Introduction:

In a significant ruling addressing the evidentiary value of self-declared information on matrimonial websites, the Delhi High Court recently observed that any declaration regarding income on such portals, without corroborative proof, cannot be treated as reliable or admissible evidence in maintenance proceedings. The judgment was delivered by Justice Swarana Kanta Sharma in the matter titled A v. B, where the Court dismissed a wife’s appeal challenging a family court’s maintenance determination. The wife had argued that the husband, while registering on the matrimonial portal Jeevansathi.com, had declared an annual income exceeding ₹10 lakhs, which should have influenced the computation of maintenance. The Court, however, emphasized that matrimonial portals do not verify income details, and therefore, self-declared figures lack legal sanctity. This case also gained attention due to the wife’s remarriage during the pendency of proceedings, which she failed to disclose in her cross-examination, leading the Court to question her credibility and bona fides. The decision underscores the necessity for documentary evidence in matrimonial litigation and discourages speculative assumptions regarding income growth over time.

Arguments by the Appellant (Wife):

The appellant-wife contended that the family court erred in granting maintenance at ₹12,500 per month from the date of filing the petition until December 31, 2012, and ₹24,000 per month from January 1, 2013, until February 22, 2016—the date of her remarriage. According to her, the award did not adequately reflect the financial capacity of the husband. She asserted that the husband, while creating his matrimonial profile on Jeevansathi.com, had declared his annual income to be more than ₹10 lakhs. This, she argued, was an admission by the husband and should have been treated as credible evidence for determining maintenance.

The wife further argued that the husband’s income must have increased significantly over the years, given the general trend of salary increments in corporate and business sectors. She urged the Court to adopt a realistic approach that considers inflationary trends and rising living standards. Her contention was that the family court failed to adopt a progressive outlook by ignoring the husband’s declared earning capacity and by restricting the quantum of maintenance without accounting for possible income growth.

Additionally, the appellant emphasized that maintenance under Section 125 CrPC or related provisions aims to secure a dignified life for the dependent spouse and cannot be determined mechanically. She contended that courts should consider lifestyle, social status, and projected earning capacity while awarding maintenance, particularly when the husband himself has represented a substantial income in the public domain through a matrimonial portal.

Arguments by the Respondent (Husband):

The respondent-husband countered these arguments by contending that the wife’s reliance on a matrimonial portal profile was wholly misplaced and devoid of evidentiary value. He maintained that the self-declared figures on websites like Jeevansathi.com are not verified by the portal or any authority, and therefore, cannot constitute admissible proof in a court of law. The respondent stressed that matrimonial profiles are created for personal introduction purposes and often contain exaggerated claims to enhance prospects of marriage; thus, treating such declarations as evidence would amount to endorsing unverified assertions.

The husband further argued that the wife had failed to produce any corroborative material, such as salary slips, income tax returns, or bank statements, which could substantiate her claim regarding his income. He pointed out that maintenance cannot be decided based on conjecture or assumptions and that the burden of proof lies on the claimant.

Additionally, the respondent highlighted that the wife had remarried during the pendency of the proceedings in 2016, a fact she concealed during her cross-examination in 2023. This suppression of material facts, according to the husband, demonstrated mala fide intent and disqualified her from seeking any further enhancement of maintenance. The husband also rejected the argument regarding presumed income growth, stating that career trajectories differ widely and economic fluctuations can affect earning patterns.

Court’s Analysis and Judgment:

Justice Swarana Kanta Sharma commenced her analysis by reaffirming the principle that maintenance is intended to provide financial support to a dependent spouse but must be determined based on verifiable evidence rather than speculation. Addressing the appellant’s reliance on the matrimonial portal declaration, the Court held that such information, being self-declared and unverified, lacks probative value.

The Court observed:

 “Any self-declared information made on a matrimonial portal, without verification or corroborative evidence, cannot be treated as reliable or admissible proof of income. A court of law cannot rely upon a declaration made by a person on a matrimonial website.”

The Court underscored that matrimonial websites function as private platforms for personal matchmaking and do not authenticate financial details. Therefore, permitting such unverifiable assertions to influence judicial determination would not only undermine evidentiary standards but also open floodgates for misuse.

On the appellant’s plea to presume an upward trajectory in the respondent’s income over the years, the Court rejected the contention as speculative, observing:

 “Income trends can vary depending on various personal and professional circumstances, and cannot be presumed to have followed a linear upward trajectory without any documentary proof.”

The Court took serious note of the wife’s concealment of her remarriage during cross-examination, terming it a significant lapse. It held that once a spouse remarries, entitlement to maintenance ceases from the date of remarriage, as recognized under matrimonial and maintenance laws. This concealment cast doubts on the appellant’s bona fides and weakened her plea for enhancement.

The Court upheld the family court’s order granting maintenance of ₹12,500 per month up to December 31, 2012, and ₹24,000 per month from January 1, 2013, until February 22, 2016, noting that the computation was fair and based on evidence available on record. Concluding that there was no error or perversity in the impugned order, the High Court dismissed the appeal.