Inheritance Dispute: Supreme Court Rules on Life Interest vs Absolute Ownership in Property

The Supreme Court of India recently ruled on a complex inheritance dispute between family members regarding property ownership. The case involved Mr. Ranvir Dewan (appellant) and Mrs. Rashmi Khanna & Anr. (respondents), centering on the interpretation of a will and whether the testator’s wife had acquired absolute ownership or only a life interest in the property.

Background of the Case

The case revolved around a residential house in Defense Colony, New Delhi, owned by the late Mr. B.R. Dewan. Mr. Dewan had two wives—Kamla Devi and Pritam. He had one son from his first wife and two children, Ranvir (the appellant) and Rashmi (respondent no.1), from his second wife, Pritam.

Mr. Dewan executed a will on 24.06.1984, distributing his assets among his family members. The key aspects of the will concerning the disputed property were:

• The ground floor was given to his son, Ranvir Dewan (appellant), with full ownership.
• The first floor was given to his daughter, Rashmi Khanna (respondent no.1), with full ownership.
• His wife, Pritam, was granted a life interest in the property, allowing her to reside there and collect rent for maintenance.

The will also specified that after Pritam’s death, the property would belong to the son and daughter in accordance with their respective floors.

Legal Dispute

After Mr. Dewan’s death on 16.09.1984, the will was probated and executed. However, disputes arose over property rights:

• Pritam and her son, Ranvir, argued that her life interest should be converted into absolute ownership under Section 14(1) of the Hindu Succession Act.
• Rashmi, the daughter, contended that the will clearly gave only a life interest to Pritam, which should be governed by Section 14(2) of the Hindu Succession Act, preventing its conversion into absolute ownership.

Trial Court Decision

Pritam and Ranvir filed a civil suit in the Delhi High Court, seeking a declaration that Pritam had full ownership rights over the property, including the second and third floors.

The Single Judge of the Delhi High Court dismissed the suit on 11.10.2013, holding that:

• Pritam had only a life interest as per the clear wording of the will.
• Section 14(2) of the Hindu Succession Act applied, which prevented her from gaining absolute ownership.

Appeal Before the Division Bench

Ranvir and Pritam filed an appeal (RFA(OS) No. 147 of 2013) before the Division Bench of the Delhi High Court. On 13.07.2016, the Division Bench upheld the Single Judge’s ruling, affirming that:

• The testator’s will was clear in granting Pritam only a life interest.
• The case fell under Section 14(2) of the Hindu Succession Act, not Section 14(1).

Arguments Before the Supreme Court

Appellant’s Arguments:

• Pritam’s life interest should be converted into full ownership under Section 14(1) of the Hindu Succession Act.
• Since a wife is legally entitled to maintenance from her husband, granting her a life interest was a recognition of that right, which should be enlarged into absolute ownership.

Respondent’s Arguments:

• The will was unambiguous and granted only a life interest to Pritam.
• The case fell under Section 14(2) of the Hindu Succession Act, as the property was bequeathed through a will with specific conditions.
• As per legal precedents, a testator can grant a restricted estate under Section 14(2), and it does not automatically convert into absolute ownership.

Supreme Court’s Observations

The Supreme Court bench, consisting of Justices R.K. Agrawal and Abhay Manohar Sapre, analyzed the will’s provisions and upheld the previous rulings.

On the Nature of Life Interest:

“The testator gave the suit house in absolute ownership to his son and daughter while conferring only ‘life interest’ on his wife, which he had the legal right to do. This is permissible under Section 14(2) of the Act.”

On the Applicability of Section 14(2):

“Since the wife was given only a right to reside in the property and collect rent, without full ownership rights, the life interest did not convert into absolute ownership. Section 14(2) applies, preventing its enlargement into absolute ownership.”

On the Precedents Supporting Section 14(2):

“The ruling in Sadhu Singh vs. Gurudwara Sahib Narike (2006) 8 SCC 75 supports this view, holding that where a will grants only a life interest, it remains a restricted estate.”

Final Judgment

The Supreme Court dismissed the appeal, affirming that:

• Pritam had only a life interest in the property.
• After Pritam’s death, her life interest expired, and ownership rights reverted to the son and daughter as per the will.
• Section 14(2) of the Hindu Succession Act applied, preventing any conversion of the life interest into full ownership.

Key Takeaways

• Under Hindu Succession law, if a will expressly grants only a life interest, it remains a restricted estate under Section 14(2).
• A wife’s right to maintenance does not automatically convert a life interest into full ownership.
• A testator has the legal authority to create a limited interest in property through a will.
• This ruling reaffirms the distinction between Sections 14(1) and 14(2) of the Hindu Succession Act.

The judgment serves as an important precedent in property inheritance disputes, clarifying the legal principles governing life interest and absolute ownership under Hindu law.

Don’t miss out on the full details! Download the complete judgment in PDF format below and gain valuable insights instantly!

Download Judgment: Ranvir Dewan vs Rashmi Khanna & Anr. Supreme Court of India Judgment Dated 12-12-2017.pdf

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