In a significant ruling on the educational rights of adult daughters, the Karnataka High Court has held that a father can be directed to bear the postgraduate educational expenses of his unmarried daughter under the Protection of Women from Domestic Violence Act, 2005. Dismissing a criminal revision petition, the Court refused to interfere with concurrent orders directing the father to pay ₹16 lakh towards his daughter's M.D. Dermatology course after finding that he possessed sufficient financial capacity and that the daughter had no independent income.
Background of the Case
The dispute arose after the petitioner's 23-year-old daughter secured admission to the M.D. Dermatology programme at Fr. Muller's Institute of Medical Education and Research, Mangaluru, through Karnataka Examination Authority (KEA) counselling. She informed the trial court that the total first-year educational expenses, including tuition, institutional charges, books and equipment, amounted to approximately ₹16 lakh.
According to her plea, she had already borrowed nearly ₹14 lakh from her grandfather to immediately pay the admission fee and required financial assistance to continue her studies. She contended that she had no independent source of income to meet the remaining educational expenses.
The father opposed the application. He argued that his daughter had already completed MBBS with his financial support and, being a major, could not compel him to fund postgraduate studies. He further claimed that she would receive a monthly stipend during her residency and questioned whether the Domestic Violence Act could be invoked by an adult daughter seeking educational expenses.
The trial court nevertheless directed him to pay ₹16 lakh under Section 20(d) of the Domestic Violence Act. The appellate court later affirmed that order, prompting the father to approach the High Court through a criminal revision petition.
Court's Observations
Justice H.P. Sandesh examined whether an unmarried daughter who had attained majority could seek monetary relief for higher education under Section 20 of the Domestic Violence Act.
The Court noted that the daughter had secured an All India Rank of 11,722 in the postgraduate NEET examination and had obtained admission through the prescribed counselling process. The records also established that she had already paid a substantial portion of the fees after borrowing money from her grandfather.
The Court also examined the father's financial position. The appellate court had relied on his income tax returns, bank records and loan documents showing acquisition of substantial assets and significant financial transactions over several years. These materials, the High Court observed, supported the finding that he possessed the financial capacity to bear his daughter's educational expenses.
Referring to recent Supreme Court precedent in Neelima Choure v. Vijay Choure, the Court observed that a daughter has a legally enforceable right to pursue education and that parents may be required to provide necessary educational support within the limits of their financial resources.
The Court further analysed Section 20 of the Domestic Violence Act and concluded that the expression "but is not limited to" gives the provision a broad scope. It held that monetary relief under the Act is not confined to basic maintenance but can also extend to educational expenses where justified by the facts of the case.
Rejecting the father's argument that the daughter should instead obtain an educational loan because she had attained majority, the Court emphasised that continuation from MBBS to postgraduate medical education formed part of the same educational journey and that her lack of independent earnings was an important consideration.
The Court observed,
"The daughter has a fundamental right to pursue her education, for which the parents could be compelled to provide necessary funds within the limit of their financial resources."
It further held,
"The father has to meet the educational expenses of the daughter whether it is for under graduation or post graduation."
Court's Decision
Finding no legal or factual error in the concurrent findings of the trial court and the appellate court, Justice H.P. Sandesh dismissed the criminal revision petition.
The High Court upheld the direction requiring the father to pay ₹16 lakh towards his unmarried daughter's postgraduate medical education, holding that her attainment of majority did not, by itself, extinguish her entitlement to seek educational expenses under the facts of the present case.
Case Details
Case Title: Vincent Correa v. Viyola Prathvi Correa
Case Number: Criminal Revision Petition No. 870 of 2026
Judge: Justice H.P. Sandesh
Decision Date: 17 July 2026
