C. Meena v. C. Suresh Kumar, 1993 (1) ALT 1 found that without an application by a party, a decree can be passed fixing a reasonable amount by way of maintenance. Section 25 of the Hindu marriage Act envisages that maintenance can be granted by a Court basing on the conduct of the parties and other circumstances of the case if it is just without any application and such payment may be secured, if necessary, by a charge on the immovable property of the respondent

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