The Madhya Pradesh High Court recently held that a father-in-law is not legally obligated to provide maintenance to his widowed daughter-in-law under the Protection of Women from Domestic Violence Act, 2005, or Muslim personal law.

The ruling, delivered by Justice Hirdesh, overturned a lower court's directive that had ordered the father-in-law to pay ₹3,000 per month as maintenance to his late son’s widow. The High Court emphasized that neither Muslim personal law nor the DV Act mandates such a financial obligation.

This case originated when the widow, who married the petitioner’s son in 2011 and lost her husband in 2015, filed a domestic violence complaint seeking ₹40,000 in monthly maintenance due to her financial needs. The petitioner contested this, arguing that he was under no legal duty to support her. Despite his stance, the trial court initially ruled in her favor, a decision later upheld by a sessions court.

In his defense, the petitioner’s counsel cited Muslim personal law, which does not require a father-in-law to maintain his widowed daughter-in-law. The counsel highlighted the petitioner’s advanced age and limited means and referenced a similar ruling from the Calcutta High Court in Shabnam Parveen v. State of West Bengal to bolster this argument.

The fact that the widow had been residing separately from her in-laws, even during her husband’s life, was also presented as evidence that no financial obligation was expected from the father-in-law.

The High Court clarified that Muslim personal law does not impose any financial maintenance duty on a father-in-law for a widowed daughter-in-law. Justice Hirdesh noted that such responsibilities do not traditionally extend to the husband's family after his passing.

Additionally, the Court examined the scope of the DV Act, pointing out that it aims to protect women from domestic violence within the household but does not establish a financial dependency or maintenance duty on extended family members after the husband’s death. The DV Act, while protective, does not override personal laws like those governing maintenance obligations in Muslim law.

The Court found that the trial court had overstepped by ordering the father-in-law to pay maintenance without adequately considering these legal limits.

Justice Hirdesh noted that imposing maintenance on the petitioner, especially without a legal foundation, could create unnecessary financial strain for individuals who bear no such duty under the law.

Moreover, the Court considered the family dynamics, observing that the widow’s separate residence even before her husband's death further suggested her independence and that maintenance responsibility should not automatically fall on the father-in-law. Based on these findings, the High Court set aside the trial court’s order, underscoring that maintenance rulings must adhere to established legal principles and avoid imposing undue burdens where no statutory obligation exists.