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Issues Involved:
1. Scope and ambit of Section 14(1) and Section 14(2) of the Hindu Succession Act, 1956. 2. Whether life interest acquired under a will becomes absolute property under Section 14(1) of the Act. 3. Application of Section 14(1) and Section 14(2) to property acquired by a Hindu female under a will or other instruments. Detailed Analysis: Issue 1: Scope and Ambit of Section 14(1) and Section 14(2) of the Hindu Succession Act, 1956 Section 14(1) of the Act states, "Any property possessed by a female Hindu, whether acquired before or after the commencement of this Act, shall be held by her as full owner thereof and not as a limited owner." The explanation includes various forms of property acquisition. Section 14(2) specifies that sub-section (1) does not apply to property acquired by way of gift, will, or any other instrument where the terms prescribe a restricted estate. The Court clarified that Section 14(2) is an exception to Section 14(1) and applies only if the acquisition is made for the first time without any pre-existing right in the female Hindu. The objective of Section 14(1) is to remove disabilities imposed by law on women and to achieve social and economic equality. Issue 2: Whether Life Interest Acquired Under a Will Becomes Absolute Property Under Section 14(1) of the Act In the case of Civil Appeal No. 630 of 1981, the plaintiff claimed absolute rights in the suit properties after the lifetime of the defendant, who had acquired life interest under her husband's will. The Trial Court and the First Appellate Court upheld the plaintiff's claim, but the High Court reversed the decision, dismissing the suit. The Supreme Court held that the life interest acquired by the defendant under the will became her absolute property under Section 14(1) of the Act, as she was in possession of the property with a pre-existing right to maintenance. Issue 3: Application of Section 14(1) and Section 14(2) to Property Acquired by a Hindu Female Under a Will or Other Instruments The Court examined various precedents, including Badri Prashad v. Smt. Kanso Devi and V. Tulsamma v. V. Sesha Reddy, which established that Section 14(1) applies to properties where the female Hindu had a pre-existing right. The case of Mst. Karmi v. Amru was distinguished as it did not consider the provisions of Sections 14(1) and 14(2) in detail. In Special Leave Petition (C) No. 438 of 1979, the widow's limited interest under a compromise decree was held to have been enlarged into an absolute right by virtue of Section 14(1). In S.L.P. (C) No. 2113 of 1980, the widow's limited estate under a will was similarly enlarged into absolute ownership under Section 14(1), as she had a pre-existing right to maintenance. Conclusion: The Supreme Court reaffirmed that Section 14(1) of the Hindu Succession Act, 1956, aims to convert the limited estate of a female Hindu into absolute ownership if she had a pre-existing right to the property. Section 14(2) applies only when the property is acquired for the first time under a will or other instrument without any pre-existing right. The appeals and special leave petitions were dismissed, confirming the enlargement of limited estates into absolute ownership under Section 14(1).
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