Interim monetary relief for education expenses under domestic violence law may be granted purposively to address economic abuse.

Interim monetary relief under the Protection of Women from Domestic Violence Act may include lump-sum educational expenses and other urgent necessities, because Sections 20 and 23 are to be read purposively in light of the Act's remedial scheme against economic abuse. A separate affidavit was not treated as essential where the main application was already pending and the pleadings were duly verified, and the fact that the son had attained majority did not by itself defeat a claim for education-related support. The appellate monetary directions were partly modified to balance the parties' competing claims, while the balance of the relief was sustained.

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Issues: (i) Whether interim monetary relief under the Protection of Women from Domestic Violence Act, 2005 could include lump sum educational expenses and other monetary assistance at the interim stage under Section 23. (ii) Whether the absence of a separate affidavit and the fact that the son had attained majority barred the grant of interim relief. (iii) Whether the quantum and form of the appellate directions required interference.

Issue (i): Whether interim monetary relief under the Protection of Women from Domestic Violence Act, 2005 could include lump sum educational expenses and other monetary assistance at the interim stage under Section 23.

Analysis: Sections 20 and 23 were construed together with the definition of monetary relief and economic abuse. The expression in Section 20 that monetary relief is "not limited to" the listed items was treated as enlarging the Magistrate's power to grant relief for educational expenses and other necessities arising from domestic violence. The Court held that the Act is a beneficial and social welfare legislation and that interim relief under Section 23 may be granted to meet urgent needs during the pendency of the main proceeding, if the order is just and proper.

Conclusion: Interim lump sum monetary relief for educational expenses was held permissible under Section 23 read with Section 20.

Issue (ii): Whether the absence of a separate affidavit and the fact that the son had attained majority barred the grant of interim relief.

Analysis: The Court held that Section 23 does not require a separate application when the main application under Section 12 is already pending, and that the verification and affirmation in the application could satisfy the requirement of an affidavit in the facts of the case. On the question of majority, the Court held that the parental obligation to provide education and support is not extinguished merely because the child has attained majority, particularly when the claim arises from deprivation amounting to economic abuse under the Act.

Conclusion: The objections based on the absence of a separate affidavit and the son's majority were rejected.

Issue (iii): Whether the quantum and form of the appellate directions required interference.

Analysis: The Court held that the entire amount directed by the lower courts need not be sustained at the interim stage, but the son's educational needs and incidental expenses justified partial relief. The order directing payment of capitation fee in the manner originally fixed was not fully upheld, while the amount already ordered towards incidental expenses was sustained. The monthly maintenance was also adjusted, with future maintenance directed to the wife and arrears payable accordingly.

Conclusion: The revisional court interfered partly, reduced and restructured the monetary directions, and sustained the balance of the reliefs.

Final Conclusion: The proceeding was substantially upheld on the principle that the Domestic Violence Act permits interim monetary relief for educational and other necessary expenses, but the financial directions were modified to balance the parties' competing claims.

Ratio Decidendi: Under the Protection of Women from Domestic Violence Act, 2005, the Magistrate may grant interim lump sum monetary relief for educational and similar necessities at any stage of the proceedings, and such relief is to be construed purposively as part of the Act's remedial scheme against economic abuse.

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