Karnataka High Court: Adult Unmarried Daughter Can Seek Education Support from Father Under DV Act
The Karnataka High Court has ruled that an adult unmarried daughter is entitled to seek monetary relief from her father for higher education under the Protection of Women from Domestic Violence Act, 2005. The court upheld a trial court order directing a man to pay ₹16 lakh towards the annual fee for his daughter's postgraduate medical course.
Justice H.P. Sandesh, while dismissing a revision petition filed by a 53-year-old man from Mangaluru, observed that the obligation of parents to provide basic amenities, healthcare, and education does not end when a child attains majority. 'It is the custom and practice everywhere in the world that parents are morally obligated to provide basic amenities, including healthcare and education,' the court noted.
The case involved a father who had previously paid for his daughter's MBBS degree when he and his wife were living together. However, due to a strained relationship, the couple now live on separate floors of the same building—the mother and daughter on one floor, and the father on another. The daughter sought financial support for her PG medical course, citing Section 20(d) of the DV Act, which allows courts to order monetary relief for expenses incurred due to domestic violence.
The father challenged the trial court's order, arguing that the daughter, being an adult, was not entitled to maintenance or educational expenses. The high court rejected this contention, stating that accepting it would render the phrase 'in addition to' in Section 20(1)(d) meaningless. The court cited a recent Supreme Court judgment that recognized a daughter's 'indefeasible, legally enforceable, lawful and legitimate right to secure educational expenses from her parents.'
The high court also noted the father's financial capacity, as his income tax returns and bank statements revealed fixed assets worth ₹1.34 crore acquired in 2021 and loans totalling ₹1.27 crore availed between 2021 and 2023. Additionally, the daughter had secured an All India Rank of 11,722 and gained admission at a nominal fee compared to the management quota fee of ₹75 lakh per year.
Justice Sandesh emphasized that parents in conflict can be compelled to provide necessary funds for a daughter's higher education within the limits of their financial resources. The court dismissed the revision petition, affirming the orders of the lower courts.
This ruling reinforces the protective scope of the Domestic Violence Act, ensuring that adult daughters are not left without support for education due to familial discord.
