The Chhattisgarh High Court has ruled that an unmarried daughter, even if she is a major, has a full legal right to claim daughter maintenance and marriage expenses from her father. The Court dismissed the father’s appeal and ordered him to pay monthly daughter maintenance and deposit ₹5 lakh for her marriage.
BILASPUR: The Chhattisgarh High Court ruled that a father is both legally and morally responsible for giving financial support to his unmarried daughter maintenance, even after she becomes a major.
The Division Bench of Justice Sanjay K. Agrawal and Justice Sanjay Kumar Jaiswal dismissed the father’s appeal and upheld the Family Court’s direction to pay monthly maintenance and marriage expenses.
Right at the beginning of the order, the Court relied upon an important observation made earlier by the Delhi High Court.
It stated:
“A father cannot abdicate his responsibility of looking after his unmarried daughters. A father has a duty and an obligation to daughters maintenance and to take care of their expenses, including towards their education and marriage. This obligation is legal and absolute in character and arises from the very existence of the relationship between the parties. Kanyadaan is a solemn and pious obligation of a Hindu father, from which he cannot renege.”
The case came before the High Court as an appeal under Section 19 of the Family Courts Act. The father, Raj Kumar Sonwani, challenged the judgment dated 02.09.2024 passed in Civil Suit No. 56A/2022. The Family Court had allowed the application filed by his 25-year-old daughter under Section 20 read with Section 3(b) of the Hindu Adoptions and Maintenance Act, 1956.
The daughter told the Court that she is unable to maintain herself and that her father is a Government Teacher earning ₹44,642 per month. She also said that her father had remarried and has two children from the second marriage. Because she is unmarried and without her own income, she demanded maintenance and ₹15,00,000 as marriage expenses.
After considering the evidence, the Family Court ordered the father to pay ₹2,500 per month as maintenance till her marriage and ₹5,00,000 towards her marriage expenses. The father then filed an appeal before the High Court.
Before the High Court, the father argued that the Family Court should not have passed the order because neither party had filed affidavits as required by the Supreme Court judgment in Rajnish v. Neha.
On the other hand, the daughter’s lawyer supported the order, and the Amicus Curiae referred to the Supreme Court judgment Abhilasha v. Parkash (2021).
The High Court carefully examined the law and noted that the relationship of father and daughter was not in dispute. It also found that the daughter was indeed unable to maintain herself and needed financial support for her marriage.
To support its reasoning, the Court referred to Section 3(b) of the Hindu Adoptions and Maintenance Act, which defines “maintenance” to include marriage expenses of an unmarried daughter.
The Court then discussed Section 20(3) of the Act, which places a legal duty on a person to maintain an unmarried daughter who cannot support herself.
Referring to the Supreme Court ruling in Abhilasha v. Parkash, the High Court said:
“32. The provision of Section 20 of the 1956 Act casts clear statutory obligation on a Hindu to maintain his unmarried daughter who is unable to maintain herself. The right of married daughter under Section 20 to claim maintenance from her father when she is unable to maintain herself is absolute and the right given to unmarried daughter under Section 20 is rightly granted under Personal law, which can very well be enforced by her against her father. The judgment of this Court in Jagdish Jugtawat laid down that Section 20(3) of the 1956 Act recognised the right of a minor girl to claim maintenance after she attains majority till her marriage from her father.
Unmarried daughter is clearly entitled for maintenance from her father till she is married even though she has become major, which is a statutory right recognised by Section 20(3) and can be enforced by unmarried daughter in accordance with law.”
Applying this principle to the present case, the High Court 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.”
The Court further emphasised that the father’s obligation is not only legal but also moral:
“The appellant/defendant, being the father of respondent/plaintiff, has a moral and legal responsibility and obligation to daughter Maintenance, 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…”
Since the Family Court had correctly applied the law, the High Court refused to interfere with the order. It confirmed that the daughter will continue receiving ₹2,500 per month till her marriage or until she is able to earn on her own. The Court also upheld the direction to pay ₹5,00,000 as marriage expenses.
During the hearing, the daughter’s counsel informed the Court that the father had not yet paid any of the maintenance amount nor deposited the marriage expenses. The father’s lawyer then stated in Court that the father would start paying the monthly amount regularly and would deposit ₹5,00,000 within three months.
With these directions, the High Court dismissed the appeal, concluding that it had no merit.
Explanatory Table Of All Sections, Laws & Cases Mentioned
| Law / Case / Section | What It Means | How It Applies In This Case |
| Section 3(b), Hindu Adoptions & Maintenance Act, 1956 | Defines what “maintenance” includes. For unmarried daughters, it also includes marriage expenses. | The Court relied on this definition to hold that the daughter has a legal right to claim money for marriage and not just monthly support. |
| Section 3(b)(ii), HAMA | Specifically states “reasonable expenses of marriage of an unmarried daughter” are part of maintenance. | Used to justify that the father must pay ₹5,00,000 marriage expenses. |
| Section 20, HAMA | A Hindu must maintain his children and aged parents. | The daughter filed claim under this section. |
| Section 20(3), HAMA | An unmarried daughter who cannot maintain herself has a legal right to claim maintenance until marriage. | Since she is 25, unmarried, and without income, maintenance was granted. |
| Section 19, Family Courts Act, 1984 | Provides for appeals to High Court from Family Court orders. | The father filed this appeal under Section 19. |
| Supreme Court Judgment: Abhilasha vs. Parkash (2021) | Held that an unmarried major daughter has an absolute right to claim maintenance under Section 20 HAMA. | High Court heavily relied on this case; quoted para 32 in full. |
| Supreme Court Judgment: Jagdish Jugtawat vs. Manju Lata (2002) | Recognised that a daughter can claim maintenance even after majority till marriage. | Cited to reinforce that the right continues after 18 years. |
| Supreme Court Judgment: Rajnesh vs. Neha (2020) | Requires financial affidavits in maintenance cases. | Father argued that the Family Court order was invalid because affidavits were not filed. HC rejected this argument. |
| Delhi High Court Judgment: Poonam Sethi vs. Sanjay Sethi (2022) | Strong observation on father’s moral duty toward daughters and on “Kanyadaan.” | The Chhattisgarh High Court reproduced and relied upon the quote directly. |
| Exhibit P/4 (Salary Document) | Shows father earns ₹44,642/month as teacher. | Used to establish ability to pay. |
Case Summary
Case Title: Raj Kumar Sonwani vs. Kumari Purnima (FA(MAT) No. 168 of 2025)
Court: High Court of Chhattisgarh, Bilaspur
Bench (Division Bench):
- Justice Sanjay K. Agrawal
- Justice Sanjay Kumar Jaiswal
Judgment Date: 21 November 2025
Appellant (Father): Raj Kumar Sonwani, S/o Ramsai, Age 48 years R/o Village Karji, P.S. Patna, Tehsil Baikunthpur, District Koriya, Chhattisgarh
Respondent (Daughter): Kumari Purnima, D/o Raj Kumar Sonwani, Age 25 years R/o Village Kamalpur, P.S. Krishnapur, Tehsil Ramanujnagar, District Surajpur, Chhattisgarh
Counsels:
- For Appellant: Mr. Anurag Singh
- For Respondent: Mr. Utkarsh Patel
- As Amicus Curiae: Mr. Sharad Mishra
Impugned Order Challenged: Judgment dated 02/09/2024 in Civil Suit No. 56A/2022 by Family Court, Surajpur.
Relief Granted by Family Court (Upheld by High Court):
- ₹2,500 per month maintenance till marriage
- ₹5,00,000 marriage expenses
- Must deposit within 3 months
Father’s Job & Income: Government Teacher earning ₹44,642 per month.
Key Takeaways
- Another case where the father alone is held financially responsible, while the adult daughter’s own capability or the mother’s contribution is never examined.
- Even at 25 years of age, an able-bodied adult woman is legally allowed to depend entirely on the father, reinforcing financial burden only on men.
- Marriage expenses, which should be a shared family or personal choice, are again imposed solely on the father regardless of his second family or responsibilities.
- Courts continue to expand the definition of “maintenance” only for daughters, creating gender-skewed obligations with no parallel duty for mothers.
- The judgment highlights how personal responsibility of an adult woman is overlooked, while lifelong financial liability is placed entirely on the man.
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