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Issues Involved:
1. Whether the limited estate given to the widowed daughter-in-law under a registered will dated 5.1.1921 enlarges into an absolute estate under Section 14(1) of the Hindu Succession Act, 1956. Detailed Analysis: Issue 1: Enlargement of Limited Estate into Absolute Estate under Section 14(1) of the Hindu Succession Act, 1956 The primary question in this appeal is whether the limited estate given to the widowed daughter-in-law under a will dated 5.1.1921 enlarges into an absolute estate under Section 14(1) of the Hindu Succession Act, 1956. The High Court erroneously concluded that the scope of Section 14(1) did not apply, failing to reference the three Judge Bench Judgment in Tulsamma and others vs. Sesha Reddy (1977) 3 SCC 99, which clearly explains the ambit of sub-sections (1) and (2) of Section 14 of the Hindu Succession Act. The facts of the case involve a suit filed by the predecessor-in-title of the respondents seeking a declaration that the sale of a suit house by the widowed daughter-in-law to the appellant will not bind him as he was the absolute owner. The sale was challenged on the grounds that the will provided only a limited interest in the suit house to the widowed daughter-in-law, and thus, the sale would not be binding after her death. The Trial Court dismissed the suit, observing that the widowed daughter-in-law derived only life interests under the will and had no right to execute the sale deed. The District Court reversed this decision, holding that the vendor had only a life interest and that Section 14(1) of the Hindu Succession Act did not apply, as the limited estate would not enlarge into an absolute estate due to the exception in Section 14(2). The High Court, after analyzing the will, concluded that the widowed daughter-in-law was only given a right to reside in the house during her lifetime and was debarred from alienating the property. Thus, she had a limited estate, and Section 14(1) did not apply. The Supreme Court, however, disagreed with the High Court's interpretation. Referring to the judgment in Tulsamma's case, it emphasized that a Hindu woman's right to maintenance is a pre-existing right recognized under Shastric Hindu Law, and any property given in recognition of this right would be held absolutely under Section 14(1) of the Hindu Succession Act, notwithstanding any restrictions placed in the will. The Court highlighted the principles laid down in Tulsamma's case: 1. Section 14(1) must be liberally construed to advance the object of enlarging the limited interest of a Hindu widow. 2. Sub-section (2) of Section 14 applies only to instruments creating new titles and not to those recognizing pre-existing rights. 3. The widow's right to maintenance is a tangible right against property, recognized by Shastric Hindu Law. 4. Any property given in lieu of maintenance confirms a pre-existing right and does not create a new title. The Supreme Court concluded that the property given to the widowed daughter-in-law was in recognition of her pre-existing right to maintenance. Therefore, she held the property absolutely under Section 14(1), and the restrictions on alienation in the will were void. The High Court's view that the widowed daughter-in-law had only a limited estate was incorrect. Conclusion: The Supreme Court allowed the appeal, setting aside the judgments of the District Court and the High Court. It held that the widowed daughter-in-law acquired absolute title to the suit house under the will, effectuating a pre-existing right, and dismissed the suit. No costs were awarded.
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