Validity of Gift Deed in Property Dispute: Supreme Court Upholds Transfer After Decades

The case of Chaman Lal (D) Through LRs. vs. Kamlawati (D) Through LRs. is a significant ruling that clarifies the validity of a gift deed and the impact of prolonged inaction on legal claims in property disputes. The Supreme Court dismissed the appellant’s challenge, affirming that the entire land had been gifted, and the claim to reclaim a portion after decades had no merit.

The dispute involved a property in Dholewal, Ludhiana, where the appellant (Chaman Lal) had executed a gift deed in favor of his stepmother, Gurdev Kaur, in 1958. However, in 1987, he sought partition, claiming that only half the land had been gifted. The litigation journeyed through multiple appeals, ultimately reaching the Supreme Court, which upheld the High Court’s decision that the entire land was gifted.

Background of the Case

The case revolves around a piece of land measuring 3 Biswas and 11 Bighas. The sequence of events leading to the dispute is as follows:

Chaman Lal purchased the property from Mansa Ram on July 30, 1949.
On March 10, 1958, Chaman Lal executed a gift deed in favor of his stepmother, Gurdev Kaur.
In the revenue records (Jamabandi) of 1969-70, the entire land was mutated in Gurdev Kaur’s name.
In 1971, Gurdev Kaur sold the land to Kamla Wati.
The land was further resold in 1995 to the present respondents.
In 1987, Chaman Lal filed a suit for partition, claiming that only half of the land was gifted and he retained ownership of the other half.

Petitioner’s Arguments

The appellant (Chaman Lal’s legal representatives) argued the following points:

The gift deed only transferred half of the land, not the entire property.
The revenue records wrongly recorded the entire land in Gurdev Kaur’s name.
The trial court and the first appellate court rightly held that Chaman Lal was entitled to partition.
The High Court exceeded its jurisdiction by interfering with concurrent findings of fact.

Respondent’s Arguments

The respondents, represented by Kamla Wati’s legal representatives, countered with the following arguments:

The gift deed was clear and unambiguous, transferring the entire property to Gurdev Kaur.
Chaman Lal never objected when the entire land was mutated in Gurdev Kaur’s name in 1969-70.
He remained silent when Gurdev Kaur sold the land in 1971 and again when it was resold in 1995.
The challenge was barred by laches, as Chaman Lal waited almost three decades before filing suit.
The High Court correctly examined the translation of the gift deed and concluded that the entire land was transferred.

Supreme Court’s Observations

The Supreme Court, comprising Sanjay Kishan Kaul and K.M. Joseph, examined the validity of the High Court’s findings and made the following observations:

The language of the gift deed unambiguously conveyed the entire land to Gurdev Kaur.
The trial court and first appellate court erroneously concluded that only half the land was transferred.
The High Court correctly relied on the translation of the original document, which confirmed the transfer of the entire land.
The appellant’s delay of 30 years in challenging the gift deed significantly weakened his case.
The conduct of the appellant indicated that he had accepted the gift until the later legal challenge.

Critical Judgment Excerpt: “The gift deed can be read in one manner, and only in one manner. The status of the property is not liable to be disturbed after such a prolonged period, in the context of the facts and the legal position which has emerged since 10.3.1958.”

Final Decision

The Supreme Court dismissed the appeal and upheld the High Court’s ruling. It held that:

The entire property had been gifted to Gurdev Kaur.
The claim for partition was baseless and filed after an unreasonable delay.
The High Court was justified in setting aside the erroneous findings of the lower courts.
The respondents were the rightful owners of the land.

Implications of the Judgment

This ruling has significant implications for property law and legal challenges to transactions:

Once a property transfer is duly executed and recorded, later challenges must be backed by strong legal grounds.
Delays in filing property disputes can result in dismissal due to laches.
Revenue records serve as strong evidence of ownership, especially when not contested for decades.
Court translations of legal documents are binding if accepted by both parties.

The Supreme Court’s decision in Chaman Lal vs. Kamlawati reinforces the principle that property rights cannot be challenged decades later without substantial evidence of fraud or mistake. The ruling underscores the importance of timely legal action in property disputes.

Petitioner Name: Chaman Lal (D) Through LRs..
Respondent Name: Kamlawati (D) Through LRs..
Judgment By: Justice Sanjay Kishan Kaul, Justice K.M. Joseph.
Place Of Incident: Ludhiana, Punjab.
Judgment Date: 16-07-2019.

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