In Prathima v. Sundar (2025), the Madras High Court held that visitation rights must not adversely affect a child’s physical, emotional, or educational development. The wife, residing in Hosur and working in Bangalore, challenged a Family Court order directing her to bring the child to Chennai twice monthly. Justice M. Jothiraman ruled that the burden of facilitating visitation should not rest solely on the custodial parent, especially when the non-custodial parent provides no maintenance. Citing Yashita Sahu v. State of Rajasthan (2020) 3 SCC 67, the Court emphasized the child’s welfare as paramount. The order was modified to allow the father to meet the child at the Child Care Centre, Krishnagiri, on the same schedule. The Court reiterated that parental access should promote, not hinder, a child’s well-being and overall development.