Restricted Life Interest Does Not Convert to Absolute Ownership, Rules Supreme Court

The Supreme Court of India recently clarified in the case of Kallakuri Pattabhiramaswamy (Dead) Through Lrs. V. Kallakuri Kamaraju & Ors that under the Hindu Succession Act, 1956, a Hindu woman granted only a restricted life interest in property cannot claim absolute ownership of that property. The judgment, interpreting Section 14 of the Act, highlights the distinction between life interest and absolute ownership based on pre-existing rights or provisions of a legal document.

The Court explained that Section 14(1) of the Hindu Succession Act transforms a woman’s limited estate into absolute ownership if the property was acquired through a pre-existing right, such as in lieu of maintenance. However, when a property is expressly given as a restricted life interest through a legal instrument, it remains limited under Section 14(2), and absolute ownership does not arise.

This ruling came while resolving a dispute involving 3.55 acres of land. The bench, comprising Justice C.T. Ravikumar and Justice Sanjay Karol, rejected the defendants’ claim of absolute ownership, which they argued was inherited through a will executed by their mother, Smt. Veerabhadramma.

The case revolved around a partition deed executed in 1933. Under the deed, Smt. Veerabhadramma was granted a life interest in the property, with a stipulation that it would pass to other legal heirs upon her death. After her demise, the plaintiff-respondent sought a partition of the property as per the terms of the deed, which the defendants opposed, asserting that their mother had transferred the property to them through a will.

The trial court ruled in favor of the plaintiff, concluding that the partition deed granted only a life interest to Smt. Veerabhadramma, and her rights did not transform into absolute ownership under Section 14(1). The High Court upheld this decision, leading to the appeal before the Supreme Court.

The Supreme Court affirmed the decisions of the lower courts, ruling that the restricted life interest granted to Smt. Veerabhadramma could not transform into absolute ownership. Justice Sanjay Karol, delivering the judgment, emphasized that Smt. Veerabhadramma did not possess any pre-existing rights under Section 14(1) that would entitle her to claim absolute ownership.

The Court observed that Property given to a woman in lieu of maintenance can convert into absolute ownership under Section 14(1). However, when a deed explicitly restricts ownership to a life interest, Section 14(2) applies and plays its role in preventing such transformation. The 1933 partition deed clearly restricted the property’s enjoyment to Smt. Veerabhadramma during her lifetime and specified its succession thereafter.

By dismissing the appeal, the Supreme Court reinforced the distinction between absolute ownership and restricted life interest under the Hindu Succession Act. The ruling ensures adherence to legal instruments that limit property rights and upholds the principle that absolute ownership arises only from pre-existing rights or in fulfillment of maintenance obligations. This judgment provides clarity on the application of Sections 14(1) and 14(2), emphasizing that restricted rights cannot be unilaterally expanded to confer absolute ownership.