Wednesday, 6 May 2015

Whether father is liable to maintain unmarried adult daughter?



A Bombay High Court Bench comprising of Justice A.P. Bhangale and Justice A.S. Oka has upheld the constitutional validity of subsection 3 of section 20 of the Hindu Adoption and Maintenance Act, 1956.
It is also held that the applicability of Hindu Adoption and Maintenance Act, 1956 does not depend upon the nationality of the child or domicile of the child. If both the parents of the child are either Hindu or Buddhist or Jain or Sikh by religion, the said Act becomes applicable to such children.
The Petitioner, Mr. Ramesh Gajanan Rege had challenged constitutional validity of subsection 3 of section 20 of the Hindu Adoption and Maintenance Act, 1956.
The respondent daughter had filed a petition under Section 20 of the Act before the Family Court at Pune in 2005. She was 16 years old then. The petition had prayed for grant of maintenance at the rate of Rs.50, 000/per month and for issuing a direction to provide a residence to her.
The petitioner father had contended that the daughter is a British citizen and she is not domiciled in India. Apart from granting injunction against the petitioner, the Judge of the Family Court directed the petitioner to pay interim alimony of Rs.10, 000 to the daughter.
The Petitioner had then challenged the validity of Section 20 (3) of the Act, contending that it is violative of the fundamental rights of the petitioner guaranteed under Articles 14 and 15 of the Constitution of India.
This was because sub section 3 places an obligation over a person to maintain his daughter who is unmarried when she is unable to maintain herself. He thereby submitted that there is no reason to discriminate between a son and a daughter. He urged that if a father is under no obligation to maintain unmarried son after he attains majority, there is no reason to grant such a benefit to the unmarried daughter. His submission was that there is no justifiable reason to protect only a daughter. He, therefore, urged that the provision of subsection (3) is arbitrary and is violative of Article 14 of the Constitution of India.
He urged that the said provision is also violative of Article 15 which prohibits discrimination on the ground of sex. He urged that it is unjust to put responsibility on the parents to maintain an unmarried daughter even after she attains majority as the daughter may choose to remain unmarried forever.
He also submitted that his daughter is not domiciled in India and is not a citizen of India. Therefore, the Act won’t be applicable to her. Rejecting this contention, the Court observed, “The question of applicability of the said Act is different from the territorial jurisdiction of the Court to entertain the proceedings under the said Act.”
Dismissing the contention as to violation of Article 14 of the Constitution of India, the Court observed, “Sub-section (3) operates independently of subsection (2). It seeks to protect an unmarried daughter even after she attains majority. A person is under an obligation to maintain his or her daughter who is unmarried and who is unable to maintain herself. The class of unmarried sons who have attained majority is completely different from the class of unmarried daughters who have attained majority. The reason being the peculiar position of a daughter and especially an unmarried daughter in Hindu society. Therefore, the argument that two equals are being treated as unequals is not at all acceptable and therefore, Article 14 will have no application.”
The Court also rejected the contention of violation of Article 15 of the Constitution of India, in view of clause (3) of Article 15.

IN THE HIGH COURT OF JUDICATURE AT BOMBAY
CIVIL APPELATE JURISDICTION
WRIT PETITION NO.10312 OF 2014
Ramesh Gajanan Rege
vs.
Gauri Ramesh Rege
Union of India 


CORAM : A.S.OKA, &
   A.P.BHANGALE, JJ.
         DATE  : MARCH 18, 2015

Constitution of India, the petitioner has challenged 
the   constitutional   validity   of   sub­section   3   of 
section   20   of   the   Hindu   Adoption   and   Maintenance 
Act,1956 (for short “the said Act”).
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Few   facts   of   the   case   are   necessary   to   be 
considered   with   a   view   to   appreciate   the   factual 
controversy. The first respondent is the daughter of 
the present petitioner.   The first respondent filed 
a petition under section 20 of the said Act before 
the   Family   Court   at   Pune.     When   the   petition   was 
filed   in   the   year   2005,   the   age   of   the   first 
respondent was 16 years.   A prayer was made in the 
petition filed by the first respondent for grant of 
maintenance at the rate of Rs.50,000/­ per month and 

for issuing   a direction to provide a residence to 
her.   The contention of the petitioner is that the 
first respondent is a British citizen and she is not 
domiciled in India.  An application was made by the 
petitioner for rejection of the said petition filed 
by the first respondent.  The said application along 
with   interim   application   in   the   said   petition   were 
decided by the learned Judge of the Family Court by 
order   dated   9th  August   2005.     Thereafter,   an 
application   was   made   by   the   first   respondent   for 
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grant   of   educational   expenses.   An   application   was 
made by the petitioner for cancellation of order of 
interim maintenance granted under the order dated 9 th 
August   2005.     By   the   said   order   dated   9 th  August 
2005, the prayer of the petitioner for rejection of 
the   petition   filed   by   the   first   respondent   was 
rejected. Apart from granting injunction against the 
petitioner,   the   learned   Judge   of   the   Family   Court 
directed   the   petitioner   to   pay   interim   alimony   of 
Rs.10,000/­ to the first respondent. 

The said application made by the petitioner for 
cancellation   of   the   order   of   interim   maintenance 
dated   9th  August   2005   was   rejected   by   the   learned 
Judge of the Family Court by order dated 16 th October 
2012.     We   must   note   here   that   there   is   no 
substantive   prayer   made   in   this   petition   for 
challenging   the   orders   passed   by   the   Family   Court. 
The substantive prayers are prayers (a) and (b).  

The   submission   of   the   learned   counsel   for   the 
petitioner is that sub­section (3) of section 20 of 

the said Act is violative of the fundamental rights 
of   the   petitioner   guaranteed   under   Articles   14   and 
15  of the Constitution of India. His submission is 
that  as far as the sub­section (2) of section 20 of 
the said Act is concerned, it makes no distinction 
between a male or a female child.  His submission is 
that   under   sub­section   (3)   of   section   20,   the   law 
provides   that   it   is   the   obligation   of   a   person   to 
maintain his daughter who is unmarried when she is 
unable   to   maintain   herself.     The   learned   counsel 

submitted   that   there   is   no   reason   to   discriminate 
between a son and a daughter.   He urged that if a 
father is under no obligation to maintain unmarried 
son after he attains majority, there is no reason to 
grant such a benefit to the unmarried daughter.  His 
submission is that there is no justifiable reason to 
protect only a daughter.   He, therefore, urged that 
the provision of sub­section (3) is arbitrary and is 
violative   of   Article   14   of   the   Constitution   of 
India.     He   urged   that   the   said   provision   is   also 
violative   of   Article   15   which   prohibits 
discrimination on the ground of sex.  He urged that 
it is unjust to put responsibility on the parents to 
maintain   an   unmarried   daughter   even   after   she 
attains   majority   as   the   daughter     may   choose   to 
remain unmarried for ever. 

He urged that the first respondent daughter is 
not a citizen of India and she is not domiciled in 
India.   He, therefore, submitted that the said Act 
is not applicable to the first respondent. He urged 
that the first respondent is very affluent.

We deal with the first submission in support of 

plea   that   sub­section   (3)   of   section   20   is 
unconstitutional.   Section 20 of the said Act reads 
thus: 
“(3) The   obligation   of   a   person   to   maintain 
his   or   her   aged   or   infirm   parent   or   a 
daughter who is unmarried  extends in so far 
as the parent or the unmarried daughter, as 

the   case   may   be,   is   unable   to   maintain 
himself   or   herself   out   of   his   or   her   own 
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earnings or other property.”
Sub­sections (1) and (2) of section 20 apply to 
a child whether male or female.  Obligations created 
by   sub­sections   (1)   and   (2)   of   section   20   to 
maintain are in relation to the sons or daughters so 
long   as   they   do   not   attain   majority.     Sub­section 
(3)   of   section   20   is   applicable   to   an   unmarried 
daughter   who   may   have   attained   majority.     Sub­
section   (3)   operates   independently   of   sub­section 
(2).  It seeks to protect an unmarried daughter even 
after   she   attains   majority.     A   person   is   under   an 
obligation   to   maintain   his   or   her   daughter   who   is 
unmarried   and   who   is   unable   to   maintain   herself. 
The   class   of   unmarried   sons   who   have   attained 
majority   is   completely   different   from   the   class   of 
unmarried   daughters   who   have   attained   majority. 
The   reason   being     the   peculiar   position   of   a 
daughter   and   especially   an   unmarried   daughter   in 
Hindu   society.     Therefore,   the   argument   that   two 

equals are being treated as unequals is not at all 
acceptable   and   therefore,   Article   14   will   have   no 
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application. 
For   the   same   reason,   Article   15   will   have   no 
application.     Moreover   clause   (3)   of   Article   15 
specifically provides that nothing in the Article 15 
shall   prevent   the   State   from   making   any   special 
provision   for   women   and   children.     Sub­section   (3) 
of   section   20   is   a   special   provision   within   the 

meaning   of   clause   (3)   of   Article   15.   As   stated 
earlier,   the   class   of   unmarried   major   sons   is 
different from the class of unmarried major daughter 
and,   therefore,   the   discrimination   which   is 
prohibited under Article 15 is not at all attracted. 
Therefore, challenge to the constitutional validity 
must fail. 

As   far   as   applicability   of   the   said   Act   is 
concerned, the same applies to all persons named in 
section 2.   It applies to any child, legitimate or 
illegitimate,   both   of   whose   parents   are   Hindu, 
Budhist,   Jaina   or   Sikh   by     religion.     The 
applicability of the said Act does not depend upon 
the   nationality   of   the   child   or   domicile   of   the 
child.  If both the parents of the child are either 
Hindu or Buddhist or Jaina or Sikh by religion, the 
said   Act   becomes   applicable   to   such   children. 
Moreover,   as   per   sub­section   (1)   of   section   20   of 
the said Act, the obligation to maintain his other 
children is of a   person who is Hindu by religion. 
Therefore, applicability of the Act does not depend 

on the nationality or domicile of the child.  We are 
not   dealing   with   a   parent   who   is   not   domiciled   in 
India. Whether section 20 will apply to a parent who 
is not domiciled in India or who is not a citizen of 
India is an altogether separate issue.  
The   question   of   applicability   of   the   said   Act 
is   different   from   the   territorial   jurisdiction   of 
the   Court   to   entertain   the   proceedings   under   the 

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said Act. 
Therefore,   we   find   no   merit   in   both   the 
contentions raised by the petitioner.   The petition 
deserves to be rejected.   However, We have made no 
adjudication   on   the   merits   of   the   pending 
proceedings.
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Writ Petition is rejected.     
     
(A.P.BHANGALE,J.)
(A.S.OKA,J.)
                 

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