DUKHTARJAHAN versus MOHAMMED FAROOQ

DUKHTARJAHAN versus MOHAMMED FAROOQ

The High Court erred in quashing maintenance for the child based on the alleged timing of birth; Section 112 creates a presumption of legitimacy for a child born in wedlock unless it is shown that the husband and wife had no access; evidence and conduct of parties do not rebut this presumption. Maintenance order should be sustained and the respondent may seek declaration in civil court if desired.

Parties
Appellant: Dukhtar Jahan; Respondent: Mohammed Farooq
Jurisdiction
India
Judgment Date
20 January 1987
Procedural Posture
Criminal Appeal / Appeal From High Court Judgment
Outcome
Appeal allowed
Legal Topics
Maintenance for Child, Legitimacy, High Court Powers Under Section 482 Cr PC

Case Brief

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Parties

Dukhtar Jahan

Appellant

Mohammed Farooq

Respondent

Procedural Posture

Criminal Appeal / Appeal From High Court Judgment

  1. 1 Whether High Court can interfere with concurrent findings under Section 482 CrPC
  2. 2 Presumption of legitimacy under Section 112 Evidence Act
  3. 3 Maintenance entitlement of child born during marriage

Ratio Decidendi

The High Court erred in quashing maintenance for the child based on the alleged timing of birth; Section 112 creates a presumption of legitimacy for a child born in wedlock unless it is shown that the husband and wife had no access; evidence and conduct of parties do not rebut this presumption. Maintenance order should be sustained and the respondent may seek declaration in civil court if desired.

Court Disposition

Appeal allowed

Orders

  • Order of High Court quashing maintenance set aside
  • Trial court order granting maintenance restored