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Issues Involved:
1. Determination of the nature of interest (full ownership vs. life interest) acquired by appellant no.1 under the will. 2. Applicability of Section 14(1) vs. Section 14(2) of the Hindu Succession Act, 1956. 3. Pre-existing legal rights of the widowed daughter under the Hindu Succession Act and the Hindu Adoptions and Maintenance Act. Detailed Analysis: 1. Determination of the Nature of Interest Acquired by Appellant No.1: The core issue revolves around whether appellant no.1, the widowed daughter of the testator, acquired full ownership of a 1/3rd interest in the suit land or merely a life interest under her father's will dated 21st August, 1959. The Trial Court ruled that appellant no.1 had only a life interest, which was not sufficient to bequeath to defendant no.2. Conversely, the District Judge, acting as the first appellate court, held that she had full ownership. The High Court, on second appeal, restored the Trial Court's view, concluding that appellant no.1 had only a life interest. 2. Applicability of Section 14(1) vs. Section 14(2) of the Hindu Succession Act, 1956: The appellants contended that Section 14(1) of the Hindu Succession Act applied, arguing that appellant no.1 had a pre-existing legal right to the property, which matured into full ownership upon the testator's death. The respondents countered that Section 14(2) applied, as the will conferred only a life interest, not a pre-existing right. 3. Pre-existing Legal Rights of the Widowed Daughter: The Supreme Court examined whether appellant no.1 had any pre-existing legal rights in the testator's estate prior to his death. The Court noted that under Section 8 of the Hindu Succession Act, appellant no.1, as a Class I heir, would have inherited the entire estate if the testator had died intestate. However, since the testator executed a will, appellant no.1's potential inheritance was merely a "spes successionis" (a chance to succeed), not a pre-existing legal right. The Court then turned to the Hindu Adoptions and Maintenance Act, 1956, specifically Sections 18 to 22. It found that appellant no.1, as a destitute widowed daughter, had a pre-existing right to maintenance from her father's estate. This right existed during the testator's lifetime and continued after his death, as per Sections 19(1)(a) and 22(2) of the Maintenance Act. The will's provision of a 1/3rd life interest was in lieu of this pre-existing right. Conclusion: The Supreme Court concluded that appellant no.1 had a pre-existing right of maintenance against her father's estate, which matured into full ownership under Section 14(1) of the Hindu Succession Act upon the testator's death. The High Court's application of Section 14(2) was incorrect. The judgment of the High Court was set aside, and the decree of dismissal of the respondents' suit by the District Judge was confirmed. Final Judgment: The appeal was allowed, setting aside the High Court's judgment and restoring the dismissal of the respondents' suit as decreed by the District Judge. No order as to costs was made.
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