Major Unmarried Daughter Can Seek Educational Expenses For Post-Graduation Under Domestic Violence Act: Karnataka High Court

The Karnataka High Court has held that a father is obligated to bear the educational expenses of his unmarried daughter pursuing postgraduate medical studies under the Protection of Women from Domestic Violence Act, 2005, even after she has attained majority, observing that the parental obligation to provide education does not cease merely because the child has become an adult. [2026 LiveLaw (Kar) 258] A Single Judge Bench of Justice H.P. Sandesh dismissed a revision petition filed by the father against concurrent orders of the Trial Court and the District & Sessions Court directing him to pay ₹16 lakh towards his daughter's MD Dermatology course fees. The Court held that educational expenses can be awarded as monetary relief under Section 20 of the DV Act, noting that deprivation of such financial support amounts to "economic abuse" under Section 3(d)(iv) of the Act. "...While defining economic abuse, the Legislature has also included deprivation of all or any economic or financial resources to which the aggrieved person is entitled under any law or custom. It is the custom and practice that everywhere in the world that parents are morally obligated to provide basic amenities, including health and education. If the contention of the petitioner that the child is not entitled to maintenance or educational expenses on attaining majority is accepted, the expression 'in addition to' employed in Section 20(1)(d) would be otiose..." Section 20(1) empowers a Magistrate to grant monetary relief to meet expenses and losses suffered by the aggrieved person and her children as a result of domestic violence. Clause (d) specifically refers to maintenance for the aggrieved person and her children, including an order under or in addition to maintenance under Section 125 CrPC or any other law. The respondent daughter secured admission to the MD Dermatology programme at Father Muller's Institute of Medical Education & Research, Mangaluru, after qualifying the NEET-PG examination. She stated that she had borrowed ₹14 lakh from her grandfather to pay the admission fees owing to the urgency in securing the seat. The Trial Court directed the father to reimburse ₹16 lakh towards the first-year educational expenses, and the appellate court affirmed the order. Before the High Court, the father contended that his daughter had attained majority, was receiving a stipend during her postgraduate course, and therefore could not invoke the provisions of the DV Act. He also argued that she did not fall within the definition of an "aggrieved person" under Section 2(a) of the Act. The Court rejected these submissions. Referring to its earlier decision in Kum. Bhavana N. v. Sri Nagaraju S, the Court reiterated: "A daughter as soon as she attains majority falls under the definition of woman and may become an aggrieved person if she establishes that she has been subjected to domestic violence. A daughter on whose behalf monetary reliefs were sought, on attaining majority, would be entitled to such monetary reliefs." The Court also relied on the Supreme Court's decision in Neelima Choure v. Vijay Choure (2025), which recognised that a daughter has a legally enforceable right to seek educational expenses from her parents and that parents can be compelled to provide the necessary funds within the limits of their financial resources. Further, the Court extensively referred to the Madras High Court's judgment in Jagadesan v. State of Tamil Nadu (2015), which held that a father's legal and moral obligation to provide education does not end upon the child attaining majority and that denial of such financial support may amount to economic abuse under the DV Act. Relying on these principles, the Court observed: "The detailed discussion in the Madras High Court judgment makes it clear that Section 20 of the DV Act provides for monetary relief in addition to maintenance, and the father has to meet the educational expenses of the daughter, whether for undergraduate or postgraduate studies. The expressions 'but is not limited to' in Section 20(1) and 'in addition to maintenance' have wide connotation and amplitude, and the power of the Magistrate is not restricted." The High Court also noted that the father's financial records demonstrated sufficient capacity to bear the expenses. It referred to findings that he had acquired fixed assets worth over ₹1.34 crore in 2021 and had availed substantial loans over subsequent years, indicating his financial capability. Rejecting the father's argument that the daughter could finance her studies through a bank loan, the Court observed: "The contention that, after attaining majority, she can pursue her education by obtaining a bank loan cannot be a ground to interfere with the orders of the Trial Court and the Appellate Court. The daughter is not earning and is pursuing continuous education from undergraduate to postgraduate level." Interpreting Section 20 of the DV Act, the Court held ...

Major Unmarried Daughter Can Seek Educational Expenses For Post-Graduation Under Domestic Violence Act: Karnataka High Court

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Major Unmarried Daughter Can Seek Educational Expenses For Post-Graduation Under Domestic Violence Act: Karnataka High Court

Sebin James

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