The Execution Gap: An Empirical and Doctrinal Analysis of Rajnesh v. Neha Guidelines in Curbing Delays and Litigation Costs in Indian Maintenance Law | Authored by: Anshita Verma | Volume VI Issue III |

Abstract

In 2020, the Supreme Court of India tried to fix the broken system of matrimonial maintenance with its ruling in Rajnesh v. Neha. They used their powers under Article 142 of the Constitution to set up a five-part system. This move was supposed to make sure women actually received the financial support they were promised instead of getting stuck in years of court battles. The plan focused on five main goals: stopping cases from overlapping in different courts, setting strict deadlines for temporary relief, making everyone show their real finances with an affidavit, starting payments from the day of the application, and finding ways to force people to pay when they refuse.

This research looks at how these rules are working now, especially as India moves from the old Section 125 of the Criminal Procedure Code to Section 144 of the new Bharatiya Nagarik Suraksha Sanhita (BNSS). To see if anything changed, I looked at data from the National Judicial Data Grid, the DAKSH India database, and court orders from 2025 and 2026. This included Supreme Court cases like Deepa Joshi v. Gaurav Joshi and the Allahabad High Court’s ruling in Nirmal Kumar Fukan. The numbers show a bleak reality. Lower courts are still struggling with nearly 48 million cases. The four-to-six-month window for temporary relief is almost never met. Most judges still just guess how much money someone has instead of using the financial disclosures the Supreme Court ordered.

There is a major gap in the law because the new BNSS does not include the requirement for an “Affidavit of Assets and Liabilities” in the actual text of the statute. Since it is just a court rule and not a law passed by parliament, people do not take it as seriously. This makes it harder to punish people for lying about their money under Section 227 of the Bharatiya Nyaya Sanhita. Also, Section 144 of the BNSS left out the word “minor” when talking about children. This change might expand who can ask for support, but we are still waiting to see how higher courts interpret it.

Scholars like Flavia Agnes and Saptarshi Mandal argue that these reforms fail because they do not address deeper problems. Our courts lack resources and the system still favours men who have more money and better lawyers. Even though the law now recognizes the “caregiver penalty”the fact that a mother loses out on income while raising kidsjudges do not have a clear way to calculate that loss. Most trial courts just go back to giving out the bare minimum needed for a person to survive.

To fix this, I suggest five specific changes. First, the requirement for financial affidavits must be written directly into Section 144 of the BNSS. Second, the whole country should adopt the “Allahabad model.” In this system, courts have to audit their own cases and report on whether they are following the rules. Third, we need a way to value unpaid housework and childcare so the amount isn’t just based on a minimum wage. Fourth, the National Legal Services Authority needs to make these cases a priority and help pay for lawyers so both sides have a fair chance. Finally, if we ever use AI to help decide payment amounts, the system must explain exactly how it reached its numbers.

The failure to enforce maintenance laws in India is not something we have to accept. It happens because of specific choices made by our institutions, and we can change it. Closing this gap requires the legislature, the government, and the judges to work together. Without a real plan to turn these rules into law and hold people accountable, the promise of living with dignity will not mean much for the people who need it most.

Chapter 1: Introduction

1.1 Background of the Study and the Legal Crisis

Legal fights over maintenance in India usually come down to a clash between the high ideals of the Constitution and the messy reality of slow, crowded courts (Verma, 2026). Maintenance laws were meant to be urgent tools for social justice. They exist to stop people from falling into poverty, yet they operate in a confusing mix of different rules and statutes (Verma, 2026). The law is supposed to protect women and children, as seen in Article 15(3) and the directive principles of Article 39. However, the actual experience of going to court often involves years of waiting and high costs that ruin the point of the law in the first place (Verma, 2026).

Before 2020, the legal system for maintenance was a maze of religious laws and general codes. Someone needing supportusually a wifecould have three different cases going at the same time. They might use Section 125 of the Code of Criminal Procedure, the Hindu Marriage Act, and the Domestic Violence Act all at once (Verma, 2026). This overlap allowed lawyers to drag out cases or get conflicting orders. It often left vulnerable people trapped in a cycle of poverty and legal bills (Verma, 2026).

The Supreme Court tried to fix this with the 2020 case Rajnesh v. Neha. The court used its powers under Article 142 to set clear rules for the whole country. These rules were meant to stop people from filing in too many courts and set strict deadlines for finishing cases. They also made it mandatory for both sides to prove their income with financial affidavits and set clear rules on when payments should start and how to make people pay (Verma, 2026).

1.2 Statement of the Problem: The Persistence of the Execution Gap

The main problem this research looks at is the “execution gap.” This is basically the failure of local courts to actually follow the Rajnesh rules (Verma, 2026). Even though the 2020 framework is smart on paper, data from 2023 to 2026 shows it is not working as intended (Prime Legal, 2026).

You can see this failure in a few ways. First, Family Courts often pass orders without checking the mandatory financial affidavits. The Supreme Court noted this failure in the 2023 case Aditi v. Jitesh Sharma. Second, while the rules say these cases should wrap up in four to six months, they often take years (Verma, 2026). Third, since much of India’s economy is informal, people find it easy to hide their money, which makes the affidavits less useful. Finally, wealthy spouses often use expensive appeals to tire out the other side until they run out of money (Verma, 2026).

1.3 Research Objectives and Methodology

This study uses a mix of legal analysis and hard data. I want to look at the Rajnesh rules, use court data from 2025 and 2026 to show where they fail, and see how much this costs the people involved. The numbers come from the National Judicial Data Grid and reports by DAKSH India. I also look at recent rulings like the 2026 Supreme Court decisions in Deepa Joshi v. Gaurav Joshi and XXX v YYY (Verma, 2026).

The research works on four levels. I start with the laws themselves, like the Hindu Marriage Act and the new criminal code, the BNSS, to see what the standard should be. Then I look at court backlogs and how long these “temporary” relief cases actually take in practice (Verma, 2026). I also use case studies from the last two years to show where judges have ignored the rules (Prime Legal, 2026). Finally, I use theories from scholars like Flavia Agnes and Saptarshi Mandal to explain why these structural problems keep happening (Verma, 2026).

1.4 Significance and Scope of the Study

This work is meant for the people who make policy and train judges. By showing exactly where the system breaks down, it gives the Judicial Training and Research Institutes a path for reform, especially as India moves to the new BNSS laws (Verma, 2026). The timing is urgent. In early 2026, the Supreme Court had over 93,000 pending cases(Supreme Court Observer, 2026b). Lower courts were dealing with 48 million cases, which is an 85 percent jump over the last decade(Data for India, 2026)

This study focuses on the years 2024 to 2026 to see how the new legal changes are playing out. I look at the whole country but pay extra attention to places like Delhi, Uttar Pradesh, and Maharashtra where the court backlogs are worst (Verma, 2026). The longer we wait to fix this gap, the further we get from the promise of dignity written in the Constitution.

In short, this chapter has explained where the Rajnesh rules came from and why they are failing in practice. The chapters that follow will look at the new criminal laws, analyze the data on how courts are performing, and offer real solutions for reform.

Chapter 2: Legal Framework and the BNSS Transition

2.1 The basic ideas behind maintenance: Social Justice versus Civil Rights

Maintenance law in India started as a colonial rule to stop people from wandering the streets without money. Since then, it has changed into a focus on human dignity (Verma, 2026). In the past, Section 125 of the old code was a welfare tool meant to stop women and children from needing state support (Verma, 2026). Scholars like Archana Parashar argue that we should instead see maintenance as a civil right. This view recognizes marriage as an economic partnership (Parashar & Dhanda, 2016; Verma, 2026).

Under this civil-right model, maintenance is not a gift or charity for a wife. It is a way to recognize her unpaid work. It ensures she can keep the same standard of living she had during the marriage (Verma, 2026). The court in Rajnesh v. Neha (2020) tried to balance these two ideas. The ruling required people to show their actual finances while keeping the legal process fast and simple (Verma, 2026).

2.2 Moving from the CrPC to the BNSS, 2023

Replacing the old 1973 code with the Bharatiya Nagarik Suraksha Sanhita (BNSS) in 2023 changed how Indian criminal procedures work (Tripathi & Singh, 2026). Section 144 of the BNSS keeps the main duty to pay maintenance. However, it makes a few small but important changes to the wording and how cases are handled (Sheokand Legal, 2026).

2.2.1 Removing the word “Minor”

One big change in Section 144 is that the law no longer uses the word “minor” when talking about children (Joshi, 2024). Under the old law, children usually only got support if they were under 18, unless they had a physical or mental disability (Joshi, 2024). Now, Section 144(1)(b) says a child can claim maintenance whether they are married or not, as long as they cannot support themselves (Joshi, 2024). In 2026, courts like the one in Mohammed Abuzar v. Mohammed ArzulKamar suggested that this change expands the law. It might now cover adult children, such as unmarried daughters or sons still in school, who depend on their parents.

2.2.2 The sixty-day goal and reality

The BNSS says that courts should finish interim maintenance cases within sixty days of the notice “as far as possible” (Tripathi & Singh, 2026). Lawyers and scholars often argue about that phrase “as far as possible” because it makes the deadline optional. Data from early 2026 shows that courts rarely meet this goal. The National Judicial Data Grid found that one in three cases in lower courts has been stuck for more than five years (Data for India, 2026). Without a way to force courts to move faster, this timeline is just a wish (Verma, 2026).

2.3 The missing rules and the financial affidavit

A major issue found in this study is that the government did not include the Rajnesh financial affidavit in the actual text of the BNSS (Verma, 2026). The Supreme Court made this affidavit a requirement, but it is still a judge-made rule rather than a part of the written law (Sharma, 2026). This creates two main problems.

First, there is no real fear of punishment. Because the rule is not in the statute, trial courts are often afraid to punish people who lie on their financial forms under Section 227 of the Bharatiya Nyaya Sanhita (Sharma, 2026). Second, enforcement is inconsistent. Different High Courts handle the affidavit differently. This creates unequal justice based on where a person lives. A person’s ability to see their spouse’s real finances depends on which court hears their case (Verma, 2026).

2.4 Comparing different laws

Right now, a person needing support can look at several different laws. These rules often overlap. The table below shows how these laws work together in 2026 (Verma, 2026).

When you look at these laws together, they create a system where a spouse can try different legal paths. In reality, having so many options often leads to people filing cases in multiple courts at once. The Rajnesh ruling tried to fix this by requiring people to disclose any other cases they have filed. The next chapter looks at how well this system actually works, including the data on delays and court warnings.

Chapter 3: How the Rajnesh v. Neha Rules Work in Practice

3.1 The Facts That Started the Reform

The Rajnesh v. Neha case grew out of a seven-year legal mess. This struggle showed the exact problems the Supreme Court wanted to fix. In 2013, the wife asked for interim maintenance, but the Family Court took two years just to finish that single application. By the time the Supreme Court set its new rules in 2020, the children of the marriage had grown from babies to school students (Verma, 2026). They spent those years without any certainty that they would receive money for food or clothes. The Supreme Court saw this delay as a normal part of Indian law rather than a one-time mistake (Verma, 2026). This realization led to the five-pillar plan.

3.2 Testing the Five Pillars in 2025 and 2026

3.2.1 Pillar I: Overlapping Courts and the Set-Off Rule

The first pillar tries to stop the confusion caused when people file cases in different courts at the same time to get extra money. The Supreme Court said that anyone in a case must list every other legal action they have started (Verma, 2026). This allows judges to adjust payments so no one gets paid twice for the same thing. In 2026, High Courts followed this rule closely. The Delhi High Court used it in Tasmeer Qureshi v. Asfia Muzaffar(Delhi High Court, 2025). The judges said this rule stops people from getting unfair extra money. It also makes sure the spouse who needs help gets the highest amount they are legally allowed to receive.

3.2.2 Pillar II: The Broken Timeline

The rules say courts should decide on maintenance within four to six months (Verma, 2026). Data from early 2026 shows this is not happening. Instead of getting smaller, the pile of unfinished cases is growing (Supreme Court Observer, 2026b). The table below shows the gap between the rules and what actually happens in court.

When timelines fail, the spouse who has no money suffers the most (Verma, 2026). Waiting years for a judge to decide means years of debt or poverty. The number of cases at the top level rose again in January 2026(Supreme Court Observer, 2026a). This makes it even harder for local courts to finish their work on time.

3.2.3 Pillar III: The Asset Form and the Guesswork Issue

The Court created a standard form for assets and liabilities to find hidden bank accounts or property. But not every local judge uses it (Verma, 2026). In the 2023 case Aditi v. Jitesh Sharma, the Supreme Court noticed that many trial courts still guessed the amount of money a person should pay. They did not ask for the required forms (Verma, 2026). Another problem is the informal economy. Many people in India work for cash or own unregistered businesses. This makes it easy for them to hide their true income on paper (Verma, 2026).

3.2.4 Pillar IV: When Payments Begin

The fourth rule says maintenance starts on the day the person first asks for it. Before this, different courts started payments on different dates. The goal was to stop people from stalling the case. If a person delays, they just end up owing more money at the end(Verma, 2026). Most judges now follow this. Still, some try to avoid paying. In the 2026 case Deepa Joshi v. Gaurav Joshi, a husband tried to lower his debt by claiming he had to pay back loans first (Prime Legal, 2026). The Supreme Court said no. Supporting a spouse is more important than paying off a loan for a new house or car.

3.2.5 Pillar V: Forcing People to Pay

Collecting money is the hardest part of these rules. In a 2026 case, XXX v. YYY, the husband was a lawyer. He started over eighty different legal actions against his wife. This made it impossible for her to get her money for almost ten years (SCC Online, 2026). If judges do not use tools like arresting the person or stopping their legal defense, the court order is just a piece of paper. This type of legal war turns a simple case into a contest of who can last the longest. The spouse without money almost always loses.

3.3 Warnings from the Courts in 2026

High Courts are reacting to these delays. In 2025, the Allahabad High Court did something rare. In Nirmal Kumar Fukan v. State of U.P., they ordered every Family Court judge in the state to send secret reports on their work (LegitQuest, 2025). The High Court saw that trial judges were ignoring the rules about asset forms(Verma, 2026). This confirms that there is a big gap between the law and reality. Even though the Supreme Court has been clear, the culture in local courts has not changed yet.

The facts from all five pillars show a big problem. The Supreme Court has high goals, but local courts do not have enough staff or resources to meet them. The data on case loads and the way people ignore the rules show this is a common pattern, not a small mistake. Chapter 4 looks at why these patterns continue.

Chapter 4: Social Impact and Theory

4.1 The Price of Legal Delays

The gap between a court order and actual payment creates a situation often called a winner’s curse. Even when a wife eventually wins a favorable order, she has frequently spent more on legal fees and travel than the money she actually receives (Verma, 2026). This isn’t an accident. It happens because of the financial gap between the two sides. The husband usually has plenty of cash, while the wife’s access to family funds often stops the moment the marriage breaks down.

4.1.1 Unfair Legal Resources

Fairness in court requires that both sides have a real chance to present their case without one person being at a total disadvantage (Goss, 2014). In maintenance cases, this balance fails. A wealthy husband can pay for endless delays and a series of legal challenges (Verma, 2026). The wife, who is usually looking after the children, often runs out of money before the first six months of the case are over (Verma, 2026). The system ends up rewarding the person who can afford to wait the longest.

4.1.2 Counting the Costs

The costs for a wife fall into two groups. First, there is the direct money paid to lawyers, bus fares to the courthouse, and court filing fees (Verma, 2026). Then there are the hidden costs. Women lose wages when they take time off work for hearings. They also face a career penalty for years spent out of the workforce. The mental strain eventually pushes many women to accept a settlement that is only a tiny fraction of what the law says they deserve (Verma, 2026). They settle just to make the fighting stop.

4.2 The Cost of Raising Children

The Rajnesh rules say that a woman who gives up her career to raise children loses money over the long term. Courts must look at this when they decide how much maintenance to award (Verma, 2026). The Delhi High Court noted in 2025 that this loss is real and measurable. However, judges still struggle to put a clear price on these lost years.

Research from 2025 and 2026 shows that mothers earn less money throughout their entire lives because of the time they spend on childcare (Minnesota Women Lawyers, 2020). Although the Rajnesh guidelines say judges must consider this, many trial courts ignore it. They go back to the old way of thinking, giving out just enough money to prevent starvation rather than providing a fair share (Verma, 2026).

4.3 Theoretical Views on the Law

4.3.1 Flavia Agnes: Maintenance as a Right

Flavia Agnes argues that maintenance is not a favor or a gift; it is a right (Bhardwaj, 2021). She points out that some laws still judge women based on their “morality.” For example, Section 144(4) of the BNSS says a wife gets nothing if she commits adultery. Agnes says this treats women like property instead of equal partners in a marriage (Verma, 2026). She believes these laws only work if the justice system is affordable and the judges actually understand the struggles women face.

4.3.2 Archana Parashar: Hidden Wealth

Archana Parashar has a harsher view. She says that new rules like Rajnesh won’t work because the underlying property laws still favor men (Verma, 2026). She points to “ancestral property” as a way for men to hide their wealth so it doesn’t show up on court affidavits. Even if the law says a wife has a right to be supported, it does not give her a right to own a share of the family’s assets. Because of this, procedural changes can only do so much to help (Verma, 2026).

4.3.3 Saptarshi Mandal: The Delay Trap

Saptarshi Mandal looks at how court procedures can be used as weapons (Verma, 2026). The Rajnesh guidelines were a creative step by the Supreme Court, but they created a dilemma for local judges. A judge has to balance a husband’s right to a fair trial against a wife’s need to buy food and pay rent today (Verma, 2026). Mandal argues that complex rules actually help the side with more money. They can use the complicated paperwork requirements to create even more delays. Without better staff and resources at the local level, sophisticated legal rules might actually make inequality worse.

These three perspectives lead to the same conclusion. The gap between the law and reality exists because of old social structures, a lack of court resources, and a property system that refuses to let women own assets.

Chapter 5: Reform Recommendations and Conclusion

5.1 What the Evidence Shows: The Execution Gap

This study began with the theory that the Rajnesh v. Neha (2020) guidelines have failed to close the gap between legal theory and what actually happens in court. Four specific lines of evidence prove this is true.

First, the data shows that courts are simply not following the rules for financial disclosure. In 2023, the Supreme Court noted in Aditi v. Jitesh Sharma that trial courts are still ignoring the requirement for an Affidavit of Assets and Liabilities. This means the most important procedural tool in the Rajnesh framework is not being used by lower-level judges (Verma, 2026). Second, the promise of getting relief within four to six months is basically a myth for most people. National records show a backlog of forty-eight million cases in lower courts as of 2026 (Data for India, 2026).

Third, wealthy litigants are using legal procedures as a weapon to drag out cases. In the case of XXX v. YYY (2026), the Supreme Court saw one party start over eighty separate legal proceedings just to avoid paying maintenance (SCC Online, 2026). Finally, there is a major structural problem. The Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, did not turn the affidavit requirement into a law. Because of this, the Rajnesh rules remain a court-made tool rather than a legal obligation that everyone must follow (Sharma, 2026).

5.2 Practical Recommendations for Reform

5.2.1 Changing the Law: BNSS and BNS

The most important step is to make the Affidavit of Assets and Liabilities a part of the actual law (Verma, 2026). Parliament should change Section 144 of the BNSS to make this affidavit a mandatory step (Sharma, 2026). This change would do two things. It would make the rules the same in every High Court and give trial judges a clear legal reason to demand these documents before they decide on payment amounts.

Parliament should also add a clear link to Section 227 of the Bharatiya Nyaya Sanhita. This would ensure that lying about money in a maintenance case is treated as perjury, exactly like lying in any other criminal trial (Sharma, 2026). Without this threat, the affidavit will stay a mere formality instead of a real tool for transparency.

5.2.2 Training Judges and Holding Them Accountable

Changing the law only works if the courts change how they operate. Training institutes should use the “Allahabad model” seen in Nirmal Kumar Fukan v. State of U.P. (2025) (Verma, 2026). This model has three parts that should be used across India. First, Family Court judges should need a formal certificate to prove they understand the Rajnesh framework (Verma, 2026). Second, there should be regular audits of maintenance orders. These audits would check that judges are using real financial data rather than vague guesses to set payment amounts (LegitQuest, 2025). Third, Principal Judges should have to file “sealed-cover” reports to prove that the Rajnesh rules are being followed in their districts (LegitQuest, 2025).

5.2.3 Fixing the Caregiver Penalty

The courts need a reliable way to calculate the cost of unpaid care work. The judiciary should create a standard matrix to value this work (Verma, 2026). Right now, many trial courts just fall back on minimum wage levels. A proper matrix would account for lost career opportunities and the “human capital” that a mother or caregiver loses when they stay home (Prime Legal, 2026). Putting this matrix into a formal practice direction would stop the massive differences we currently see in how much money is awarded from one court to the next.

5.2.4 Better Legal Aid and Fairer Trials

There is a huge gap between the money a wealthy spouse has and the resources available to a dependent spouse. The state needs to step in. The National Legal Services Authority should provide experts to help people write their financial affidavits (Verma, 2026). The quality of this document often determines if a person wins or loses their case at the very start.

Courts should also use Legal Services Payment Orders more often. These orders force the wealthier spouse to pay for the other person’s legal costs while the case is still going (Stewarts Law, 2024). This is common in other countries and it helps make sure both sides have a fair chance. There is no reason why Indian courts cannot do the same under Section 144 of the BNSS.

5.2.5 The Role of AI and SUPACE

New tools like the SUPACE portal show that artificial intelligence will soon help manage the heavy workload in our courts (IJLRA, 2026). These tools might help clear the backlog, but they also bring risks. AI systems can be biased and might suggest lower payments for women from poor or marginalized backgrounds (IJLRA, 2026). If AI is used to help set maintenance amounts, the law must require “explainability.” Judges must be able to see exactly how the AI made its decision and they must have the power to ignore the AI if the result is unfair (IJLRA, 2026).

5.3 Final Reflections

The Rajnesh v. Neha (2020) decision was an ambitious attempt to fix a broken system. The Supreme Court tried to use its special powers to create a modern and humane blueprint for maintenance law (Verma, 2026). But six years later, the gap between that plan and reality is still huge. Judicial creativity is not enough on its own to change how the whole system works.

Closing this gap requires the legislature, the government, and the courts to work together. Parliament needs to fix the gaps in the BNSS, especially regarding the affidavit and perjury rules. The government has to fund the Family Court system properly. We cannot expect progress when the system is understaffed and facing a backlog of forty-eight million matters (Data for India, 2026). Finally, judges must hold themselves accountable for following the Supreme Court’s instructions (LegitQuest, 2025).

The move to the new BNSS laws in 2023 is a perfect chance to fix these mistakes (Joshi, 2024). Parliament can still amend Section 144. The courts can adopt the Allahabad reporting model nationwide. If these groups do not act together, the right to maintenance will remain a “winner’s loss.” For many women, it is just a long and ruinously expensive fight. Making the law match the guidelines is the only way to ensure that the constitutional promise of dignity actually reaches the people who need it.

This study shows that the failures in our maintenance laws are not inevitable. They are the result of specific choices, and they can be fixed with specific reforms. These recommendations are based on hard evidence and are ready to be put into practice. They will not solve every inequality in Indian marriages, but they will certainly help close the gap between the promise of Rajnesh and the difficult reality of the people it was meant to protect.

References

Bhardwaj, S. (2021). Morality, dependency and maintenance: Plight of women under Hindu law. Journal of Legal Studies & Research. https://journal.thelawbrigade.com/jlsr/article/view/2021

Data for India. (2026). Judicial pendency in India. https://www.dataforindia.com/pendency/

Delhi High Court. (2025, October 29). Tasmeer Qureshi v. Asfia Muzaffar [Judgment dated 29-10-2025, CRL.M.A. 123/2024]. https://delhihighcourt.nic.in/app/showFileJudgment/SKS29102025CRLRMAT1232024_200006.txt

Goss, R. (2014). Chapter 2: Equality of arms. ResearchGate. https://www.researchgate.net/publication/368198262_Chapter_2_-_Equality_of_Arms

IJLRA. (2026). Indian Journal of Legal Research and Advancements, 3(2). https://www.ijlra.com/uploads/866136232.pdf

Joshi, P. (2024). Maintenance under BNSS, omission of word ‘minor,’ a major change. LiveLaw. https://www.livelaw.in/articles/maintenance-under-bnss-omission-word-minor-major-change-295467

Lawsathi Consulting. (2026). New Maintenance Act and alimony. https://lawsathi.com/new-maintenance-act-and-alimony/

LegitQuest. (2025, May 12). Nirmal Kumar Fukan v. State of U.P. and 3 others. https://www.legitquest.com/case/nirmal-kumar-fukan-v-state-of-up-and-3-others/1D65C97

Minnesota Women Lawyers. (2020). Out of the black box: Highlighting central myths of gender pay disparity in the legal profession in 2020. https://mwlawyers.org/page/WERDec2020Feat7

Parashar, A., & Dhanda, A. (2016). Redefining family law in India. Routledge.

Prime Legal. (2026). [2026 SC] Loan repayments don’t reduce wife’s maintenance. Prime Legal Blogs. https://blog.primelegal.in/bnss-144-maintenance-loan-deductions-sc-ruling/

SCC Online. (2026, April 9). Supreme Court quashes over 80 cases; grants divorce. SCC Times. https://www.scconline.com/blog/post/2026/04/09/supreme-court-quashes-over-80-cases-divorce-article-142/

Sharma, R. (2026). Factual and legal impact of affidavit disclosure in maintenance proceedings: A study in light of Rajnesh v. Neha. ResearchGate. https://www.researchgate.net/publication/400713632

Sheokand Legal. (2026). Section 144 of BNSS. https://sheokandlegal.com/articles/section-144-of-bnss/

Stewarts Law. (2024). Family court considers whether post-separation bonus forms matrimonial property and reviews child maintenance in shared care cases. https://www.stewartslaw.com/news/family-court-considers-whether-post-separation-bonus-forms-matrimonial-property-and-reviews-child-maintenance-in-shared-care-cases/

Supreme Court Observer. (2026a, January). January 2026: Pendency increases by 510 cases. https://www.scobserver.in/journal/january-2026-pendency-increases-by-510-cases/

Supreme Court Observer. (2026b, March). March 2026: Pendency increases to over 93,000 cases. https://www.scobserver.in/journal/march-2026-pendency-climbs-to-over-93000-cases/

Tripathi, S., & Singh, R. (2026). Maintenance under Section 144 of Bharatiya Nagarik Suraksha Sanhita, 2023: A complete guide. Legal Kart. https://www.legalkart.com/legal-blog/maintenance-under-section-144-of-bharatiya-nagarik-suraksha-sanhita-2023-a-complete-guide

Verma, A. (2026). Dissertation Anshita Verma A032134721053 [Unpublished dissertation].