The Protection of Women from Domestic Violence Act, 2005 (“PWDVA”) explicitly recognizes “economic abuse” as a core component of domestic violence, placing financial control and deprivation on the same plane as physical and sexual violence.
Explanation I(iv) to Section 3 provides a detailed statutory definition of “economic abuse”, broken into three broad heads: (a) deprivation of economic/financial resources and necessities; (b) alienation or disposal of assets and property, including stridhan; and (c) prohibition or restriction of continued access to resources and facilities, including the shared household.
Financial abuse within Indian homes through the statutory and judicial lens of “economic abuse”, structured around five recurring patterns: (1) deprivation of resources; (2) asset alienation; (3) violation of stridhan rights; (4) restriction of access to shared household resources; and (5) employment sabotage. Each of these patterns is embedded in the text of the PWDVA and its Rules, and has been progressively elaborated in case law.
I. Statutory Framework: Economic Abuse under the PWDVA
A. Definition in Section 3 of the PWDVA
Section 3 PWDVA defines domestic violence broadly and then, through Explanation I(iv), defines “economic abuse” in three sub-clauses:
- Deprivation of resources (Explanation I(iv)(a)): “Deprivation of all or any economic or financial resources to which the aggrieved person is entitled under any law or custom … or which the aggrieved person requires out of necessity including, but not limited to, household necessities for the aggrieved person and her children, if any, stridhan, property, jointly or separately owned by the aggrieved person, payment of rental related to the shared household and maintenance”.
- Alienation of assets (Explanation I(iv)(b)): “Disposal of household effects, any alienation of assets whether movable or immovable, valuables, shares, securities, bonds and the like or other property in which the aggrieved person has an interest or is entitled to use by virtue of the domestic relationship or which may be reasonably required by the aggrieved person or her children or her stridhan or any other property jointly or separately held by the aggrieved person”.
- Restriction of access (Explanation I(iv)(c)): “Prohibition or restriction to continued access to resources or facilities which the aggrieved person is entitled to use or enjoy by virtue of the domestic relationship including access to the shared household.”
B. Illustrations in the PWDV Rules, 2006
The PWDV Rules supplement the statutory definition by providing concrete illustrations in the prescribed Domestic Incident Report (Form I) and in the “Information on rights” (Form IV). Rule 5 read with Form I requires the Protection Officer or service provider to record, inter alia, “economic violence”, with specific tick-box examples such as:
- “Not providing money for maintaining you or your children” and “Not providing food, clothes, medicines etc. for you or your children”;
- “Forcing you out of the house you live in” or “Preventing you from accessing or using any part of the house”;
- “Not allowing you to take up an employment” and “Stopping, disturbing you from carrying on your employment”;
- “Not allowing you to use clothes or articles of general household use”;
- “Selling or pawning your stridhan or any other valuables without informing and without your consent” and “Disposing your stridhan”;
- “Non payment of rent in case of rented accommodation” and “Non payment of other bills such as electricity, etc.”.
Form IV, which explains to women their rights under the PWDVA, again enumerates “economic violence” with an almost identical list, including not providing money for maintenance, preventing employment, forcing the woman out of the house, stopping her from accessing parts of the home, and withholding basic necessities and household articles.
C. Remedies for Economic Abuse under the PWDVA
The remedial architecture of the PWDVA is designed to respond to economic abuse through protection orders, residence orders, monetary reliefs, compensation and custody orders (Sections 18–22).
- Residence rights (Section 17 & Section 19): Section 17 confers on “every woman in a domestic relationship” a right to reside in the “shared household”, regardless of her legal title or interest, and prohibits eviction “save in accordance with the procedure established by law”.
- Monetary reliefs (Section 20): The Magistrate may direct payment to meet expenses and losses caused by domestic violence, including loss of earnings, medical expenses, loss due to destruction or removal of property, and maintenance for the aggrieved woman and her children.
- Compensation (Section 22): A separate “compensation order” may be made for physical injury and “mental torture and emotional distress” resulting from domestic violence, which obviously includes economic abuse.
These remedies are thus directly responsive to the forms of economic abuse identified in Explanation I(iv) and the Rules.
II. Dimensions of Financial Abuse: Mapping Statute to Practice1. Deprivation of Resources
Explanation I(iv)(a) PWDVA expressly covers “deprivation of all or any economic or financial resources to which the aggrieved person is entitled under any law or custom or which the aggrieved person requires out of necessity including, but not limited to, household necessities stridhan, property payment of rental and maintenance”.
The PWDV Rules translate this into concrete, day-to-day scenarios. The Domestic Incident Report directs the officer to record whether the woman suffers from:
- “Not providing money for maintaining you or your children”;
- “Not providing food, clothes, medicines etc. for you or your children”;
- “Non payment of rent in case of a rented accommodation”;
- “Non payment of other bills such as electricity, etc.”
These illustrations match the user-specified category of “Deprivation of Resources: Denying a woman financial resources she is entitled to by law or custom, or those she needs for herself and her children (e.g., food, clothes, medicines, or school fees)”, and are squarely within Explanation I(iv)(a).
Judicially, the Delhi High Court has treated failure to provide maintenance to wife and child as a classic form of economic abuse, referring back to Section 3(iv) and holding that “not providing any maintenance to the wife is a form of 'economic abuse' under the DV Act”.
2. Asset Alienation and Financial Dispossession
Explanation I(iv)(b) explicitly characterizes financial abuse as the “disposal of household effects, any alienation of assets whether movable or immovable, valuables, shares, securities, bonds and the like or other property in which the aggrieved person has an interest or is entitled to use or which may be reasonably required by the aggrieved person or her children or her stridhan or any other property jointly or separately held by the aggrieved person”.
Form I of the PWDV Rules operationalizes this by asking whether the respondent has “sold, pawned your stridhan or any other valuables without informing and without your consent” or “dispos[ed] your stridhan”.
The Supreme Court's decision in Mrs. Shailja Krishna v. Satori Global Limited & Ors. provides a striking corporate-asset context. The appellant-wife alleged that she was coerced into signing documents by which her shareholding in a closely held company was transferred to her mother-in-law, and she filed proceedings under the PWDVA against her husband and mother-in-law, contemporaneously with complaints to the Registrar of Companies and the Ministry of Corporate Affairs.
3. Stridhan Rights and Economic Abuse
The statutory definition of economic abuse repeatedly invokes stridhan: Explanation I(iv)(a) lists “stridhan” as a resource whose deprivation constitutes economic abuse; Explanation I(iv)(b) refers to “her stridhan or any other property jointly or separately held by the aggrieved person”; and the PWDV Rules' Form I asks whether the respondent has sold, pawned or disposed of stridhan without consent.
The Supreme Court has long held that stridhan remains the absolute property of a Hindu married woman and that retention of stridhan by the husband or in-laws amounts to a continuing wrong. In a widely-cited judgment (quoted by the Chhattisgarh High Court), the Court observed that “as long as the status of the aggrieved person remains and stridhan remains in the custody of the husband, the wife can always put forth her claim under Section 12 of the 2005 Act”, and that the “concept of 'continuing offence' gets attracted from the date of deprivation of stridhan”.
The PWDV Rules go further and, in the information booklet (Form IV), inform women that under Section 18 they can seek an order directing the respondent “to give you the possession of your stridhan, jewellery, clothes, etc.” and restraining him from operating joint bank accounts or lockers without permission of the court.
Thus, withholding or misusing a woman's stridhan is not merely a property wrong but is statutorily and judicially recognized as a form of domestic violence, engaging both criminal law (e.g. criminal breach of trust) and civil-remedial jurisdiction under the PWDVA.
4. Restriction of Access to Shared Household and Resources
Explanation I(iv)(c) identifies economic abuse as “prohibition or restriction to continued access to resources or facilities which the aggrieved person is entitled to use or enjoy by virtue of the domestic relationship including access to the shared household”.
The PWDV Rules, in Form I, ask whether the woman has been:
- “Forcing you out of the house you live in”;
- “Preventing you from accessing or using any part of the house”;
- “Not allowed use of clothes, articles or things of general household use”.
Form IV reinforces this by listing, under “economic violence”, forcing the woman out of the house, stopping her from accessing or using any part of it, not paying rent in rented premises, and not allowing use of household goods.
The PWDVA gives this content through Section 17 and 19. Section 17 gives the woman an independent right to reside in the shared household “whether or not she has any right, title or beneficial interest in the same” and prohibits her eviction save by law.
In Nancy Kashyap v. State of Bihar (Cr. Rev. 482/2025, decided with connected writs), the Patna High Court noted that the wife alleged not only physical and dowry-related cruelty but also “emotional and economic abuse” in relation to her exclusion from residence and retention of her “streedhan properties and bridal gifts” by the husband's family, and upheld an order directing provision of alternative accommodation to her under the PWDVA.
These decisions show that restricting a woman's access to the shared household and household resources is now firmly conceptualized as economic abuse and remedied through residence and protection orders, not merely through traditional property litigation.
5. Employment Sabotage and Control of Earnings
While the bare text of Explanation I(iv) does not explicitly mention employment, the PWDV Rules squarely classify interference with a woman's right to work and control over her earnings as “economic violence”. Form I lists, under “verbal and emotional abuse”, “preventing you from taking up a job” and “forcing you to leave your job”; and, under “economic violence”, it records as specific acts:
- “Stopped, disturbed from carrying on your employment, or not allowed to take up the same”;
- “Forcibly taking away your salary, income or wages etc.”;
- “Not providing money for maintaining you or your children” notwithstanding that the woman is working.
Form IV's explanatory note similarly includes “Stopping you from carrying on your employment”, “Not allowing you to take up an employment” and “Taking away your income from your salary, wages etc. or not allowing you to use your salary, wages etc.” as paradigmatic examples of “economic violence”.
More directly, the Delhi High Court has stressed that abandonment of financial responsibility by a husband by refusing to maintain his wife and child is economic abuse. In Satyavol Venkat Rama Krishna Rao v. Kavita Rao, the Court held that “not providing any maintenance to the wife is a form of 'economic abuse' under the DV Act”, citing Section 3(iv) and noting that the husband had “played little role in supporting and providing for his wife and minor child” and had “made it only more difficult for them to sustain”.
The PWDVA's remedial provisions again reflect this understanding: Section 20 explicitly allows monetary relief for “loss of earnings” and “any other loss or physical or mental injury” resulting from domestic violence.
III. Judicial Elaboration and Limits of Economic Abuse
A. Courts Affirming Broad Protection
Several courts have endorsed an expansive reading of economic abuse consistent with the PWDVA's text and purpose.
- The Supreme Court in treated economic abuse as co-equal with other forms of domestic violence and emphasized that, in determining whether conduct constitutes domestic violence, courts must consider “the overall facts and circumstances of the case”, as mandated by Explanation II to Section 3.
- In the case of Shaurabh Kumar Tripathi, the Supreme Court emphasized the expansive legislative intent of the Protection of Women from Domestic Violence Act, 2005, by recognizing economic abuse as a core component of domestic violence. The Court noted that under Section 3 of the Act, domestic violence is not limited to physical or sexual harm but expressly includes "economic abuse," which encompasses the deprivation of financial resources, disposal of household assets, or the restriction of access to a shared household. Furthermore, the Court highlighted that per Explanation II to Section 3, the judiciary is mandated to take the "overall facts and circumstances of the case" into consideration when determining whether a respondent's conduct, be it an act, omission, or commission, constitutes domestic violence.
- The Delhi High Court, in Ajay Kumar v. Uma (quoted by a coordinate bench in Satyavol Venkat Rama Krishna Rao), underscored that “domestic violence” includes “economic abuse” and that the PWDVA's object is “to provide for more effective provisions to protect the rights of women , who are victims of violence of any kind occurring within the family”.
- Patna High Court, in its 2025 trilogy of decisions (Rekha Bihar, Kastub Sourabh and Nancy Kashyap), repeatedly reproduced the statutory definition of economic abuse, highlighted the inclusion of deprivation of necessities, stridhan, shared household rights and maintenance, and treated “emotional and economic abuse” as central allegations warranting residence and monetary relief.
- The Chhattisgarh High Court, relying on the Supreme Court, considered retention of stridhan as a continuing wrong and affirmed that the wife can invoke Section 12 PWDVA for relief so long as the husband or in-laws continue to withhold her stridhan.
B. Judicial Caution against Misuse and Overreach
At the same time, courts have also cautioned against stretching the concept of economic abuse to cover every financial or succession dispute.
In Raj Lakshmi Mishra v. State of Bihar, the Patna High Court was confronted with a domestic violence case where the core dispute was over nomination and entitlement to terminal benefits (NPS and insurance) after a male employee's death. Having surveyed Supreme Court and High Court jurisprudence on nomination, the Court observed that “nomination alone does not confer any exclusive beneficial interest on the nominee” and directed that the amount be distributed under the Hindu Succession Act.
The Court described the domestic violence proceedings in that case as “completely unwarranted, occasioned, and initiated out of ulterior and oblique motive” and as an “exemplif[ication] [of] the gross misuse of the provisions of the Protection of Women from DV Act, wherein the law is being invoked as a tool to harass the in-laws”.
IV. Synthesis: Financial Abuse as Invisible Domestic Violence
The PWDVA and its interpretative case law collectively reframe financial control and deprivation within intimate and family relationships as a form of “violence” rather than a mere private or civil dispute.
- Deprivation of resources is recognized where a woman is denied the money, food, clothing, medicines, school fees, rent and utilities she requires for herself and her children, or where legally or customarily entitled resources such as maintenance and stridhan are withheld.
- Asset alienation is captured where household effects, movable and immovable assets, shares, securities and other property in which the woman has an interest or use-right are sold, gifted or encumbered without her consent and to her detriment, including transfer of corporate shares and dispossession of stridhan and household goods.
- Stridhan control is directly named, and withholding, pawning or disposing of stridhan is both statutorily and judicially treated as a continuing economic abuse, on the premise that stridhan is the woman's absolute property and the husband or in-laws are only custodians.
- Restriction of access encompasses exclusion from the shared household, denial of access to parts of the home, household articles and common facilities, and attempts to alienate or renounce rights in the residence, thereby undermining the woman's right to secure housing recognized in Sections 17 and 19.
- Employment sabotage includes preventing a woman from taking up employment, forcing her to leave a job, obstructing her work, and appropriating her earnings, all identified as “economic violence” in the PWDV Rules, and complemented by judicial recognition that non-provision of maintenance and financial abandonment are themselves forms of economic abuse.
Through this doctrinal framework, Indian law makes visible a spectrum of financial harms that were historically normalized or treated as mere incidents of patriarchy or private family arrangements. The PWDVA, reinforced by the Rules and judicial interpretation, conceptualizes these harms as “domestic violence”, with corresponding rights to residence, maintenance, monetary relief and compensation.
At the same time, courts have begun to delineate the limits of economic abuse, insisting that the PWDVA not be used to transform every succession, nomination or financial dispute among relatives into criminalized domestic violence, and requiring a nexus to the statutory categories in Section 3.
Authors are Advocates practicing at Bombay High Court. Views are personal.