Virginia Code

Va. Code Ann. § 8.01-186 (2026)

Further relief

✓ current as of May 2026

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Further relief based on a declaratory judgment order or decree may be granted whenever necessary or proper. The application shall be by motion to a court having jurisdiction to grant the relief. If the application is deemed sufficient the court shall, on reasonable notice, require an adverse party whose rights have been adjudicated by the declaration of right to show cause why further relief should not be granted forthwith.

Code 1950, § 8-581; 1977, c. 617.

Notes of Decisions

Cited in 11 cases (1 in the last 5 years), 1992–2026 · leading case: Russell Cnty. Dep't of Soc. Servs. v. O'Quinn, 523 S.E.2d 492 (Va. 2000).

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Russell Cnty. Dep't of Soc. Servs. v. O'Quinn, 523 S.E.2d 492 (Va. 2000). · cites it 10× “The primary issue we consider in this appeal is whether Code §§ 8.01-186 and -191, which are contained in the Virginia Declaratory Judgment Act, authorize a circuit court to award attorney’s fees to a prevailing litigant.”

Chapman v. Clarendon Nat'l Ins., 299 F. Supp. 2d 559 (E.D. Va. 2004). · cites it 4× “that [plaintiff] shall be awarded his costs and expenses, and attorney’s fees, in accordance with Section 8.01-186 and/or Section 8.01-190, Code of Virginia, as amended, and as the law may otherwise permit.”

Upper Occoquan Sewage Auth. v. BLAKE CONST., 655 S.E.2d 10 (Va. 2008). · cites it 2× “" On November 26, 2003, the Joint Venture filed a motion pursuant to Code § 8.01-186 asserting that it was entitled to additional compensatory damages.”

Indian Creek Monument Sales v. Adkins, 301 F. Supp. 2d 555 (W.D. Va. 2004). · cites it 4× “The plaintiffs would there have normal appellate procedures available to them, with possible final review in the United States Supreme Court.”

City of Richmond City Council v. Wilder, 74 Va. Cir. 382 (Richmond County Cir. Ct. 2007). · cites it 3× “tor’s letter, and the Separation Notice are null and void and without legal effect; To retain jurisdiction over this matter and that it remain on the docket for a reasonable time for the Defendants to take any actions that are consistent with the declaration sought, and to…”

Blaylock v. City of Richmond, 29 Va. Cir. 148 (Richmond County Cir. Ct. 1992). · cites it 7× “Retroactivity Virginia Code § 8.01-186 provides: Further relief based on a declaratory judgment order or decree may be granted whenever necessary or proper.”

Koski v. Repub. Nat'l Comm. (ORDER) (Va. 2026). · cites it 2× “01-184, and provides that “[f]urther relief based on a declaratory judgment order or decree may be granted whenever necessary or proper,” Code § 8.01-186. See Berry v. Board of 2 court colleague to bring this case to closure as soon as reasonably possible in light of the…”

Culpeper Cnty. Dep't of Soc. Servs. v. Sharman, 79 Va. Cir. 141 (Culpeper Cir. Ct. 2009). · cites it 3× “The Department responds that it has properly chosen a way to present this controversy, constituting an antagonistic assertion of rights, to the court, particularly when Va. Code §8.01-186, it says, provides a means for the court to grant further relief under § 8.”

Kontzias v. CVS, Inc., 44 Va. Cir. 161 (Fairfax Cir. Ct. 1997). · cites it 3× “In addition, Kontzias asserts that an action for declaratory judgment may be maintained even where other remedies exist, based on the language contained in § 8.01-186, which provides that “[fjurther relief based on a declaratory judgment order or decree may be granted whenever…”

Front Royal v. Town of Front Royal, 29 Va. Cir. 226 (Warren Cir. Ct. 1992). · cites it 3× “It is instructive to note that monetary relief may be available in other similar actions, including declaratory judgment actions and constitutional “taking” cases.”

Estes v. Powell, 73 Va. Cir. 370 (Madison Cir. Ct. 2007). “” Furthermore, § 8.01-186 provides the court with the authority to grant further relief in any declaratory judgment order “whenever necessary or proper.”

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