2026:CGHC:7422 NAFR HIGH COURT OF CHHATTISGARH AT BILASPUR CRR No. 52 of 2022 Smt. Nirmala Satnami W/o Shri Ramratan Satnami, Aged About 52 Years R/o Deendayal Ward, Bhatapara, P.S. Bhatapara City, District Balodabazar Bhatapara Chhattisgarh, District : Balodabazar-

Bhathapara, Chhattisgarh ... Applicant(s)

versus Ramratan Satnami S/o Ramprasad Satnami, Aged About 56 Years R/o Shantinagar Ward, Bhatapara, P.S. Bhatapara Ward, Bhatapara, P.S. Bhatapara City District Balodabazar Bhatapara (Chhattisgarh), District :

Balodabazar-Bhathapara, Chhattisgarh ... Respondent(s)

For Applicant(s) : Mr. Bharat Lal Dembra, Advocate.

For Respondent(s) : Mr. Rakesh Kumar Manikpuri, Advocate.

Hon'ble Shri Ramesh Sinha, Chief Justice

Order on Board

10 /02/2026

1. The applicant has filed this criminal revision against the order dated 20.12.2021 passed by learned Judge, Family Court, Balodabazar, District – Balodabazar (C.G.) in M.J.C No.176/2021, whereby the learned Family Court has rejected the application under Section 127 CrPC filed by the applicant.

2. Brief facts necessary for disposal of this revision are that the applicant is the legally wedded wife of the respondent. In the year 2000, the competent Court directed the respondent/husband to pay maintenance of Rs. 1,000/- per month to the applicant. After lapse of about 21 years, the applicant filed an application under Section 127 of the Code of Criminal Procedure seeking enhancement of the said maintenance amount from Rs. 1,000/- per month to Rs. 30,000/- per month, on the ground of substantial increase in the cost of living and change in circumstances. It was specifically pleaded that the respondent is employed as a Railway Employee and is earning approximately Rs. 80,000/- per month, and that his salary has considerably increased since the year 2000. The learned Family Court recorded the evidence of both parties and their respective witnesses. After appreciation of the evidence and pleadings, the learned Family Court dismissed the application filed under Section 127 Cr.P.C. seeking enhancement of maintenance. Being aggrieved by the dismissal order, the applicant has preferred the present revision petition.

3. Learned counsel for the applicant submits that the impugned judgment passed by the learned Family Court is bad in law, perverse and based on no proper appreciation of evidence, and is therefore liable to be set aside. The learned Court failed to assign cogent and sufficient reasons while dismissing the application under Section 127 Cr.P.C., which is a mandatory requirement of law, rendering the impugned order unsustainable in the eyes of law. He further submits that the learned Family Court committed a grave error in not considering that the applicant is unable to maintain herself with a meagre amount of Rs. 1,000/- per month, which was awarded in the year 2000, and no enhancement has been made for the last 21 years despite substantial rise in the cost of living. He also submits that the learned Family Court ignored the oral as well as documentary evidence adduced by the applicant and recorded findings on presumptions, without properly appreciating the material available on record, thereby causing serious prejudice to the applicant.

4. On the other hand, learned counsel for the respondent opposes the submissions made by the learned counsel for the applicant and submits that the Family Court after considering all the documents and evidence adduced by the parties has passed the order, in which no interference is called for.

5. I have heard learned counsel for the parties, perused the impugned order and other documents appended with criminal revision.

6. From perusal of the impugned order, it transpires that the learned Family Court has rejected the application under Section 127 CrPC filed by the applicant, holding that the applicant failed to establish any material change in circumstances warranting enhancement of maintenance. The Court observed that no cogent evidence was produced to prove the