Chaturbhuj v. Sita Bai (2008)

Quick Summary

CASE_TITLE: Chaturbhuj v. Sita Bai (2008) 2 SCC 316

PRIMARY_KEYWORDS: Section 125 CrPC, maintenance, wife unable to maintain, sufficient means

SECONDARY_KEYWORDS: standard of living, pension & rent income, evidentiary burden, family law

PUBLISH_DATE: October 31, 2025   |   AUTHOR_NAME: Gulzar Hashmi   |   LOCATION: India

The Supreme Court said: even if a wife has some income, maintenance can be granted under Section 125 CrPC if that income is not enough for a basic, dignified life. The wife’s standard should broadly match the matrimonial home. Here, Sita Bai’s income was insufficient; maintenance was awarded.

Issues

• Was Sita Bai’s income sufficient to sustain herself?
• If not, should Chaturbhuj be directed to pay maintenance under Section 125 CrPC?

Rules

• Wife’s inability test: Court checks if the wife can maintain herself reasonably. Small/irregular income does not bar maintenance.
• Husband’s means: His capacity (salary, pension, rent, other sources) is relevant when fixing maintenance.
• Standard of living: Aim is comparable dignity to life in the matrimonial home.
• Evidence-based: Decision depends on material on record before the court.

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Arguments

• Key holding: Presence of some income with the wife does not defeat a Section 125 claim unless it is sufficient to maintain her.
• Entitlement: Sita Bai’s income was found insufficient; she was entitled to maintenance.
• Assessment: Courts look at husband’s means and wife’s reasonable needs measured against the matrimonial standard.

Ratio Decidendi

The decisive test is inability of the wife to maintain herself at a reasonable level. Any income is not enough; it must be sufficient. If not, maintenance under Section 125 CrPC can and should be ordered, considering the husband’s means and the wife’s dignity.

Why It Matters

• Clarifies threshold: “Some income” ≠ “sufficient income”.
• Dignity focus: Maintenance supports a basic dignified life near the marital standard.
• Practical guide: Shows how courts weigh evidence of means and needs.

Key Takeaways

1. Section 125 CrPC: Relief turns on the wife’s inability to maintain herself.
2. Income test: Small/irregular income does not defeat maintenance; it must be sufficient.
3. Husband’s means: Pension, rent, and other earnings count.
4. Standard: Comparable to life in the matrimonial home.

Mnemonic + 3-Step Hook

Mnemonic: “S U F F I C I E N T — M E A N S”

• SUFFICIENT: Wife’s income must truly sustain her.
• MEANS: Court gauges the husband’s capacity to pay.

3-Step Hook: Some Income ≠ Enough → Check Husband’s Means → Maintain Dignity.

IRAC Outline

Issue

Whether Sita Bai’s income was sufficient; if not, should maintenance be ordered against Chaturbhuj?

Rule

Under Section 125 CrPC, wife’s inability to maintain herself triggers relief; husband’s means and wife’s needs are weighed.

Application

Evidence showed some income with wife but not enough for a dignified life; husband had pension/rent and capacity.

Conclusion

Income was insufficient; maintenance payable by the husband.

Glossary

• Section 125 CrPC: Summary remedy for maintenance to prevent destitution.
• Sufficient Means: Real ability and resources to support dependants.
• Matrimonial Standard: Approximate level of living enjoyed during cohabitation.

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