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12. In Danial Latifi and Another v. Union of India [(2001) 7 SCC 740], the Supreme Court considered the constitutional validity of the provisions of the Muslim Women (Protection of Rights on Divorce) Act, 1986 and upheld it. The Act of 1986 provides remedies beneficial to the Muslim women divorcee by making the former husband liable to provide the divorced woman with a reasonable and fair provision, in addition to providing maintenance. While the Criminal Procedure Code provides the relief of maintenance only, the Act of 1986 furnishes to a divorced woman, in addition to a reasonable and fair provision, the relief of recovery of dower and return of marital gifts.