Supreme Court Holds GPF Nomination Invalid Upon Marriage; Restores CAT Order Directing Equal Distribution Between Wife and Mother

Case Name: Smt. Bolla Malathi v. B. Suguna & Others
Citation: 2025 INSC 1391
Date of Judgment/Order: 05 December 2025
Bench: Sanjay Karol, J.; Nongmeikapam Kotiswar Singh, J.

Held: The Supreme Court held that the original GPF nomination in favour of the deceased employee’s mother became invalid when he “acquired a family” upon marriage in 2003, as clearly stipulated in the nomination form and under Rule 5(5)(b) of the GPF(CS) Rules, 1960. Even though the deceased failed to file a fresh nomination, the rules mandate that once the contingency occurs, the nomination does not subsist, and the GPF must be distributed among surviving family members as per Rule 33. The High Court erred in treating the original nomination as continuing in effect and in holding that no automatic invalidation occurs. Relying on Sarbati Devi, Shakti Yezdani and Shipra Sengupta, the Court reiterated that nomination only indicates the hand authorised to receive the amount; it does not confer beneficial ownership.

Summary: The deceased initially nominated his mother for GPF, CGEGIS and DCRG benefits. After his marriage in 2003, he filed fresh nominations for CGEGIS and DCRG in favour of his wife but did not update the GPF nomination. Upon his death in 2021, the employer refused the widow’s claim for GPF, citing the old nomination. The Central Administrative Tribunal held that the nomination became invalid upon marriage and directed equal distribution between the wife and mother under Rule 33. The High Court reversed the CAT, holding there was no automatic cancellation absent a written notice cancelling the earlier nomination. Before the Supreme Court, the appellant-wife argued that both the nomination form and Rule 33 required equal distribution when nomination becomes invalid. The mother argued that the deceased intentionally retained her as nominee for GPF. The Court rejected this contention, holding that the Rules expressly provide for invalidation upon the subscriber acquiring a family, and that failure to update the nomination does not preserve its validity. The Court emphasized that the rules exist precisely to address situations where subscribers neglect to update nominations.

Decision: The Supreme Court allowed the appeal, set aside the High Court’s judgment dated 11 February 2025, and restored the CAT’s order directing equal distribution of GPF between the wife and the mother. The Court noted that the wife had already been paid her half-share pursuant to CAT’s order and directed that the remaining amount deposited before the Registrar (Appellate Side) be released to the mother upon application. All pending applications were disposed of.