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Kerala High Court Bars Maintenance for Unmarried Adult Christian Daughters Without Disability

The judge grounded the decision in Section 125 CrPC, citing the lack of any Christian personal‑law duty to support an adult daughter.

Overview

  • Justice Kauser Edappagath partly allowed RPFC No. 157 of 2021, setting aside maintenance for the major daughter while upholding the wife's award.
  • The court held that under Section 125(1)(c) CrPC (Section 144 BNSS), a daughter over 18 can claim maintenance only if she cannot support herself due to physical or mental abnormality or injury.
  • The bench noted that, unlike HAMA and Muslim personal law, Christian personal law contains no parallel obligation requiring a father to maintain an unmarried adult daughter.
  • The Family Court's direction to pay Rs 20,000 per month to the wife and Rs 30,000 as consolidated educational expenses was affirmed as reasonable given the husband's means.
  • The court found the wife's separate residence justified by care for an ailing son studying in Mumbai and reiterated that a wife's employment does not by itself defeat a maintenance claim.