22. The principles relating to the widow's power to alienate property were dealt with by the Supreme Court in JAISRI v. RAJDEWAN , which are as follows:
"Besides legal necessity, a widow or other limited heir may alienate the estate 'for the benefit of the estate'. An alienation of property to meet the costs of litigation necessary for preserving the estate is alienation 'for the benefit of the estate'. So too is alienation for making necessary repairs to properties belonging to the estate; so also is an exchange of land for effective management of the estate. However, alienation for developing or improving the properties is not one 'for the benefit of the estate', though it may bring additional income, and it does not bind the reversioners (HURRY v. GONESH (1884) 10 Cal 823)".