Supreme Court Justice Vikram Nath Delivers Groundbreaking Ruling Enhancing Alimony in Sadhukhan v. Sadhukhan Maintenance Dispute

Introduction

On the 29th of May, 2025, the Supreme Court of India issued a verdict that was of great significance in the matter of Civil Appeal No. 10209 of 2024. This lawsuit was brought about as a result of a dispute on family law that took place between Rakhi Sadhukhan and Raja Sadhukhan, who is her husband.

The decision of the High Court of Calcutta, which granted a decree of divorce and created perpetual alimony at a small sum, was challenged by the bench, which comprised of Justice Vikram Nath and Justice Sandeep Mehta.

As a result, the bench decided to revisit the order. The major focus of the appeal was on the appropriate amount of child support that ought to be paid, as well as the accurate interpretation of statutory duties that are imposed by a range of laws pertaining to marriage and criminal procedure.

Facts of the Case

On the 18th of June in 1997, Rakhi and Raja Sadhukhan tied the wedding, and on the 5th of August in 1998, they became parents to a boy. In July of 2008, Raja submitted a petition for divorce in accordance with Section 27 of the Special Marriage Act, 1954. He said that his spouse had been psychologically abusive to him during their marriage.

During the ensuing proceedings, Rakhi submitted a petition for interim support under Section 24 of the Hindu Marriage Act, 1955, and later under Section 125 of the Code of Criminal Procedure, 1973, for both herself and their child.

Both of these petitions were filed jointly. The lower court made some modest interim payments, then the higher court enhanced these payments such that they were in line with Raja’s income.

The divorce was finalized on June 25, 2019, when the High Court approved the divorce, ordered the husband to redeem the mortgage on the marital apartment in favor of the wife, let the wife and son to continue living there, and established permanent alimony at a rate of ₹20,000 per month, with a 5% rise every three years. In addition to this, the court took into account arrangements for the son’s education and the price of his tuition.

During its deliberations, the Supreme Court of India relied on a variety of statutory statutes that control marital disputes and maintenance duties in India. These provisions were cited as examples.

A spouse has the ability to file for the dissolution of their marriage for a number of reasons, including cruelty, as stated in Section 27 of the Special Marriage Act of 1954. This law was passed in 1954.

A party has the power to get interim support pendente lite in accordance with Section 24 of the Hindu Marriage Act, which was enacted in the year 1955. During the time that the issue is being litigated, this clause guarantees that the party will be provided with essential financial aid.

According to Section 125 of the Code of Criminal Procedure, 1973, any person who has sufficient money to provide for his wife, children, and parents who are dependent on him is subject to a greater obligation.

For the purpose of preventing persons from slipping into poverty, this clause requires that payments be made on time. It is shown in each of these pieces of legislation that a social commitment has been made to protect vulnerable parties, to ensure economic stability, and to preserve human dignity within the context of the family.

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Statutory Framework

She stated that the amount of alimony that was being given to her was utterly inadequate in relation to the kind of life that she was living and the financial capabilities of her husband. Rakhi Sadhukhan was making this argument.

She contended that the ₹20,000 monthly award, which had initially been provided as interim maintenance, did not appropriately reflect the lifestyle that she had lived during the duration of the marriage and did not satisfy her essential necessities.

To support her position, she cited Raja’s higher wages in the past and argued that a substantial raise was necessary. She did this in order to make her point. In addition, Rakhi stressed the inflationary pressures and the rising price of living, underlining the fact that her exclusive dependency on maintenance demanded a more significant sum in order to assure her future security and dignity.

Rakhi’s statement was made in light of the fact that she was dependent on maintenance alone.

Contentions of the Appellant-Wife

In answer, Raja Sadhukhan said that his current net monthly income, which was supported by salary slips, bank accounts, and tax filings, was around ₹1,64,039, which was a reduction from his prior earnings.

This information was provided in response to the question. In order to demonstrate that the alimony that had been established in the past struck a reasonable balance between his commitments and his limited resources, he provided a comprehensive account of his home costs.

This included providing financial assistance to his elderly parents and other members of his family who were dependent on him. In addition, Raja said that their son, who was now 26 years old, was financially self-sufficient, which reduced the need for continuous necessary support that went beyond educational assistance. Raja’s son was now financially independent.

Contentions of the Respondent-Husband

The Supreme Court of the United States identified the following fundamental issues: whether the alimony that was determined by the High Court was proportionate to the wife’s requirements and the husband’s capacity; the extent to which the wife’s previous standard of living should guide future maintenance; the appropriate frequency and quantity of periodic enhancements; and the extent to which the husband is still liable to an adult child. All of these issues were addressed in court.

To find solutions to these issues, it was necessary to use a sophisticated application of legislative concepts in combination with equitable considerations, therefore striking a balance between fairness and practicability.

Fundamental Issues for Determination

In his opinion for the bench, Justice Vikram Nath emphasized that maintenance orders must guarantee that the genuine needs of the dependents are addressed while also appreciating the capacity of the payer. This was a need that must be met.

The court made the comment that the sum of ₹20,000 per month, subject to a triennial increment, that was awarded by the High Court did not sufficiently reflect Raja’s financial disclosures or the wife’s mode of life during the marriage.

Permanent alimony should enable the spouse to maintain a lifestyle that is reasonably comparable to that which was experienced during the marriage, with modifications made for inflation and future demands. This is something that has been established by precedents. These previous cases were taken into consideration by the panel.

With regard to the husband’s income, the court confirmed his assertions but came to the conclusion that the expenses he stated were too high. Despite the fact that he met his voluntary family duties and gave financial help to his elderly parents, the court decided that his maintenance requirements could not be decreased by a disproportionate amount. Furthermore, the Court stressed that once a child reaches the age of maturity and is financially independent, the need for regular maintenance is no longer necessary; although, voluntary contributions are still authorized up until that point.

In terms of the enhancement schedule, the bench came to the view that a mid-term boost every two years was a more effective strategy to address inflationary tendencies than the three-year cycle that had been imposed before. This was the result reached by the bench. This method is in line with the current body of legislation, which lays a focus on making regular improvements in order to avoid the degradation of maintenance over the course of time.

Court’s Analysis

As a result of the Supreme Court’s decision to approve Rakhi’s appeal, the alimony was increased to ₹50,000 per month, with the potential of a 5% increase every two years. The court affirmed that the mortgage on the flat would be redeemed and passed to the wife, and that she would continue to have the right to reside there.

This was done in line with the order that was handed down by the High Court. It was made abundantly plain by the court that once the son attained the age of majority, he would no longer be eligible for support.

This is in conformity with the conditions that are stipulated by both the laws and the constitution. Raja, on the other hand, was offered the opportunity to pay support on his own will. It was highlighted in the decree that it is necessary to undertake periodic evaluations and make revisions in order to ensure that maintenance orders continue to be equal and effective despite the changes that have occurred in the economic environment.

Judgment and Directions

This opinion reaffirms the concept that maintenance must strike a balance between the legitimate necessities of the receiver and the practical capabilities of the payer, with proof of income and expenses serving as the basis for the determination of the balance.

Both the amount and the frequency of upgrades were raised by the Supreme Court in order to address the issue of inflation and the changes that have occurred in the economy. In order to prevent maintenance awards from becoming out of date, this action was taken.

In addition, the decision emphasizes that once an adult child achieves the age of financial independence, they are no longer eligible to receive necessary maintenance as stipulated by the law. As a result, this helps to guarantee that the major focus of alimony is on the well-being of the husband.

Conclusion

The decision that was handed down by the Supreme Court in the matter of Sadhukhan v. Sadhukhan is a significant affirmation of the maintenance jurisprudence that is in place in India. By establishing a connection between statutory needs and equitable principles, the Supreme Court has provided clear guidance on the process of establishing and amending alimony.

Because of this, it has been made certain that spouses get help that is suitable for their prior way of life and the economic realities of their circumstances. The decision that Justice Vikram Nath made on behalf of the bench will serve as a significant precedent for the purpose of ensuring that matters pertaining to marital maintenance are handled in a fair manner and for maintaining the dignity of couples who are dependent on one another.