Section 20 of the Protection of Women from Domestic Violence Act, 2005

Source: Karnataka High Court 

Why in News? 

A Single Judge Bench of Justice H.P. Sandesh, in Vincent Correa v. Viyola Prathvi Correa (2026), 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, and that deprivation of such financial support amounts to economic abuse under Section 3(d)(iv) of the Act. 

What was the Background of Vincent Correa v. Viyola Prathvi Correa (2026) Case? 

• 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 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. 
• The father filed a revision petition before the High Court, contending that his daughter had attained majority, was receiving a stipend during her postgraduate course, and could not invoke the provisions of the DV Act as she did not fall within the definition of an "aggrieved person" under Section 2(a) of the Act. 

What were the Court's Observations? 

• On economic abuse under Section 3(d): The Court held that the definition of economic abuse includes deprivation of all or any economic or financial resources to which the aggrieved person is entitled under any law or custom, and that parents are morally obligated to provide basic amenities including health and education. 
• On the scope of Section 20(1)(d): The Court held that if the father's contention that a child is not entitled to maintenance or educational expenses on attaining majority were accepted, the expression "in addition to" employed in Section 20(1)(d) would be rendered otiose. 
• On a major daughter as an "aggrieved person": Relying on its earlier decision in Kum. Bhavana N. v. Sri Nagaraju S, the Court reiterated that a daughter, on attaining majority, falls under the definition of "woman" and may become an aggrieved person if she establishes that she has been subjected to domestic violence, and would be entitled to monetary reliefs sought on her behalf. 
• On reliance on Neelima Choure v. Vijay Choure (2025): The Court relied on the Supreme Court's recognition 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. 
• On reliance on Jagadesan v. State of Tamil Nadu (2015): The Court extensively referred to the Madras High Court's ruling 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. 
• On the width of Section 20: The Court held that Section 20 of the DV Act provides for monetary relief in addition to maintenance, and that the father must meet the educational expenses of the daughter, whether for undergraduate or postgraduate studies, since the expressions "but is not limited to" and "in addition to maintenance" have wide connotation and amplitude, leaving the Magistrate's power unrestricted. 
• On the father's financial capacity: The Court noted that the father's financial records demonstrated sufficient capacity to bear the expenses, referring to findings that he had acquired fixed assets worth over ₹1.34 crore in 2021 and had availed substantial loans over subsequent years. 
• On the argument regarding a bank loan: Rejecting the father's contention that the daughter could finance her studies through a bank loan, the Court held that this could not be a ground to interfere with the concurrent orders, since the daughter was not earning and was pursuing continuous education from undergraduate to postgraduate level. 
• On relief granted: The Court held that the Magistrate's power to grant monetary relief under Section 20 is not confined to the categories expressly enumerated in the provision and extends to directing payment of educational expenses where warranted. The revision petition was accordingly dismissed, and the concurrent orders directing payment of ₹16 lakh towards the daughter's postgraduate medical education were affirmed. 

What is Section 20 of the DV Act? 

About: 

• It is a social beneficial legislation enacted to protect women from domestic violence of all kinds. 
• It was brought into force on 26th October 2006. 
• It provides for effective protection of the rights of women who are victims of violence of any kind occurring within the family. 
• The preamble of the Act makes it clear that its reach extends to violence, whether physical, sexual, verbal, emotional, or economic, all of which are to be redressed by the statute. 

Section 20 of the DV Act: 

• Section 20 of the Domestic Violence Act empowers the court to issue orders for monetary relief aimed at covering expenses and losses incurred by the aggrieved person and any children due to domestic violence. 
• This relief may encompass expenses associated with medical treatment, loss of earnings, damage to property, and other consequential costs arising from the violence. 
• Section 20(1)(d) states that the maintenance for the aggrieved person as well as her children, if any, includes an order under or in addition to an order of maintenance under Section 125 of the Code of Criminal Procedure, 1973 (2 of 1974), or any other law for the time being in force.