and woman live together as husband and wife for a reasonably long period of
time (live-in relationship/ presumed marriage/ de facto marriage/ cohabitation). A strict proof of
marriage should not be a precondition for maintenance under S. 125 CrPC so as to fulfill the true
spirit and essence of the beneficial provision of maintenance.

Recently, it is held that a woman in a live-in relationship has an efficacious remedy to seek
maintenance under Protection of Women from Domestic Violence Act, 2005 even if it is
assumed that she is not entitled to the same under Section 125 CrPC. In fact, under the Domestic
Violence Act, the victim would be entitled to more relief than what is contemplated under
Section 125 CrPC, Lalita Toppo v. State of Jharkhand, 2018 SCC OnLine SC 2301.

Woman knowingly entering in a live-in relationship with a married man

All live-in relationships are not relationships in the nature of marriage. There has to be some
inherent/ essential characteristic of marriage though not a marriage legally recognised. A live-in
relationship between an unmarried woman knowingly entering into relationship with a married
male cannot be termed as a relationship in the “nature of marriage” and her status would be that
of a concubine or mistress and therefore is not entitled to maintenance, Indra Sarma v. V.K.V
Sarma, (2013) 15 SCC 755.
Provisions under the Hindu Marriage Act, 1955:

Section 24 and Section 25 of the Hindu Marriage Act, 1955 act deals with the provisions of
allowing pendente lite and permanent maintenance respectively.

Section 24 Maintenance pendente lite and expenses of proceedings: —Where in any proceeding
under this Act it appears to the court that either the wife or the husband, as the case may be, has
no independent income sufficient for her or his support and the necessary expenses of the
proceeding, it may, on the application of the wife or the husband, order the respondent to pay to
the petitioner the expenses of the proceeding, and monthly during the proceeding such sum as,
having regard to the petitioner's own income and the income of the respondent, it may seem to
the court to be reasonable: [Provided that the application for the payment of the expenses of the
proceeding and such monthly sum during the proceeding, shall, as far as possible, be disposed of
within sixty days from the date of service of notice on the wife or the husband, as the case may
be.]

Section 25 Permanent alimony and maintenance:

(1) Any court exercising jurisdiction under this Act may, at the time of passing any decree or at
any time subsequent thereto, on application made to it for the purpose by either the wife or the
husband, as the case may be, order that the respondent shall pay to the applicant for her or his
maintenance and support such gross sum or such monthly or periodical sum for a term not
exceeding the life of the applicant as, having regard to the respondent's own income and other
property, if any, the income and other property of the applicant [, the conduct of the parties and
other circumstances of the case], it may seem to the court to be just, and any such payment may
be secured, if necessary, by a charge on the immovable property of the respondent.

(2) If the court is satisfied that there is a change in the circumstances of either party at any time
after it has made an order under sub-section (1), it may at the instance of either party, vary,
modify or rescind any such order in such manner as the court may deem just.

(3) If the court is satisfied that the party in whose favour an order has been made under this
section has re-married or, if such party is the wife, that she has not remained chaste, or, if such
party is the husband, that he has had sexual intercourse with any woman outside wedlock, [it
may at the instance of the other party vary, modify or rescind any such order in such manner as
the court may deem just].

In Dr. Kulbhushan v/s Raj Kumari and Anr 1971 AIR 234, the court while deciding the
amount of maintenance observed that it is determined based on the facts of each case and
declared that if the court enhances or moulds the amount of maintenance, then such a decision
would be justified. It was further held in this case that it would be fair to provide wife with 25%
of husband’s net salary as maintenance.

 Under Section 24 of the act if the court considers fit and is satisfied that either wife or
husband does not have an independent income, then it can order the respondent to pay the
maintenance to the petitioner in accordance with the provisions of this Section. Thus, the
claimant can be a husband as well.

 Further, according to the provisions of Section 25 of the Act, which deals with the
granting of alimony on a permanent basis, the court may on the application made by the
respondent, order to provide for maintenance either in the form of periodical payments or
a gross sum to be provided. Thus, in this case as well the respondent can either be a wife
or a husband.

 The purpose of interpreting the provision in this way is to avoid the discrimination
because both husband and wife are equal in the eyes of law.

Delhi High Court in the case of Rani Sethi v/s Sunil Sethi, Delhi High Court,
2011 ordered wife (respondent) to pay maintenance to her husband (petitioner) of Rs 20,000
and Rs.10,000 as litigation expenses. Further a Zen car was ordered to be given for the use of the
petitioner.

 Wife on being aggrieved by the same order approached the High Court, where the scope
of Section 24 of HMA was construed and it was held that the purpose of this Section to
provide support to the spouse who is incapable of earning his/her independent income.

 Further it was held that the term “support” shall not be construed in a narrow sense and
thus, it includes not only bare subsistence. It aims to provide a similar status as that of the
respondent spouse.
Thus, considering all the facts and circumstances, the appeal of wife was dismissed.

 Though Section of the above said Act provides sufficient right to both husband and wife
to move an application before the court for seeking maintenance, if they do not have an
independent source of income and have been solely dependant upon his/her spouse. But
this Section cannot be invoked in such a manner as to where husband though capable of
earning does not continue to do so intentionally for the sole purpose of depending on his
wife. In such a case husband cannot move an application for seeking maintenance. This
was held by the Madhya Pradesh High Court in the case of Yashpal Singh Thakur vs
Smt. Anjana Rajput, AIR 2001 MP 67 where husband incapacitated himself by
stopping to run an auto rickshaw. Hence, where a person intentionally incapacitates
himself he loses the opportunity to file an application for seeking maintenance.

Section 26 of The Hindu Marriage Act, 1955 act deals with the custody, maintenance and
education of minor children. Court may, as it considers necessary and deems fit, from time to
time pass interim orders in this regard and at the same time has the power to revoke, suspend or
vary such an order. Obligation to maintain lies on both father and mother of the child or on either
of the parents as ordered by the court.

Maintenance under Section 125 Cr.P.C

According to this Section magistrate of first class has the power to order the person to provide
monthly allowance to:

 His parents,

 Wife, or

 To his legitimate or illegitimate minor children who are unable to maintain themselves

 Legitimate or illegitimate major child not being a married daughter, who are unable to
maintain themselves due to any physical injury or abnormality

 Married daughter till she attains her majority if her husband is unable to maintain her
 His or her father or mother if they are unable to maintain themselves, whoever neglects or
refuses to do so.

Magistrate may issue warrants for levying the amount due, in case of non-compliance with the
order. Making of an application is mandatory to the court for levying such amount within a
period of one year from the date on which the amount was due, otherwise warrant cannot be
issued. Where in case a wife is living separately without any sufficient reason or is living in
adultery or they have separated through a mutual consent, then in such cases she is not entitled to
receive allowance.

Distinction between Section 18 of the Hindu Adoption and Maintenance Act and Section 25
of the Hindu Marriage Act and Section 125 of the Code of Criminal Procedure:

(a). Under Section 18 of the Hindu Adoption arid Maintenance Act and Section 125 of the Code
of Criminal Procedure only wife can claim maintenance, while under Section 25 of the Hindu
Marriage Act either spouse can do so.

(b). Under Section 18 of the Hindu Adoption and Maintenance Act and Section 125 of the Code
of Criminal Procedure, a wife can claim maintenance and live separately from her husband while
her marriage subsists. Under Section 25 of the Hindu Marriage Act, either spouse can claim
maintenance and permanent alimony but that can be done only after judicial separation or after
divorce. When the marriage is subsisting there is no question of applicability of Section 25,
Hindu Marriage Act but Section 18, Hindu Adoption and Maintenance Act. The word "wife"
does not have the same meaning in the two enactments.

(c). Hindu wife contemplated under Section 18 of the Hindu Adoption and Maintenance Act and
Section 125 of the Code of Criminal Procedure includes only the wife of a valid marriage. While
under Section 25 of the Hindu Marriage Act even a wife of void marriage can claim
maintenance. (d). Apparently Section 18 of the Hindu Adoption and Maintenance Act seems to
have overridden Section 25, Hindu Marriage Act because in both the sections a similar provision
exists and by virtue of Section 4, Hindu Adoption and Maintenance Act, it is the Act of 1956 (i.e.
HAMA) which shall prevail and the provisions of the Act of 1955 (i.e. HMA) vis-a-vis
maintenance of a wife shall cease to have any effect.
Provisions under the Hindu Adoptions and Maintenance Act, 1956:

The Hindu husband is under a duty to maintain his wife during life time. Maintenance is a
personal/legal obligation. It is an incident of the status or estate or matrimony. The meaning of
the term 'maintenance' is given in Section 3 (b) of the Act "maintenance" includes (i) in all cases,
provision for food, clothing, residing, education, and medical treatment and (ii) in case of an
unmarried daughter, also the reasonable expenses of an incident to her marriage.

Section 18: Maintenance of wife

(1) Subject to the provisions of this section, a Hindu wife, whether married before or after the
commencement of this Act, shall be entitled to he maintained by her husband during her life
time.

Section 18 (1) is applicable when the wife lives with her husband. A wife who has ceased to be
Hindu cannot claim maintenance.

(2) A Hindu wife shall be entitled to live separately from her husband without forfeiting her
claim to maintenance.

a) If he is guilty of desertion or of willfully neglecting her.

b) If he has treated her with such cruelty as to cause a reasonable apprehension in her mind that it
will be harmful or injurious to live with her husband.

c) If he is suffering from a virulent form of leprosy.

d) If he has any other wife living.

e) If he keeps a concubine in the same house in which his wife is living or habitually resides with
a concubine elsewhere.

f) If he has ceased to be a Hindu by conversion to another religion.

g) If there is any other cause justifying living separately.


(3) (Forfeiture of the claim of maintenance). A Hindu wife shall not be entitled to separate
residence and maintenance from her husband if she is unchaste or ceases to be a Hindu by
conversion to another religion.

Maintenance of widowed daughter-in-law

Section 19 of the Hindu Adoption and Maintenance Act provides that after the death of her
husband, a Hindu wife is entitled to be maintained by her father-in-law, if she has no means of
her own earnings or other property or estate of her husband/ father/ mother or from her son or
daughter or his/her estate. However, this right cannot be enforced if the father-in-law does not
have the means to do so from any coparcenary property in his possession out of which the
daughter-in-law has not obtained any share. Further, his obligation ceases when the daughter-in-
law remarries.

Section 20 in the Hindu Adoptions and Maintenance Act, 1956

20. Maintenance of children and aged parents.—

(1) Subject to the provisions of this section a Hindu is bound, during his or her lifetime, to
maintain his or her legitimate or illegitimate children and his or her aged or infirm parents.

(2) A legitimate or illegitimate child may claim maintenance from his or her father or mother so
long as the child is a minor.

(3) The obligation of a person to maintain his or her aged or infirm parent or a daughter who is
unmarried extends in so far as the parent or the unmarried daughter, as the case may be, is unable
to maintain himself or herself out of his or her own earnings or other property. Explanation.—In
this section “parent” includes a childless step-mother.

Amount of Maintenance: Court's Discretion

Under Section 23, it is in the discretion of the Court to determine whether any, and if so what,
maintenance should be awarded under the Act, in respect of the wife, children, aged or infirm
parents, the Court will have regard to:

(a) the position and status of the parties;


(b) the reasonable wants of the claimant;

(c) if the claimant is living separately, whether he (or she) is justified in doing so;

(d) the value of the claimant's property and any income derived from such property, or from the
claimant's own earning or from any other source; and

(e) the number of persons entitled to maintenance under the Act

In Sukhjinder singh saini v/s Harvinder kaur SCC OnLine Del 11621, decided on
10.11.2017, certain observations were made by the Delhi High Court while dealing with the
issue of deciding the maintenance to be granted for a child:

 Both the parents have a legal, social and a moral obligation to maintain their children and
provide them with the best standard of living, depending on the financial footing of the
parties.

 They are equally obligated to provide means for best education.

 It was further held that even if the child is living with the spouse whose income is
sufficient enough to maintain the child cannot be taken as a good ground by the other
spouse of not maintaining the child or taking care of the child’s welfare.

The amount of maintenance, whether fixed by a Court's decree or by agreement, may be altered
subsequently if there is a material change in the circumstance (Section 25). A person cannot
claim maintenance under the Act if he or she has ceased to have a Hindu by conversion to
another religion (Section 24).
Maintenance of dependants

Dependents of a deceased must be maintained if they do not have the capacity to do so by


themselves. Section 21 of the Hindu Adoption and Maintenance Act, 1956 defines dependents
and Section 22 of the Hindu Adoption and Maintenance Act, 1956 states that such persons
shall be entitled to maintenance.

Who are dependents?

Dependent is someone who relies on parents, brother or some other relative for sustaining
themselves.

Section 21 of the act says that in the context of this act dependents refer to the following
relatives of the deceased:

 A father.

 A mother.

 A widow who has not remarried.

 A minor son, grandson, or great-grandson with predeceased father and grandfather.


Provided he has not been able to obtain maintenance from any other source.

 Unmarried daughter, granddaughter, or great-granddaughter with predeceased father and


grandfather. Provided she has not been able to obtain maintenance from any other source.

 A widowed daughter who has not been able to obtain maintenance from the estate of her
husband, children, or from her in-laws.

 Widowed daughter-in-law, or widowed granddaughter-in-law, who has not been able to


obtain maintenance from any other sources.

 An illegitimate minor son or illegitimate unmarried daughter.


Do dependents need to be maintained?

Section 22 of the act states:

 That dependents of a deceased Hindu must be maintained by his heirs with the aid of the
estate that they inherited from the deceased.

 When the dependents have not been left with any share in the property or estate by way
of will or succession, they are still entitled to be maintained by whoever takes over the
estate.

 If multiple persons have taken over the property of the deceased, each one of them will
be liable to maintain the dependents.

 The amount of maintenance to be paid will be divided among them depending on the
value of the share they hold in that property.

 In case a dependent has obtained some part of share in the property of the deceased, they
will not be liable to maintain other dependents.

 Others who have taken over the property will still have to maintain other dependents but
the dependent holding a share shall be excluded and maintenance will now be paid from
the remaining property.
Maintenance of Muslim woman

Muslim woman entitled to maintenance under CrPC

A divorced Muslim woman has right under Section 125 CrPC to claim maintenance even beyond
the iddat period. If the woman is able to maintain herself then the liability of husband to maintain
her ceases with the expiration of iddat period. However, on the inability of maintaining herself,
she can take recourse of that section. Section 125 has an overriding effect on personal law in case
of conflict between the two, Mohd. Ahmed Khan v. Shah Bano Begum, (1985) 2 SCC 556.

Husband to make fair provision and maintenance within iddat period for ex-wife’s whole
life

Section 3(1)(a) of Muslim Women (Protection of Rights on Divorce) Act, 1986 makes husband
liable to make a reasonable and fair provision and maintenance to divorced Muslim wife on or
before the expiration of the iddat period. However, this maintenance is not limited only for the
iddat period but extends to her whole life unless she remarries. Husband is obliged to provide a
reasonable and fair provision in addition to maintenance to contemplate the future need of ex-
wife, Danial Latifi v. Union of India, (2001) 7 SCC 740.

Maintenance not restricted to iddat period

A divorced Muslim wife is entitled to maintenance not merely until the completion of the iddat
period, but for her entire life unless she remarries. Sabra Shamim v. Maqsood Ansari, (2004) 9
SCC 616.

Maintenance to second wife

Husband who conceals subsistence of his earlier marriage while marrying the second wife is
entitled to give maintenance to second wife. Second wife is to be treated as a legally wedded
wife for the purpose of maintenance, Badshah v. Urmila Badshah Godse, (2014) 1 SCC 188.
Mohd Ahmed Khan V. Shah Bano Begum, 1985 AIR 945

Facts of the Case:

Shah Bano was promised Rs.200 as maintenance per month by her ex-husband since after she
was driven out of her house in 1975, the same got stopped in April 1978.

In 1978, she filed for a maintenance petition in the local court for Rs 500 per month as
maintenance.

Subsequently, the husband gave her irrevocable talaq on November 6 th, 1978 and used it as a
defence to not pay maintenance.

Further, he contended that the amount of Rs 200 per month was paid for about two years and an
additional amount of Rs 3000 had been deposited as dower in court for the period of iddat.

The magistrate, in August 1979, directed the husband to pay a sum of Rs 25 per month as
maintenance

A revisional application filed in high court increased the maintenance to Rs 179. 20 per month.
The same was challenged by the husband in the supreme court as a special leave petition to the
high court’s decision.

Issues:

1. Whether the “WIFE” definition includes a divorced Muslim woman?


2. Criminal Procedure Code (II of 1974), Section 125. Whether it overrides
personal law?
3. Whether a Muslim husband’s obligation to provide maintenance for a
divorced wife is in or not in the conflict between section 125 and Muslim
Personal Law?
4. Criminal Procedure Code (II of 1974), Section 127(3) (b). What is the sum
payable on divorce?
Judgment:

 The verdict was given by C.J, Y.C Chandrachud, and the appeal of Mohd. Ahmed
Khan was dismissed.
 Supreme Court said Section of the code applies to all citizens independent of their
religion and consequently Section 125(3) of Code of Criminal Procedure is pertinent
to Muslims as well, without any sort of discrimination. The court further stated that
Section 125 overrides the personal law if there is any conflict between the two.It
makes clear that there’s no strife between the provisions of Section 125 and those of
the Muslim Personal Law on the address of the Muslim husband’s obligation to
provide maintenance for a divorced wife who is incapable to maintain herself.
 Supreme Court in this case duly held that since the obligation of Muslim husband
towards her divorced wife is restricted to the degree of ” Iddat” period, indeed though
this circumstance does not contemplate the rule of law that’s said in Section 125 of
CrPc., 1973 and subsequently the obligation of the husband to pay maintenance to the
wife extends beyond the iddat period in the event that the wife does not have
sufficient means to maintain herself. It was further stated by the court that this rule
according to Muslim Law was against humanity or was wrong because here a
divorced wife was not in a condition to maintain herself.
 The payment of Mehar by the husband on divorce is not sufficient to exempt him from
the duty to pay maintenance to the wife.
 After a long court procedure, the Supreme Court finally concluded that the husbands’
legal liability will come to an end if a divorced wife is competent to maintain herself.
But this situation will be switched in the case when the wife isn’t able in a condition
to maintain herself after the Iddat period, she will be entitled to get maintenance or
alimony under Section 125 of CrPC.
Subsequently, the Parliament of India in 1986 decided to enact the Muslim Women (Protection
Of Rights Of Divorce) Act, 1986. Protecting the rights of the divorced Muslim Women and for
those who have got divorced from their husbands, were the main objective of this act. The Act
was passed by the Rajiv Gandhi government to nullify the decision in the Shah Bano case. Under
this act:

 Muslim divorced women ought to be entitled to an adequate and reasonable sum of


maintenance till the Iddat period.

The provision in question is Section 3(1)(a) of the Muslim Women (Protection of Rights
on Divorce) Act, 1986 which states that "a reasonable and fair provision and maintenance
to be made and paid to her within the iddat period by her former husband".

But the Court held this provision means that reasonable and fair provision and maintenance is
not limited for the iddat period (as evidenced by the use of word "within" and not "for"). It
extends for the entire life of the divorced wife until she remarries. (Danial Latifi & Anr vs
Union of India, (2001) 7 S.C.C. 740)

THESE NOTES ARE ONLY FOR REFERENCE. IT IS SUGGESTED TO GO


THROUGH THE CLASS NOTES AND BOOKS ALSO.

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