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Issues: (i) whether the High Court could invoke inherent jurisdiction to interfere with concurrent orders granting maintenance after dismissal of a revision under the revisional scheme of the Code; (ii) whether the wife's statements that she left the matrimonial home voluntarily and earned some income were enough to deny maintenance under Section 125 of the Code of Criminal Procedure, 1973.
Issue (i): whether the High Court could invoke inherent jurisdiction to interfere with concurrent orders granting maintenance after dismissal of a revision under the revisional scheme of the Code.
Analysis: The revisional bar against a second revision cannot be circumvented by resort to inherent powers except in rare and exceptional cases. Such power is available only to prevent abuse of process of court or failure of justice. The jurisdiction under Section 482 is not meant to override an express statutory bar where no exceptional circumstance is shown.
Conclusion: The High Court was not justified in interfering on this basis.
Issue (ii): whether the wife's statements that she left the matrimonial home voluntarily and earned some income were enough to deny maintenance under Section 125 of the Code of Criminal Procedure, 1973.
Analysis: A wife's right to claim maintenance continues unless one of the disqualifying conditions under sub-section (4) of Section 125 is attracted. Mere assertion that she left the matrimonial home voluntarily, or that she had some earning from agricultural work, without more, does not by itself defeat the statutory entitlement. On the findings recorded by the courts below, the disqualifying provision was not attracted.
Conclusion: The wife was entitled to maintenance and the order granting maintenance could not be upset.
Final Conclusion: The maintenance order was restored and the High Court's interference was set aside, leaving the wife's entitlement to maintenance intact.
Ratio Decidendi: Inherent jurisdiction cannot be used to circumvent the statutory bar on a second revision except in exceptional cases involving abuse of process or failure of justice, and a wife's maintenance under Section 125 cannot be denied merely because she left the matrimonial home or had some earnings unless a statutory disqualification is established.