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Lady Ramabai W/O. Parashuram Bhau ... vs Pranaya Parshuram Patwardhan And Ors. on 23 December, 2005

In the case of Eramma (supra) it had been held that in order to acquire full title under Section 14 of the HSA the widow should have acquired some kind of title to that property. It is held that therefore, under Section 14(1) any illegal possession of Hindu female is not contemplated. It would therefore, not confer any title on a mere trespasser.
Bombay High Court Cites 46 - Cited by 0 - H L Gokhale - Full Document

M.Krishnamoorthy vs K.Pondeepankar on 28 April, 2017

One with reference to coparcenery property and the other with reference to self acquired property. By proviso to Section 6, the effect devolution of interest in the coparcenary property on the coparcener is the same. What is distinct is the inheritance of interest of the male Hindu that remains, after the notional partition and not the entire coparcenary property. This difference has been highlighted by the Hon'ble Supreme Court in Eramma vs Verrupanna & Ors reported in AIR 1966 SC 1879 as well as in Gurpad Khandappa Magdum vs. Hirabai Khandappa Magdum and others reported in AIR 1978 SC 1239.The Hon'ble Supreme Court observed as follows:

Daya Singh (Dead) Through L.Rs. & Anr vs Dhan Kaur on 5 March, 1974

-visions of the Hindu Women's Right to property Act, 1937, she would become a full owner under s. 14. In both those cases S. 8 would have no operation. It is only in rare cases, like the present, that the question is likely to arise at all and we can see no reason either in principle or on authority why the principle consistently followed under the earlier Hindu Law that on the death of the limited owner succession opens and would be decided on the basis that the last male owner died on that day, should not apply even after coming into force of the Hindu ,Succession Act, Mr. Naunit Lal appearing for the appellant argued that the result ,of the decision of this Court in Eramma v. Verrupanna (supra) is that on the death of Wadhawa Singh's widow it is the old Hindu Law that applied and therefore under the custom in force in Punjab under which a daughter was not entitled to succeed to the ancestral property of the father in preference to the reversioners should apply and the appellants are entitled to succeed. There is no doubt about the position under the Customary Law of Punjab before coming into force of the Hindu Succession Act. In Rattigan's Digest of the Customary Law' published by the University Book Agency (14th Ed.), paragraph 23 at age 132 it is stated:
Supreme Court of India Cites 15 - Cited by 18 - A Alagiriswami - Full Document

Baliammal (Died) vs Valliammal (Died)

“14.A plain reading of sub-section (1) makes it clear that the concerned Hindu female must have limited ownership in property, which limited ownership would get enlarged by the operation of that sub-section. If it was intended to enlarge any sort of a right which could in no sense be described as ownership, the expression “and not as a limited owner” would not have been used at all and becomes redundant, which is against the well-recognised principle of interpretation of statutes that the Legislature does not employ meaningless language. Reference may also be made in this connection to Eramma v. Verrupanna [AIR 1966 SC 1879 : (1966) 2 SCR 626, 630, 631] wherein Ramaswami, J., speaking on behalf of himself, Gajendragadkar, C.J., and Hidayatullah, J., interpreted the sub-section thus:
Madras High Court Cites 43 - Cited by 0 - Full Document

Sheubai Nana Lanke And Another vs Kondiba Hanmant Lamkhade (Deleted) And ... on 4 June, 2019

That decree is challenged in Second Appeal No. 165 of 2018. There is no application of Section 14 of Hindu Succession Act in this case as Sheubai has not come with a case that the suit property was given to her towards maintenance in any form or any limited right is given to her. Since the property was self acquired property of Kondiba, she could not have claimed it as of right. Therefore, the ratio laid down in Eramma Vs. Verrupanna & others (supra) and Smt. G. Rama Vs. T.G. Seshagiri Rao (Dead) by L.Rs. (supra), relied by the respondent - Balasaheb are applicable here.

Sheubai Nana Lanke And Another vs Kondiba Hanumanta Lamkhande (Deleted) ... on 4 June, 2019

That decree is challenged in Second Appeal No. 165 of 2018. There is no application of Section 14 of Hindu Succession Act in this case as Sheubai has not come with a case that the suit property was given to her towards maintenance in any form or any limited right is given to her. Since the property was self acquired property of Kondiba, she could not have claimed it as of right. Therefore, the ratio laid down in Eramma Vs. Verrupanna & others (supra) and Smt. G. Rama Vs. T.G. Seshagiri Rao (Dead) by L.Rs. (supra), relied by the respondent - Balasaheb are applicable here.

Rajammal vs Lakshmi And Anr. on 10 September, 1979

It is clear from the above observation that the widow must have acquired some kind of title, however, restricted it may be and whatever its nature may be. In the absence of acquisition of any such interests in the property, the mere residence by a pre-1937 widow in the family residential house as a member of the family cannot enable her to claim that she had acquired a right with reference to the residential house which would enable her to claim the benefit of an enlargement of that interest by the operation of Section 14(1) of the Act. The learned Counsel for the respondents further invited my attention to the decision of the Supreme Court in Mangal Singh and Ors. v. Shrimati Ratno and Anr. , Bhargava, J., observed after referring to Eramma v. Veerrupana and Ors. , that the case clarified the expression "possessed by" as not intended to apply to a case of mere possession without title and that the legislature intended this provision for cases where the Hindu female possesses the right of ownership of the property in question. It was also further pointed out that even mere physical possession of the property without the right of ownership will not attract the provisions of this section.
Madras High Court Cites 7 - Cited by 0 - Full Document

K Doddarangareddy S/O Venkanna vs K Ushamma @ Hushamma ... on 29 September, 2020

In Eramma v. Verrupanna, (1966) 2 SCR 626 on the death of the last male holder, his two step mothers who had no vestige of title to the properties got possession of the properties and in answer to a suit by the rightful heirs, one of them claimed that she had become full owner of the property under sec. 14 of the Hindu Succession Act. The Supreme Court pointed out that the object of sec. 14 was to extinguish the estate called limited estate and to make a Hindu woman who would otherwise be a limited owner, a full owner of the property but it was not to confer a title on a female Hindu, who did not in fact possess any vestige of title. The case did not deal with the case of Hindu a woman who was given 19 property in lieu of maintenance and in whom therefore a right or interest was created in the property.
Karnataka High Court Cites 17 - Cited by 1 - P N Desai - Full Document

P.Saravanan vs / on 4 March, 2021

“14. As per proviso to unamended Section-6 and Sub Section 3 of the amended Section-6 makes it clear that it is only the interest of the deceased Mitakshara coparcener in the property that would devolve either by testamentary or intestate succession under the Act. The position of law declared by the Hon'ble Supreme Court in various pronouncements regarding the proviso remains unaltered by the amendment of Section 6 by Act 39 of 2005. Sub Section-3 of Section-6 is only a reproduction of proviso to old Section-6. The difference between devolution under Section-6 and the devolution under Section 8 was observed by the Supreme Court in Eramma v. Verrupanna reported in AIR 1966 SC 1879 wherein the Hon'ble Supreme Court 21/35 http://www.judis.nic.in A.S.No.250 of 2017 pointed out and observed as follows:
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