The Madhya Pradesh High Court has significantly enhanced compensation awarded to a woman in a domestic violence case, holding that prolonged deprivation of maintenance rights and years of litigation amounted to serious economic abuse. The Court increased the compensation from ₹10,000 to ₹10 lakh, observing that the earlier amount did not reflect the hardship suffered by the aggrieved woman and her daughter.
Background of the Case
The case arose from a dispute involving Smt. Chandabai and her daughter. According to the records, Chandabai had married Mayaram under Hindu customs, and a daughter was born from the marriage. She later alleged that she was subjected to domestic violence and that her husband contracted a second marriage.
During maintenance proceedings under Section 125 of the Criminal Procedure Code, a family settlement was reached in 2011. Under that arrangement, several agricultural land parcels were allotted to Chandabai in lieu of maintenance. Revenue authorities subsequently mutated her name in official records after appellate proceedings.
However, disputes over the land continued. Chandabai alleged that despite the settlement and revenue orders, she was prevented from enjoying the benefits of the land and suffered financial loss and harassment. She then sought relief under the Protection of Women from Domestic Violence Act, 2005.
The trial court partly accepted the claim and awarded ₹10,000 as compensation for mental harassment. Both sides challenged the decision before the appellate court.
While the respondents questioned the compensation itself, Chandabai sought stronger relief, including protection regarding the agricultural land and higher compensation. The appellate court eventually dismissed both appeals, leaving the trial court’s order intact.
Justice Gajendra Singh examined the history of the dispute and noted that the maintenance settlement had been reached more than a decade earlier. The Court observed that the petitioners had been allotted agricultural land as part of that settlement and that their names were subsequently entered in revenue records.
The Court further noted that later civil proceedings effectively deprived the petitioners of the benefits of the maintenance arrangement.
“The course adopted by the respondents amounts to economic exploitation of the revision petitioners and constitutes a graver form of domestic violence,” the Court observed.
The bench emphasized that compensation under the Domestic Violence Act should correspond to the nature of deprivation, the value of the property involved, and the prolonged hardship faced by the aggrieved persons.
Finding the compensation of ₹10,000 to be “wholly inadequate,” the High Court enhanced the amount to ₹10 lakh.
The Court directed respondents Nos. 1, 3 and 5 to pay the enhanced compensation within three months from receipt of the certified copy of the order. It further ordered that if the amount is not paid within the stipulated period, it will carry interest at the rate of 6% per annum until realization.
With this modification, the criminal revision petition was allowed and disposed of.
Case Details:
Case Title: Smt. Chanda Bai @ Chandarbai & Others v. Mayaram & Others
Case Number: Criminal Revision No. 3517 of 2019
Judge: Justice Gajendra Singh
Decision Date: 22 May 2026
