A single judge of Allahabad bench of Allahabad High Court held as follows on two aspects,

From Paras 9 to 11, (Failed to prove that Wife was ‘unable to maintain herself‘)

9. From the perusal of Section 125 Cr.P.C., it is clear that maintenance can be awarded to the wife, when she is unable to maintain herself.
10. A perusal of the paragraph 23 of the impugned judgment which is at internal page no. 12 of the impugned indicates that in the affidavit filed before the trial court, the opposite party no. 2 herself admitted that she is a Post-Graduate, Web Designer by qualification, and is working as a Senior Sales Coordinator in Keiath Telecom Pvt. Ltd., getting salary of Rs. 34,000/- per month but in her cross-examination she has further admitted that she is earning of Rs. 36,000/- per month and such amount, for a wife who has no other liability, cannot be said to be meagre, whereas the revisionist has the responsibility of maintaining his aged parents and other social obligations.
11. Thus, this Court is of the view that as per the provision of Section 125(1) (a), the opposite party no. 2 is not entitled to get any maintenance from her husband/revisionist as she is an earning lady and able to maintain herself.

From Paras 12 to 15,

12. On the second issue, learned counsel for the revisionist has alleged that she did not came before the trial court with clean hands. A perusal of the affidavit filed by the opposite party no.2 at page no. 67-70 clearly reflects that she has not mentioned that she is an earning lady as well as a perusal of application under Section 125 Cr. P.C. paper no. 33 to 38 at paragraph no. 16 reflects that she has claimed herself as an illiterate and unemployed woman but when the document filed by the revisionist was shown to her before the trial court, she has admitted her aforesaid income during her cross-examination. Thus, it is clear that she did not came before the trial court with clean hands.
13. It is settled law that when a person approaches a Court, he should approach the Court not only with clean hands but also with clean mind, clean heart and clean objective. It is a law of nature that one should not be enriched by the loss or injury to another. The judicial process should never become an instrument of appreciation or abuse or a means in the process of the Court to subvert justice. No litigant has a right to unlimited drought on the Court time and public money in order to get his affairs settled in the manner he wishes. Easy, access to justice should not be misused as a licence to file misconceived and frivolous petitions. If a petitioner is guilty of suppression of very important fact his case cannot be considered on merits. Thus, a litigant is bound to make “full and true disclosure of facts”.
14. The Hon’ble Apex Court in Rekha Sharad Ushir Vs. Saptashrungi Mahila Nagari Sahkari Patsansta Ltd. reported in 2025 SCC OnLine SC641, para no. 11 is reproduced herein below:
“11. It is settled law that a litigant who, while filing proceedings in the court, suppresses material facts or makes a false statement, cannot seek justice from the court. The facts suppressed must be material and relevant to the controversy, which may have a bearing on the decision making. Cases of those litigants who have no regard for the truth and those who indulge in suppressing material facts need to be thrown out of the court.”
15. In view of the said judgment of Hon’ble Apex Court, the opposite party no. 2 does not deserve any sympathy and is not entitled to receive maintenance from the revisionist.

Index of Maintenance Judgements under Section 144 BNSS here.