Grounds to corroborate genuine liabilities and how how the petitioner fulfilled his responsibilities honestly:

1. . Because of, the petitioner has burden to re-pay various loan amounts as taken by the petitioner time to time, thus he has to pay EMIs for the same. Though learned court erred in observing and concluded that petitioner got those personal loans and credit card bills just for his luxurious life. His sole purpose was to provide the best of facilities and comfort to his wife, her family so that peace and harmony may prevail and add to the marital bliss. The learned court has not been pleased to consider the fact that a true wife would contribute blessings and not burdens even when she is highly educated and she did job before and after marriage and her husband has many liabilities.

2. Because of, the leaned court acknowledged and concluded that the Home Loan, Premium of Mediclaim and montly Rent and etc. were taken by the petitioner towards expenses. But the learned court erred in observing that  it was duly showcased before the learned court by the petitioner through his Indusind Bank credit card statement that the petitioner has incurred about Rs 60000/- on his wife (respondent)  and her family when he came to Jabalpur on the occasion of Barsi of his Father in law.In another instance, the petitioner has spent Rs 1,74,000 in arranging air ambulance for his father in law to be airlifted from Jabalpur to Medanta hospital in Gurgaon .All these expenses were incurred on his credit cards only . Accordingly, he incurred an expenses of about Rs 10 lacs in all in 4.5 years of his marriage life so that he could provide a comfortable life to his wife.To summarize the nature of expenses incurred on Petitioners credit cards in 4.5 years of his marriage; these largely includes money spent on their both as a couple since their marriage held in Feb 2014. Dinners ,vacation travels, to and fro air tickets for Megha when she travelled to Jabalpur ,apparel, car maintennance,shopping ,jewelry shopping ,gifts ,honeymoon ,Medical emergency expenses on Megha’s departed father ,purchase of air tickets at current price so that she could meet her dying father etc.These expenses were ongoing even when his salary was much lesser than what it is currently today. His sole purpose was to provide the best of facilities and comfort to his wife/ respondent, her family so that peace and harmony may prevail and add to the marital bliss. He availed personal loans to payoff his backlog of Credit card outstanding since his marriage in 2014 , as a Personal Loan is available at a much lesser rate of interest as against credit cards which charge 42% annually. In another instance, petitioner had to take Personal Loan because the builder of his flat could not deliver the residential project in time and LICHFL limited stopped financing the construction linked plan for his purchased flat. Hence he had to arrange for funds and pay the builder else he would have lost his flat. This is also in lines with many residential and commercial projects of Delhi and NCR wherein the builders have declared themselves bankrupt and the fate of the flat owners is left hanging in uncertainty. The lower court has further assumed that the Petitioner’s loan from TATA CAPITAL is getting over on 8.4.2019. We request you to please look at the document once again . It marks the loan statement date over a certain period. In other words it is the “to“and“From” date of the loan statement and does not mark the end of repayment tenure. This loan gets over in May 2022. What he had provide to the lower court was a loan statement from 1.06.2018 to 8.04.2019. But the same was not taken correctly by the learned court below. The lower court has not taken into account basic necessities and utilities like fuel, electricity bills, medcines, doctor consultations, groceries,monthly, vehicle repair and maintenance, allowances for maid ,phone bills, daily personal expenses of an individual in a city like Delhi /NCR ; price index of Jabalpur vis-à-vis Delhi /NCR ,while arriving at Interim Maintenance amount. It is to be mentioned here that almost 50% of the Petitioner’s Net Take Home salary goes towards his Fixed EMI’s and he would need funds for various other household expenses mentioned above. 

3. Because of, the learned court below has failed to see that the petitioner has his parents alive and both are old aged and undergoing regular medical attention, thus he has special obligation to take-care of them along with his job/service, but the learned court wrongly concluded and neglected the same.

4. Because of , the learned court failed to see that the old parents of petitioner are not able to earn whereas the respondent is abled body and highly educated and can do the job.