Summary of this article
Delhi HC says child’s PPF savings cannot offset maintenance obligations.
Father must return Rs.8.13 lakh withdrawn from daughter’s PPF.
Court treats child’s investment corpus separately from parental maintenance duties.
A father cannot use the funds invested in his daughter’s Public Provident Fund (PPF) account to offset his legal responsibility to maintain her, the Delhi High Court has held. The Delhi High Court pronounced the judgment on August 3, 2026, and dismissed an appeal filed by the father against a lower court order directing him to pay Rs 8,13,853.79 to his daughter, along with interest at 8 per cent (Sudhir Kawatra vs Shamli Kawatra).
Father Withdrew Rs 8.13 Lakh From PPF
The PPF account was opened by the father in his daughter’s name in 1999 when she was a minor. The account matured in 2016, after which the father withdrew the entire amount of Rs 8,13,853.79. At the time of withdrawal, the father gave an undertaking to the bank that the money would be used for his daughter’s higher education and well-being.
The daughter later sought the amount after attaining majority. She claimed that the money had not been used for her benefit. She subsequently filed a recovery suit seeking Rs 8,13,853.79 along with interest.
The father admitted withdrawing the money, but argued that he had already spent money on his daughter’s welfare. He said he had paid Rs 6 lakh as maintenance under an order of the Family Court and that this amount should be adjusted against the PPF corpus.
Maintenance And Investment Are Separate
The high court rejected this argument, holding that a parent’s responsibility to maintain a child is an independent legal obligation. The court said that investments made during a child’s childhood are intended to create a corpus for future use, while maintenance covers the day-to-day expenses involved in raising the child. Therefore, money saved for the child cannot be used to discharge the parent’s maintenance responsibility.
The court also rejected the argument that maintenance paid to the daughter’s mother could be considered against the daughter’s entitlement to the PPF money.
Father Held Money As Guardian
The court has clarified that the closure of the PPF account itself was not illegal. The question was who was entitled to the money after it was withdrawn. Although the father had made contributions to the account, the investment was in his daughter’s name and was intended for her benefit. After she became a major, she was entitled to receive the money, the court said.
The court further said that the father had taken the money in his capacity as guardian, but could not transfer it to his own account and treat it as his money. The Delhi High Court upheld the lower court’s decision to award the daughter the entire Rs 8,13,853.79 with 8 per cent interest and dismissed the appeal.
Implications Of The Ruling
The judgment distinguishes between a child’s investment corpus and a parent’s maintenance obligation. It establishes that money invested for a child’s future cannot be used by a parent to meet a separate legal responsibility to maintain the child.
