It is not necessary to make separate application for interim relief u/s23 of DV ACT
Vishal Damodar Patil ..vs.. Vishakha Vishal Patil; 2008 (6) AIR Bom R 297 wherein it is observed that there is no need to file separate application for interim relief under Section 23 of the said Act. The only requirement is to hear the parties concerned. In the present case, the learned trial Judge has undoubtedly heard the applicant as well as non applicant and has passed an interim order. To that extent, in the absence of regular application for interim maintenance, passing of order dated 07.04.2008 cannot be faulted with.
https://www.lawweb.in/2012/09/it-is-not-necessary-to-separate.html
Bombay High Court
Nandkishor S/O Damodar ... vs May Include A Relief For Issuance ... on 5 August, 2009
Bench: R.Y. Ganoo
1. Rule. Rule returnable forthwith. Mr. Bhattad, Advocate waives notice for non applicants. In the facts and circumstances of the case, the matter is taken up for final hearing forthwith.https://www.lawweb.in/2012/09/it-is-not-necessary-to-separate.html