Constitutional invalidity of arbitrary classification under article 14

Any restrictive interpretation of Section 21(vii) that attempts to create two distinct classes of widowed daughters-in-law based solely on the timing of the husband's death fails the test of constitutional validity under Article 14. Classifying widowed daughters-in-law into those whose husbands died during the father-in-law's lifetime and those whose husbands died after him is manifestly arbitrary and unreasonable. Such an artificial classification bears no rational nexus to the primary object and purpose of the Act, which is to secure basic maintenance for dependants facing financial vulnerability. In both scenarios, the widowed women are similarly situated regarding spousal loss, lack of financial support, and vulnerability to destitution. Denying statutory maintenance to one class of widows based on the fortuitous timing of a spouse's death violates the constitutional guarantee of equality before the law. Statutory provisions must be read in a manner that avoids constitutional infirmity and prevents arbitrary discrimination among similarly situated vulnerable claimants. Consequently, equal statutory protection for maintenance must extend to all widowed daughters-in-law irrespective of when widowhood occurred. (Kanchana Rai v. Geeta Sharma & Ors. | 2026 INSC 54)