Spousal maintenance in India is undergoing a perceptible shift: from a framework that presumes long-term dependency of one spouse (traditionally the wife) to one that increasingly expects self-reliance, especially when the spouse is educated or gainfully employable. The Orissa High Court in Madan Kumar Satpathy v. Priyadarshini Pati^[1] held that a well-educated wife cannot remain idle merely to claim maintenance, emphasizing that the purpose of Section 125 CrPC is to aid those genuinely unable to support themselves. This signals a changing judicial trend, wherein qualifications, past work experience, and earning capacity are factors that courts consider in scaling down or adjusting maintenance obligations. Previously, maintenance was awarded based largely on need and dependency, often without rigorous scrutiny of the spouse’s ability to work. Under this new trend, legal responsibility is being balanced with expectations of self-sufficiency. This paper critically analyses Madan Kumar Satpathy v. Priyadarshini Pati, explores the statutory regime and judicial practice of spousal maintenance in India, and compares these with the UK and USA approaches. It examines whether maintenance law is evolving toward greater gender equality and economic independence without sacrificing fairness, considers the challenges of enforcement and cultural constraints, and proposes reforms to ensure that maintenance regimes provide dignity and protection while promoting self-reliance.