Final Means Final: Once Permanent Alimony is Granted, No Further Maintenance Survives: Supreme Court Declares in Divorce Case

No Maintenance Claims After Full and Final Alimony – Supreme Court in a crucial ruling made it unequivocally clear that once a lump sum permanent alimony is granted and accepted, no further claims for maintenance can survive. The Court dismissed a miscellaneous application filed by the wife seeking arrears from a pending maintenance case, holding that all disputes stood finally settled with the payment of ₹50 lakh as permanent alimony.

Justice Vikram Nath, delivering the judgment, left no room for ambiguity: “Once the lis between the parties was finally settled and permanent alimony of a lump sum amount was awarded, nothing further survives for consideration.”

The dispute arose after the Supreme Court, on May 6, 2024, granted a divorce decree in favor of the husband, Jatinder Kumar Sapra, citing irretrievable breakdown of marriage. Alongside the divorce, the Court ordered him to pay ₹50 lakh as permanent alimony, which was duly paid in full to the wife, Anupama Sapra, in five installments.

Despite receiving the full amount, the wife later approached the Court through a miscellaneous application, seeking a clarification and modification of the judgment. She argued that arrears from Maintenance Case No. 408 of 2017, pending before the Family Court, Dwarka, should also be included in the permanent alimony, and the maintenance case should be closed accordingly.

Supreme Court’s Ruling: No Further Maintenance Once Alimony is Settled

The Supreme Court dismissed the application, clarifying that once a lump sum alimony has been granted and paid, no further claims for maintenance can be entertained. The judgment categorically stated that the ₹50 lakh granted as permanent alimony was a full and final settlement of all claims, including maintenance obligations.

Justice Vikram Nath, rejecting the wife’s request, stated in clear terms: “This Court, vide its judgment dated 06.05.2024, has conclusively adjudicated all disputes between the parties, including the issue of maintenance. The permanent alimony granted constitutes the full and final settlement of all claims, leaving no scope for further claims in this regard.”

The Court further ruled that the pending maintenance case before the Family Court, Dwarka, stood closed, and any arrears arising from that case would not be included in the permanent alimony settlement.

Emphasizing the principle of finality in legal proceedings, the Court declared: “Once permanent alimony is granted as a lump sum, it extinguishes all pending claims, including those for maintenance. The law does not permit endless litigation over financial disputes between divorced spouses.”

The Supreme Court reinforced several critical legal principles in its ruling. It held that permanent alimony serves as a comprehensive financial settlement in divorce cases and is not subject to later modifications or additional claims. The Court observed that allowing further claims after a full and final settlement would defeat the very purpose of granting lump sum alimony.

Rejecting the wife's contention, the Bench clarified: "A lump sum alimony grant is meant to provide complete financial closure. It is neither open-ended nor subject to additional claims. To entertain further claims after a final settlement would be legally impermissible."

The Court also emphasized that allowing additional maintenance claims after full alimony has been paid would lead to endless litigation, which is against the spirit of divorce settlements. The judgment categorically stated: "The law does not recognize perpetual claims once a final alimony amount has been granted and accepted."

With this ruling, the Supreme Court has reaffirmed the finality and conclusiveness of lump sum alimony settlements, making it clear that once a full and final financial settlement is reached, no further claims for maintenance can survive. The ruling ensures that divorced spouses cannot re-litigate financial disputes under the guise of pending maintenance cases.

Justice Vikram Nath, delivering the final verdict, declared: “The final order of maintenance passed by this Court shall be the full and final adjudication of any maintenance proceedings between the parties, leaving no scope for further claims in this regard.”

By dismissing the wife's application, the Supreme Court has established an important precedent in family law, safeguarding divorced individuals from endless financial disputes and ensuring that once a settlement is reached, it remains binding and conclusive.

Date of Decision: 17/02/2025