The petitioner/husband challenged a Family Court order (Mandla) awarding Rs. 7,000/- per month maintenance to his wife under Section 125 CrPC, arguing that a prior maintenance application had already been dismissed on merits (thus attracting res judicata) and that a decree of divorce passed on 08.03.2017 disentitled the wife from claiming maintenance. The Madhya Pradesh High Court examined two key questions: (1) whether a second Section 125 CrPC application is maintainable after dismissal of the first on merits, and (2) whether, after a divorce decree, the wife still needs to show 'sufficient cause' for living separately to claim maintenance. Relying on the Supreme Court's ruling in Rohtash Singh v. Ramendri (2000) 3 SCC 180, the High Court noted that Section 125(4) CrPC—which bars maintenance if the wife lives separately without sufficient cause—presupposes a subsisting marriage and does not apply once the marriage is dissolved by divorce. The court further noted that under Explanation (b) to Section 125(1) CrPC, a divorced woman who has not remarried retains the status of 'wife' for the purpose of claiming maintenance. The judgment extensively analyses the legal position on res judicata in maintenance proceedings and the rights of a divorced wife under Section 125 CrPC.