Case Title: Ravi Prakash Saxena @ Ravi Prakash vs. Priyanka Rani
Court: Patna High Court
Coram: Hon’ble Mr. Justice Bibek Chaudhuri
Date of Judgment: 04 September 2025
Case No.: Criminal Revision No. 676 of 2024
Background
- The petitioner, Ravi Prakash Saxena, challenged the order dated 24 May 2024 passed by the Principal Judge, Family Court, Saran (Chapra), which directed him to pay ₹20,000 per month as maintenance to his wife, Priyanka Rani.
- The marriage took place on 16 February 2020 through Arya Samaj rituals.
- The relationship soured soon after marriage, leading to disputes, allegations, and multiple legal proceedings.
Petitioner’s Contentions
- Financial Capacity of Wife
- Priyanka had already received ₹40 lakh alimony from her first husband after divorce.
- She is highly qualified (M.Sc. in Botany, Diploma in Japanese) and capable of earning independently.
- Fraud Allegation
- Claimed Priyanka suppressed her previous marriage and submitted a false affidavit declaring herself unmarried.
- False Allegations & Cruelty
- Alleged that Priyanka refused to cohabit, insulted his parents, and threatened false criminal cases.
- Stated she lodged a dowry harassment FIR after a 16-month delay, raising doubts about her credibility.
- Maintenance Challenge
- Cited Section 125 Cr.P.C., arguing that a capable and qualified wife cannot claim maintenance.
- Relied on Rajnish v. Neha (2021), asserting that asset-liability affidavits must be filed before deciding maintenance.
Respondent’s Contentions
- Denied all allegations.
- Claimed she gave the entire ₹40 lakh alimony from her first marriage to the petitioner.
- Alleged dowry demands of ₹15 lakh, physical and mental cruelty, forced abortion, and harassment.
- Filed a complaint under Sections 498A, 315, 34 IPC and 3/4 of the Dowry Prohibition Act in February 2022.
Court’s Observations
- On Suppression of Marriage
- Dismissed the petitioner’s fraud allegation, noting that Priyanka had disclosed her divorce on a matrimonial site.
- Her affidavit stating “unmarried” was not fraudulent since a divorcee’s prior marriage becomes non-existent (“non-est”) in law.
- Wife’s Capability to Earn
- Observed that Priyanka’s qualifications and ₹40 lakh settlement were relevant factors for determining maintenance.
- Delay in Dowry Complaint
- Highlighted unexplained delay in lodging the FIR and lack of supporting evidence for cruelty and abortion.
- Violation of Supreme Court Guidelines
- Criticized the Family Court for failing to follow Rajnish v. Neha (2021), which mandates:
- Filing asset & liability affidavits by both parties.
- Considering income, assets, expenses, and earning potential before deciding maintenance.
- Criticized the Family Court for failing to follow Rajnish v. Neha (2021), which mandates:
Decision
- Impugned maintenance order of ₹20,000/month was quashed.
- Directed the Family Court, Saran (Chapra) to:
- Obtain asset & liability affidavits from both parties within 4 weeks.
- Reassess maintenance afresh, following Supreme Court guidelines.
- Criminal Revision Petition Allowed.
Key Takeaways
- Courts must evaluate financial disclosures before granting maintenance.
- Qualified spouses with significant financial assets may not automatically be entitled to maintenance.
- Rajnish v. Neha (2021) guidelines are binding in maintenance cases.
Suggested Titles for Web Post
- “Patna HC Quashes ₹20K Maintenance to Wife, Orders Fresh Hearing Following SC Guidelines”
- “High Court: Affidavits of Assets & Liabilities Must Be Filed Before Deciding Maintenance”
- “Qualified Divorcee Not Automatically Entitled to Maintenance: Patna HC”
- “Patna High Court Sets Aside ₹20K Monthly Maintenance, Cites Rajnish v. Neha”
