1. A Civil Revision Petition challenged an interim maintenance order granted under the Hindu Marriage Act, 1955, in a pending matrimonial original petition. (Para 1 )
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2026 Supreme(Online)(Mad) 106264
IN THE HIGH COURT OF JUDICATURE AT MADRAS
N. Anand Venkatesh, J
Not Found – Appellant
Versus
Not Found – Respondent
Civil Revision Petition | CMP No.16467 of 2026 | CMP No.27969 of 2026
Important Points
The court upheld the trial court's discretion in fixing a reasonable amount for interim maintenance under Section 24 of the Hindu Marriage Act, 1955, and directed the collection of data to find specialized solutions for matrimonial disputes arising from marriages during the 2020-2022 pandemic period.
Subject
Family Law - Maintenance
Act Referred
Headnote
(A) Matrimonial Law - Interim Maintenance - Quantum of Maintenance - Where the trial court exercises its discretion to fix a reasonable and non-exorbitant amount of interim maintenance under Section 24 of the Hindu Marriage Act, 1955, the High Court will not interfere under Article 227 of the Constitution of India. (Para 5)
(B) Judicial Administration - Matrimonial Disputes - Pandemic Era (2020-2022) - Observation that marriages during the lockdown period were subject to extraordinary circumstances and pressures, leading to a high volume of disputes; necessity for a specialized, "out of box" approach and data collection to resolve such cases amicably. (Para 8, 9)
Issues: Whether the interim maintenance of Rs. 10,000 per month fixed by the Sub Court was reasonable or exorbitant.
(B) Judicial Administration - Matrimonial Disputes - Pandemic Era (2020-2022) - Observation that marriages during the lockdown period were subject to extraordinary circumstances and pressures, leading to a high volume of disputes; necessity for a specialized, "out of box" approach and data collection to resolve such cases amicably. (Para 8, 9)
Issues: Whether the interim maintenance of Rs. 10,000 per month fixed by the Sub Court was reasonable or exorbitant.
Legal Category Hierarchy
Advocates:
For the Appellants/Petitioners: CH. Mohith Sai
For the Respondents: A.M. Packianathan Easter, Agathian J. Pandian
For the Appellants/Petitioners: CH. Mohith Sai
For the Respondents: A.M. Packianathan Easter, Agathian J. Pandian
Table of Contents
2. The petitioner challenged the reasonableness of the maintenance amount fixed by the trial court, while the respondent sought to justify the maintenance order's quantum. (Para 2 , 3 )
3. The court found the interim maintenance amount reasonable and determined that the trial court properly exercised its discretion without warranting intervention under Article 227. (Para 5 , 6 )
4. The High Court will not interfere with an interim maintenance order under Article 227 if the trial court has properly exercised its discretion and fixed a reasonable amount. (Para 5 , 6 )
5. The revision petition was disposed of by sustaining the impugned maintenance order, directing payment of arrears, and ordering the trial court to expedite the original petition's disposal. (Para 6 , 7 )
6. What is the threshold for the High Court to interfere with an interim maintenance order under Article 227 of the Constitution?
The High Court will not interfere under Article 227 if the trial court properly exercised its discretion in fixing maintenance and the amount is found to be reasonable rather than exorbitant. (Para 5 , 6 )
7. Can the High Court issue proactive directions for data collection regarding specific categories of matrimonial disputes?
Yes, for the purpose of adopting a different method of resolution for cases arising from the 2020-2022 pandemic period, the Court can direct District Judges to collect data on such pending matrimonial files. (Para 9 , 10 , 11 )
ORDER
This Civil Revision Petition has been filed under Article 227 of the Constitution of India challenging the fair and decreetal order dated 30.03.2026 passed in I.A.No. 2 of 2025 in O.P.No. 377 of 2023 on the file of the Sub Court, Alandur, wherein the Court below based on the application filed by the respondent under Section 24 of the Hindu Marriage Act, 1955, fixed a sum of Rs.10,000/- as interim maintenance payable by the petitioner to the respondent.
2.Heard the learned counsel for the petitioner and the learned counsel appearing on behalf of the respondent and carefully perused the materials available on record and this Court also carefully went through the order passed by the Court below.
3.When this Civil Revision Petition was entertained by this Court on14.07.2026, as an interim measure, this Court directed the petitioner to pay interim maintenance at the rate of Rs.7,000/- per month and further directed the petitioner to pay the arrears of maintenance as per the impugned order.
4.The arrears of maintenance have been paid as directed by this Court and the monthly interim maintenance is also being paid at the rate of Rs.7,000/- per month.
5.In the considered view of this Court, the Court below has properly exercised its discretion and fixed the interim monthly maintenance at Rs.10,000/- per month, payable by the petitioner to the respondent and the amount fixed by the Court below is reasonable and not exorbitant. Therefore, this Court is not inclined to exercise its jurisdiction under Article 227 of the Constitution of India and interfere with the same.
6.In view of the above, the order dated 30.03.2026 passed in in I.A.No. 2 of 2025 in O.P.No. 377 of 2023 on the file of the Sub Court, Alandur, is sustained. In view of the same, the petitioner is directed to remit the arrears of maintenance, since as per the interim order passed by this Court only Rs.7,000/- was paid per month as monthly maintenance and the same shall be paid, within a period of four weeks from the date of receipt of copy of this order. Considering the fact that the Original Petition is of the year 2023, there shall be a direction to the Sub Court, Alandur, to dispose of O.P.No. 377 of 2023, within a period of four months from the date of receipt of copy of this order.
7.In the result, this Civil Revision Petition is disposed of in the above terms. No Costs. Consequently, the connected miscellaneous petitions are closed.
8.Before drawing the curtains in the present case, this Court has noticed that, in the last three months, in almost every matrimonial dispute that has reached this Court, the marriages had taken place between the parties between the years 2019 to 2022. In more than 95% of those cases, the parties had hardly lived together for six to nine months and in some cases, they had lived together only for three months. Incidentally, that period was when there was a total lockdown due to the pandemic situation. The Coronovirus has not only taken away human lives but had also destroyed the institution of marriage during that period. Since the parties were inside the same house, the best and worst aspects of their characters were exposed and most of them were under pressure, thinking about their future and it had a direct impact on their marital relationship. Therefore, those matrimonial disputes that arose during this period viz., 2000 to 2022, must be dealt with as a separate category and out of box thinking is required to resolve these disputes. This is in view of the fact that the parties lived together hardly for only a few months and they were going through extraordinary circumstances due to the pandemic. Hence, this Court is inclined to see if a different method can be adopted to resolve all those matrimonial disputes that has taken place during the period between 2020 to 2022.
9.In view of the above, there shall be a direction to all the Principal District Judges across the St
