The petitioner contends that the application is necessary to clarify the scope of the term “maintenance” in the consent order and to give effect to what he says was the parties’ 130 intention that the payment of RM480,000.00 would represent a complete settlement of the financial obligations arising from the marriage. [12]. The respondent opposes that application and maintains that enclosure 133 is in substance an attempt by the petitioner to 135 alter the agreed terms of the consent order and to avoid his continuing legal responsibility to provide maintenance for the respondent and the children. [13]. In addition, the respondent filed a separate application in enclosure 143 seeking, among others, further maintenance for 140 herself and the children, notwithstanding the consent order dated 5 October 2022. That application was supported by an affidavit affirmed on 9 May 2025 (enclosure 144). [14]. The petitioner resists the application in Enclosure 143 and contends that the consent order constitutes a full and final 145 settlement of all maintenance claims between the parties, including the respondent’s earlier claim for arrears of RM569,875.54. According to the petitioner, both enclosures 133 and 143 ultimately raise the same central issue, namely whether the consent order dated 5 October 2022 conclusively 150 settled the parties’ financial obligations or whether further claims for maintenance remain open. Issue in Enclosure 143 [15]. The issues to be determined by the court are as follows: a) whether the consent order dated 5.10.2022 constituted a 155 full and final settlement precluding further maintenance claims; b) whether the respondent, having accepted the benefits of the consent order, is estopped from reopening the issue of maintenance under the doctrine of approbation and 160 reprobation; c) whether there has been any material change of circumstances after the consent order that would justify the court revisiting the issue of maintenance; and d) whether respondent’s application in enclosure 143 is a 165 result of an afterthought action. Issue (a) : Global settlement, finality of the consent order, and absence of reservation for future maintenance [16]. The respondent relies heavily on the affidavit in enclosure 144 170 to justify reopening the maintenance issue. However, when enclosure 144 is read in its proper factual and procedural context, it does not advance the respondent’s case. Instead, it confirms that maintenance was quantified, negotiated, and resolved before the consent order was recorded. 175 [17]. The documentary trail shows that the respondent had initially demanded RM500,000.00 as arrears of maintenance for the period August 2019 to September 2022. That demand was the subject of court negotiations and was ultimately compromised at RM480,000.00, which the petitioner paid. The sum was 180 therefore not arbitrary, but the product of bargaining and compromise between legally represented parties. [18]. In this regard, the law is clear that a consent order constitutes a binding compromise between the parties, and that claims or reliefs not expressly reserved are deemed abandoned. As held 185 by the Court of Appeal in Perspective Management Services Sdn Bhd v Seganom Sdn Bhd [2004] 4 CLJ 466; [2004] 2 MLRA 128, a consent order reflects a final settlement, and any claim not reserved within it cannot later be revived. The court emphasised that if parties intended to reserve any issue for 190 future litigation, such a reservation must be clearly spelled out in the consent order itself. His Lordship Mokhtar Sidin JCA states: “In our view, when the respondent entered into a consent order with the defendants (including the appellant in the 195 present suit), the parties came to a compromise… since the consent order was a compromise, those claims and relief in the first suit not stated in that order, are deemed to have been abandoned. If any issue or claim or relief was reserved to be litigated later, it must be clearly shown in the order 200 such as the parties be given liberty to do so. We could not find any reservation… For that reason, we are of the view that res judicata and estoppel applies to the present suit.” (underlined emphasised) [19]. In the present case, the consent order dated 5.10.2022 was 205 plainly intended to operate as a global, full, and final settlement of the parties’ matrimonial financial claims, including maintenance for the respondent and the children. The settlement was not confined to a single monetary payment but formed part of a comprehensive arrangement structured to 210 achieve finality between the parties. [20]. Consistent with the foregoing principle, the terms of the consent order demonstrate that the settlement was structured as a comprehensive financial arrangement intended to achieve finality between the parties. First, the petitioner paid 215 RM480,000.00, which was expressly agreed and recorded as “nafkah kepada Responden dan anak-anak tersebut sebagai penyelesaian penuh dan muktamad”. Secondly, the consent order also provided for the conveyance of four immovable properties to the respondent. These properties 220 were not incidental or collateral but formed an integral part of the settlement, which is intended to secure the respondent’s long-term financial position, both in terms of capital value and potential income to the respondent. [21]. Further, the respondent was granted a 50% beneficial interest 225 in the Meru Valley property, while the petitioner continued to service the housing loan. When these elements are considered together, the lump-sum payment, the transfer of four properties, the beneficial interest in the matrimonial home, and the continued servicing of the housing loan, they reveal 230 the overall structure of the arrangement agreed between the parties. That structure clearly demonstrates that the parties intended a clean break and a final settlement of their financial disputes. [22]. Significantly, the consent order contains no express 235 reservation preserving any right to seek future maintenance. There is no clause indicating that the RM480,000.00 payment was interim, partial, or without prejudice to further claims. Consistent with the principle stated in Perspective Management Services Sdn Bhd’s case (supra), matters not 240 expressly reserved must be regarded as conclusively settled. [23]. Accordingly, to interpret the affidavit in enclosure 144 as supporting a claim for future maintenance would run contrary to what is clear factually, contractually, and legally in the settlement, reached between the parties. I find that the affidavit 245 in enclosure 144 does not show that the maintenance issue remained unresolved; rather, it confirms that it had already been conclusively resolved between the parties. Issue (b): Whether the respondent is estopped from reopening maintenance after accepting benefits. 250 [24]. The respondent’s position is internally inconsistent. In the committal proceedings, she took the position that clause (f) of the consent order only required her to pay electricity bills incurred from the date of the consent order onwards, thereby asserting that the petitioner remained liable for arrears 255 incurred prior to that date. However, she now adopts the opposite stance, contending that the consent order settled only maintenance due prior to it and that she remains entitled to claim further maintenance thereafter. These shifting positions demonstrate a clear attempt to rely on the consent order when 260 it benefits her, while rejecting it when it does not, which the law does not permit. [25]. Such conduct amounts to approbation and reprobation, which the law does not permit. As recognised in Konsortium Lebuhraya Utara-Timur (Kl) Sdn Bhd v. Liew Choong Kin; 265 [2018] 3 MLJ 354; [2018] 6 CLJ 217; [2018] 4 MLRA 55, a party cannot be taking inconsistent legal positions. Once a party chooses a course of action and accepts its benefits, they are legally bound by that election. They cannot later "blow hot and cold" by rejecting the associated burdens or pursuing an 270 inconsistent remedy. His Lordship Idris Harun JCA observed: [25] ... Under the law he was not allowed to blow hot and cold in the attitude that he adopts. ... The respondent having made a choice at the second enquiry could be treated as having made an election from which he should not be 275 allowed to abandon. He had taken a benefit arising out of the course of conduct which he had pursued earlier and with which his subsequent conduct was inconsistent with his election. The respondent should not be at liberty to approbate and reprobate having taken a particular position. 280 [26] ... In our judgment, the respondent ... had chosen his own course of action, he subsequently therefore is precluded from pursuing the other course of action attracting in consequence the application of the legal principle that does not permit a person to both approbate and reprobate." 285 (underlined emphasised) [26]. By accepting and retaining the benefits of the consent order without qualification, the respondent is therefore estopped from asserting that the same settlement was incomplete or 290 provisional for the purpose of seeking further maintenance. As highlighted in Tenaga Nasional Bhd v. Irham Niaga Sdn Bhd & Anor [2010] 3 MLRA 126; [2011] 1 MLJ 752; [2011] 1 CLJ 491 (cited in Konsortium Lebuhraya’s case ( supra)): "Estoppel by election is related to the principle that a person 295 may not approbate and reprobate ... a person having a choice between two courses of conduct is to be treated as having made an election from which he cannot resile. But the person will not be regarded as having so elected unless he has taken a benefit under or arising out of the course of 300 conduct which he has first pursued and with which his subsequent conduct is inconsistent with his election." [27]. In the present case, the respondent has plainly elected to rely on the consent order and has accepted the benefits arising 305 from it. Therefore, cannot now deny its finality. The law does not permit a party to approbate and reprobate or take inconsistent positions. She is therefore estopped. Issue (c): Whether a material change justifies revisiting maintenance after the Consent Order. 310 [28]. It is not disputed that under the Law Reform (Marriage and Divorce) Act 1976 (“LRA”), the court retains statutory jurisdiction in matters relating to maintenance. Sections 77 and 78 empower the court to order maintenance for a wife or former wife, while sections 92, 93, and 95 impose a 315 continuing duty on parents to maintain the children of the marriage. In addition, section 96 of the LRA provides that the court may vary or rescind any order relating to the custody or maintenance of a child where it is satisfied that the order was based on misrepresentation or mistake of fact, or where there 320 has been a material change in circumstances. Similarly, section 97 of the LRA empowers the court to vary the terms of any agreement relating to the custody or maintenance of a child where it is reasonable and for the welfare of the child to do so. Append below the relevant provisions: 325 Power for court to order maintenance of spouse s.77. (1) The court may order a man to pay maintenance to his wife or former wife—