Maintenance and Matrimonial Portals: High Court Rejects Speculative Income Claims

In a recent ruling, the High Court of Delhi addressed the complexities of determining maintenance after a decade-long legal battle. The Court dismissed a plea by a former wife seeking to enhance her maintenance award based on income figures declared by her ex-husband on a matrimonial website, reinforcing the necessity for reliable evidence in family law disputes.

The Backdrop of the Dispute

The marriage between Smt. Neeta (the petitioner) and Shri Pankaj Saragoi (the respondent) began in July 2007 but dissolved shortly thereafter, surrounded by allegations of cruelty and dowry demands. The petitioner filed for maintenance under Section 125 of the Code of Criminal Procedure (Cr.P.C.) in 2009.

Following a tumultuous series of legal procedural developments—including an ex parte decree of annulment in 2012 and subsequent maintenance orders—the Family Court eventually awarded the petitioner monthly maintenance of ₹12,500 (rising to ₹24,000 for a specific period). Dissatisfied, the petitioner sought an enhancement, arguing that the respondent’s actual income was significantly higher than the Family Court’s estimates.

Competing Claims on Financial Capacity

The petitioner’s case relied heavily on a declaration made by the respondent on the portal Jeevansathi.com , where he allegedly stated an annual income exceeding ₹10 lakhs. However, the respondent countered that the petitioner was a qualified professional who had been gainfully employed throughout the period, filing her own income tax returns and failing to disclose her 2016 remarriage during initial lower court proceedings.

The petitioner argued that in Rajnesh v. Neha (2021) , the Supreme Court mandated the filing of income disclosure affidavits, which were absent in this case. The respondent maintained that the Family Court’s estimation of ₹30,000 to ₹60,000 per month was reasonable, particularly given the documentary evidence of the petitioner's own income growth.

The Court’s Analysis

Justice Dr. Swarana Kanta Sharma noted that while the absence of income affidavits was a procedural gap, it did not necessitate the overturning of a logic-based judgment, especially given that the relevant period spanned 2007–2016. The Court emphasized that self-declared information on matrimonial sites holds no evidentiary weight in a court of law.

"This Court is of the considered opinion that any self-declared information made on a matrimonial portal, without verification or corroborative evidence, cannot be treated as reliable or admissible proof of income," Justice Sharma stated. Furthermore, the Court highlighted the petitioner’s own admission of significant career growth, noting that she now earns considerably well, rendering the request for enhancement on speculative grounds unsustainable.

Key Observations

• On Matrimonial Documentation: "A court of law cannot rely upon a declaration made by a person on a matrimonial website."
• On Speculative Income Trends: "This Court is of the view that income trends can vary depending on various personal and professional circumstances, and cannot be presumed to have followed a linear upward trajectory without any documentary proof."
• On Financial Capacity: "These statements indicate that the petitioner has a stable and progressively increasing income and is capable of supporting herself to a considerable extent."

The Final Verdict: Implications

The Delhi High Court upheld the Family Court’s judgment, dismissing the petition. The ruling signals a clear judicial stance that maintenance calculations must be rooted in verifiable financial records rather than aspirational or inflated figures presented in digital profiles. For legal practitioners, this serves as a reminder that courts will prioritize objective financial data over potential earning capacity derived from self-promotional declarations in marriage-seeking platforms.

The petition, along with all pending applications, was formally dismissed.