SMT. KULDIP KAUR vs SURINDER SINGH AND ANR.

The Supreme Court held that sentencing a husband to jail for non-payment of maintenance does not equate to satisfaction of the maintenance order under Section 125 CrPC. The Court established that actual payment of arrears is necessary to discharge the liability, and imprisonment serves only as a mode of enforcement. The appeal was allowed, emphasizing that the purpose of jail is to compel compliance, not to absolve financial obligations.