Chhattisgarh High Court Upholds Unmarried Daughter's Right to Maintenance and Marriage Expenses

Court affirms statutory obligation of father to support unmarried daughter under Hindu Adoptions and Maintenance Act, 1956

In a landmark judgment, the Chhattisgarh High Court has upheld the legal rights of an unmarried daughter to receive maintenance and marriage expenses from her father, even after attaining the age of majority. The Division Bench, comprising Justices Sanjay K. Agrawal and Sanjay Kumar Jaiswal, delivered the verdict on November 21, 2025, in the case of Raj Kumar Sonwani v. Kumari Purnima, affirming the decision of the Family Court, Surajpur.

The case arose when Kumari Purnima, the daughter of Raj Kumar Sonwani, filed a suit claiming maintenance and marriage expenses under the Hindu Adoptions and Maintenance Act, 1956. Despite being 25 years old, she argued that she was unable to sustain herself financially and thus sought support from her father, who is a government teacher earning a substantial salary.

The Family Court had previously granted Purnima a monthly maintenance of Rs. 2,500 and Rs. 5,00,000 towards her marriage expenses. This decision was contested by Sonwani, who appealed the judgment, arguing procedural lapses as both parties did not file affidavits as required by a Supreme Court precedent.

The High Court, however, dismissed the appeal, underscoring the statutory obligations under Sections 3(b)(ii) and 20(3) of the Hindu Adoptions and Maintenance Act, 1956. These provisions mandate that a father must maintain his unmarried daughter who is unable to support herself, including covering reasonable marriage expenses. The court emphasized that these obligations are absolute, deriving from the personal law, and cannot be shirked even if the father has remarried.

During the proceedings, the court considered previous landmark cases, such as Abhilasha v. Parkash and Jagdish Jugtawat v. Manju Lata, which established the legal framework supporting an unmarried daughter's right to maintenance until marriage. The court highlighted that a father's duty to maintain his daughter is both moral and legal, regardless of her age, as long as she remains unmarried and unable to earn a livelihood.

The judgment has been hailed as a significant affirmation of women's rights within familial structures, ensuring financial security for unmarried daughters. The court's decision reinforces the importance of adhering to statutory provisions that protect the welfare of women, particularly in family law matters.

The appellant, Raj Kumar Sonwani, has been instructed to comply with the maintenance order and deposit the marriage expenses within three months, as assured by his counsel during the hearing.

Bottom Line:

Maintenance and marriage expenses for unmarried daughter - Unmarried daughter is entitled to maintenance and reasonable marriage expenses from her father under Section 3(b)(ii) read with Section 20(3) of the Hindu Adoptions and Maintenance Act, 1956, even after attaining majority.

Statutory provision(s): Section 3(b)(ii), Section 20(3) of the Hindu Adoptions and Maintenance Act, 1956

Raj Kumar Sonwani v. Kumari Purnima, (Chhattisgarh)(DB) : Law Finder Doc Id # 2811789