Section 14(1) Hindu Succession Act Converts Widow’s Limited Estate into Absolute Ownership; Compromise Decree Can Extinguish Legatees’ Claims

Case Name: V. Kalyanaswamy (D) by LRs. & Anr. v. L. Bakthavatsalam (D) by LRs. & Ors.

Citation: 2020 INSC 455

Date of Judgment/Order: July 17, 2020

Bench: Sanjay Kishan Kaul, J.; K.M. Joseph, J

Held: The Supreme Court held that where a Hindu widow had a limited estate in the property, that limited estate “bloomed” into absolute ownership by operation of Section 14(1) of the Hindu Succession Act, 1956, and once she became absolute owner and thereafter entered into a compromise decree relinquishing her rights in favour of the rival branch, no right could vest in persons claiming through a will/legatee route to defeat the title flowing from her absolute ownership and compromise.

Summary: These connected civil appeals arose out of two suits over the same properties: one filed by the branch claiming under Lakshmiah Naidu, and the other by a claimant asserting rights as a legatee under a will allegedly executed by Rangaswami Naidu, who died in 1955 leaving his widow R. Krishnammal and no children. The Court examined the competing foundations survivorship/joint family claims, the genuineness and proof of the will (including the permissibility of secondary evidence), the plea of partition/divided status, and the effect of earlier litigations and decrees before reaching the central conclusion on the widow’s estate. The Court held that since Rangaswami Naidu died before the Hindu Succession Act came into force, the widow initially held only a limited estate, but that limited estate enlarged into an absolute estate under Section 14(1); consequently, when she compromised in O.S. No. 71 of 1958 giving up her rights over the relevant properties, the compromise conferred effective rights on the Lakshmiah Naidu branch, leaving no transferable right in the alleged legatee line to sustain their claim against the respondents’ title.

Decision: The Supreme Court found no merit in the appeals and dismissed all the appeals, holding that in view of its findings especially that R. Krishnammal became absolute owner under Section 14(1) and had relinquished her rights by the 1958 compromise decree no enforceable right vested in the appellants’ chain; there was no order as to costs.