HAMA | Father Obliged To Provide Maintenance & Marriage Expenses To Unmarried Major Daughter: Chhattisgarh High Court

The Chhattisgarh High Court has held that a father is legally as well as morally duty bound to provide maintenance and marriage expenses to his daughter, even after she attains the age of majority.

While dismissing an appeal against maintenance order passed by Family Court, the Division Bench of Justice Sanjay K. Agrawal and Justice Sanjay Kumar Jaiswal held -

"The appellant/defendant, being the father of respondent/plaintiff, has a moral and legal responsibility and obligation to maintain his daughter, who is unmarried, even though she has attained the age of majority. He cannot deny to pay the marriage expenses on any ground whatsoever when he is getting a reasonably well salary by working as a Government Teacher…"

The respondent herein, who is about 25 years old, is the daughter of the appellant. She filed an application under Section 20 read with Section 3(b) of the Hindu Adoptions and Maintenance Act, 1956 expressing inability to maintain herself. She further stated that her father/appellant is government teacher with a salary of Rs. 44,642/- per month and he has solemnised a second marriage. Thus, she sought for maintenance as well as marriage expenses to the extent of Rs. 15,00,000/-.

The Family Court, Surajpur held that since the respondent is the daughter of appellant and is unable to maintain herself, she is entitled to get maintenance amount of Rs. 2,500/- per month from the appellant till her marriage and is also entitled to get Rs. 5,00,000/- towards marriage expenses. Being aggrieved, the appellant/father preferred this appeal under Section 19 of the Family Courts Act.

The Court, upon hearing both the sides, recorded the relationship between the parties to be undisputed. It further noted that the daughter is unable to maintain herself and she also requires financial help from her father for bearing marriage expenses.

Reliance was placed upon Section 3(b)(ii) of the 1956 Act which defines “maintenance” to be inclusive of an unmarried daughter's expenses for marriage. Further Section 20(3) makes it obligatory for a person to maintain his or her aged or infirm parent or a daughter who is unmarried, if they are unable to maintain themselves out of their own earnings or other property.

Placing reliance upon the judgment of the Apex Court in Abhilasha v. Parkash (2020), the Court said that the right of unmarried daughter under Section 20 of 1956 Act to claim maintenance from her father when she is unable to maintain herself is absolute, which can very well be enforced against her father. Accordingly, it held –

“Coming to the facts of the present case in light of the aforesaid legal principles laid down by their Lordships of the Supreme Court in the matter of Abhilasha (supra), it is quite vivid that though the respondent/plaintiff is a major, aged about 25 years, but by virtue of Section 3(b)(ii) read with Section 20(3) of the Act of 1956, she, being an unmarried daughter, is clearly entitled for maintenance from her father appellant/defendant till she is married, as well as marriage expenses, which is her statutory right.”

As a result, the appeal was dismissed by upholding the Family Court order. The appellant/father was directed to provide regular (monthly) maintenance to the respondent/daughter and to deposit Rs. 5,00,000/- towards her marriage expenses within a period of three months.

Case Title: Raj Kumar Sonwani v. Kumari Purnima

Case No: FA(MAT) No. 168 of 2025

Date of Judgment: November 21, 2025

Counsel for Parties: Mr. Anurag Singh, Advocate for the Appellant; Mr. Utkarsh Patel, Advocate for the Respondent; Mr. Sharad Mishra, Advocate as Amicus Curiae

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