The recent decision of the Bombay High Court in Purvi Mukesh Gada v. Mukesh Popatlal Gada, 2025¹, represents a paradigm shift in the approach to matrimonial maintenance in India, standing out as a powerful exemplification of the judiciary’s willingness to go beyond the facade of declared income in matrimonial disputes. This case features a Pune-based businessman who, after a 16-year marriage and subsequent divorce, claimed a drastically low income in an attempt to evade his maintenance obligations, triggering a rare and rigorous judicial investigation into the true scale of his wealth.

Case Background
In this case, after the dissolution of a 16-year marriage, the Family Court initially awarded the wife permanent maintenance of ₹50,000 per month. Dissatisfied, the wife filed for revision, referencing her difficulties as a single mother and her former husband's luxurious standard of living. The husband, however, maintained that his annual income was a meager ₹6 lakh. The High Court found his submission “farcical,” observing that, despite these claims, the husband was at the helm of a conglomerate valued at over ₹1,000 crore, as evidenced by his role as a “torchbearer” and details of asset movement recorded. In conclusion, the Bombay High Court raised the wife’s maintenance from ₹50,000 to ₹3.5 lakhs per month.

The judgment itself is notable for its reliance on lifestyle evidence. It details how the husband’s financial conduct included hosting lavish parties, expensive travel, luxury apparel, high-end education for his children, and significant money transfers, including ₹10 crore moved to his brother. The Court found that these circumstantial facts far outweighed self-serving declarations on paper and made it clear that the appropriate standard for assessing capacity is the lifestyle enjoyed during marriage, not mere disclosed income.

This rigorous approach is mirrored in recent cases from other High Courts. For example, the Supreme Court in Manoj Kumar v. Sangeeta (Supreme Court, 2017)², reaffirmed that the courts should inquire beyond the surface to avoid injustice when husbands suppress their actual means. The Bombay High Court judgment draws on constitutional ideals set out in Bhuwan Mohan Singh v. Meena(Supreme Court, 2015)³, stating in para 40 that “maintenance is not a bounty but a tangible right to subsist with dignity”.

Analysis and Conclusion
In conclusion, the Bombay High Court’s decision in Purvi Mukesh Gada v. Mukesh Popatlal Gada reiterates that courts will not be bound by the facade of declared income. They must “lift the veil” and go above and beyond to uncover the true economic power of the husband. The observations of the court in this judgment expose how concealing real income and hiding behind the veil of a family business remains a common tactic used by husbands in divorce cases to avoid paying maintenance.

Does this judgment have an uplifting ripple effect for women? While on the face of it, it appears that the Purvi Mukesh Gada judgment creates a circle of empowerment for women facing maintenance woes, it is important to step back and assess whether the perceived empowerment is actual or has been sensationalised by headlines. Legal news headlines claiming that the Bombay High Court raised the maintenance of the wife by seven times⁴ fail to highlight that the final maintenance of ₹3.5 lakhs per month was combined maintenance for the wife and the child, and that the original maintenance of ₹50,000 per month was unreasonable to begin with. There is an urgent need for maintenance for the wife and maintenance for the children to be decoupled, so that the wife receives a reasonably substantial amount in her own right instead of most of the award being subsumed by the child’s needs.

Equally important is the call for restraint in reportage. Media coverage must follow a decorum befitting matrimonial litigation and avoid sensationalising headlines when the reality is far from what the headlines portray. The judgment serves as a reminder that accuracy, not amplification, should shape public understanding of maintenance law, and that true justice requires courts and commentators alike to look beyond surface-level narratives.

By - Manasi Chaudhari