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The Madras High Court declined to interfere with a Family Court’s interim maintenance award under Section 24 of the Hindu Marriage Act. The Court emphasised that Article 227 is supervisory, not an ordinary appeal permitting routine reassessment of every factual or monetary finding.

Case Details

Case — C. Hariharan v. M. Sowmya and Minor Child | C.R.P. No. 2754 of 2025

Court — High Court of Judicature at Madras - Principal Bench, Chennai

Date of Order — 29 October 2026

Judge / Bench — Justice N. Anand Venkatesh

Neutral Citation — Not specified in verified order text

Relevant Provisions — Section 24 Hindu Marriage Act, 1955; Article 227 of the Constitution of India

Result — Civil revision dismissed; interim maintenance of Rs 20,000 to wife and Rs 7,000 to minor child left undisturbed.

Family Court order

In H.M.O.P. No. 3893 of 2021, the wife sought divorce and interim maintenance. The Family Court directed Rs 20,000 monthly to the wife and Rs 7,000 to their minor child.

The husband’s challenge

The husband appeared in person, did not object to child support of Rs 7,000, but argued that his income was only about Rs 35,000 monthly and that the wife’s maintenance was excessive.

Evidence before Family Court

The High Court noted assets-and-liabilities material and documents pointing to the husband’s resources. The parties’ submissions also referred to his subsequent marriage and messages concerning support.

Scope of Article 227

Justice N. Anand Venkatesh explained that supervisory interference ordinarily requires jurisdictional failure, excess of jurisdiction or perversity; it does not invite fresh estimation of a reasonable interim amount as an appellate exercise.

Outcome

The civil revision was dismissed. Although the High Court commented on the reasoning of the Family Court’s monetary assessment, it found no basis to upset the interim order in the husband’s revision.

Key Legal Questions

• What is the scope of supervisory review under Article 227?
• How should interim maintenance evidence be assessed?
• Can the High Court re-evaluate the amount as if hearing an appeal?

Legal Takeaways

• Article 227 provides limited supervisory correction rather than a full rehearing.
• Interim awards may rely on approximate assessment of prima facie income evidence.
• The court must distinguish between the claims of spouse and minor child.

Practical Guidance for Advocates and Litigants

• Produce income records and liabilities properly rather than relying on an unsupported salary assertion.
• In a revision petition, identify perversity or a jurisdictional error with precision.
• Remember that the appellate forum cannot necessarily enhance maintenance in a challenge filed by only the paying spouse.

Frequently Asked Questions

How much monthly interim maintenance was upheld?

Rs 20,000 for the wife and Rs 7,000 for the minor child.

Does Article 227 allow automatic re-calculation?

No. Supervisory jurisdiction is limited and ordinarily requires a recognised error.

Does this conflict with Raguram v Bhuvana?

No. The cases involved different facts and financial material, leading to different results.

Conclusion

The decision illustrates why the facts, precise statutory provision and relief granted must be read together. Civil revision dismissed; interim maintenance of Rs 20,000 to wife and Rs 7,000 to minor child left undisturbed.

Official Court Source

C. Hariharan v. M. Sowmya and Minor Child | C.R.P. No. 2754 of 2025. Date: 29 October 2026. Use case number for official lookup.

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Disclaimer: This is an original educational case analysis. It is not a substitute for the original order, current case status or case-specific legal advice.