Challenging the “idle wife” notion, the Delhi High Court held that a homemaker’s contributions enable the earning spouse’s success and cannot be ignored in maintenance decisions. Justice Swarana Kanta Sharma said non-employment does not imply idleness or deliberate financial dependence.

NEW DELHI: Challenging the “myth” of the “idle wife,” the Delhi High Court asserted that a homemaker’s contributions are vital for the earning spouse’s effective functioning, deeming it “unjust” to overlook her role when determining maintenance.
Justice Swarana Kanta Sharma noted that a wife’s lack of employment should not equate to idleness or intentional dependence. In matters of maintenance, the law must acknowledge not only financial contributions but also the economic value of her efforts within the household throughout the marriage.
The court stated,
“The assumption that a non-earning spouse is ‘idle’ reflects a misunderstanding of domestic contributions. To describe non-employment as idleness is easy; to recognize the labor involved in sustaining a household is far more difficult,”
The court emphasized,
“A homemaker does not sit idle; she performs labor that enables the earning spouse to function effectively. To disregard this contribution while adjudicating claims of maintenance would be unrealistic and unjust.”
The court made these remarks while reviewing a case concerning the maintenance of an estranged wife under the Protection of Women from Domestic Violence Act. A magisterial court had denied her interim maintenance, reasoning that she was able-bodied and well-educated but had opted not to seek employment. The appellate court also denied her relief.
The couple had married in 2012, and the husband was accused of abandoning both the wife and their minor son in 2020. He argued in the high court that the wife could not sit “idle” and demand maintenance when she was capable of earning; he claimed to be covering their child’s educational expenses.
The court clarified that the ability to earn and actual earnings represent distinct concepts, noting that established law maintains that mere capacity to earn should not serve as grounds to deny maintenance.
The court remarked,
“Women who can and are willing to work should be encouraged, but denying maintenance solely because she is capable of earning and should not rely on her husband is a flawed perspective,”
The court added,
“Managing a household, caring for children, supporting the family, and adjusting one’s life around the career and relocations of the earning spouse constitutes work, even if unpaid and often unrecognized. These responsibilities do not show up in bank statements or generate taxable income, yet they create the invisible framework on which many families operate,”
It highlighted that, in Indian society, women are often expected to abandon their careers after marriage, yet husbands frequently argue in matrimonial disputes that they should deny maintenance to their “well-qualified” wives for deliberately remaining unemployed.
The court stated that such a stance cannot be supported, emphasizing that the law should ensure that a spouse who has devoted time, effort, and years to building the family is not left financially vulnerable.
It acknowledged that a woman who had left her profession due to marital or familial obligations cannot be expected to return to the same level or salary later on.
Ultimately, the court found no evidence of past or present employment or earnings for the wife and awarded her Rs 50,000 in domestic violence proceedings.
The court also expressed concern over maintenance proceedings often becoming “intensely adversarial,” stating this rarely benefits either party or their minor children. It suggested that mediation, rather than prolonged litigation, could offer a more constructive resolution to matrimonial disputes, fostering meaningful dialogue, realistic assessments of both parties’ needs and capabilities, and mutually acceptable outcomes.
The court indicated that court proceedings complicate dialogues between parties, and in contentious cases, the wife might exaggerate her monthly expenses, while the husband may downplay his income or claim financial incapacity.
