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Harak Singh vs Kailash Singh And Anr. on 1 July, 1958

Harak Singh v. KailaSh Singh (1) overruled its previous decisions referred to above, and rightly pointed out that the object of the Act was to improve the legal status of Hindu women, enlarging their limited interest in property inherited or held by them to an absolute interest, provided they were in possession of the property when the Act came into force and, therefore, in a position to take advantage of its beneficial provisions; but the Act was not intended to benefit alienees who with their eyes open purchased the property from the limited owners without justifying necessity before the Act came into force and at a time when the vendors had only a limited interest of Hindu women. In the case before us, the essential question for con- sideration is as to how the words "any property possessed by a female Hindu, whether aquired before or after the commencement of this Act " in a. 14 of the Act should be interpreted. Section 14 refers to property which was either acquired before or after the commencement of the Act and that such property should be possessed by a female Hindu. Reference to property acquired before the commencement of the Act certainly makes the provisions of the section re- trospective, but even in such a case the property must be possessed by a female Hindu at the time the Act came into force in order to make the provisions of the section applicable. There is no question in the present case that Veeravva acquired the property of her deceased husband before the commencement of the Act. In order that the provisions of s. 14 may apply to the present case it will have to be further established that the property was possessed by her at the time the Act came into force. It was the case of the appellant that the estate of Veerappa was in actual possession of the second defendant and not Veeravva at the relevant time. On behalf of the respondent it was urged that the words " possessed by " had a wider meaning than actual physical possession, although physical possession may be included in the expression. (1) A.I.R. 1958 Pat. 581.
Patna High Court Cites 9 - Cited by 22 - V Ramaswami - Full Document

Mt. Janki Kuer And Ors. vs Chhathu Prasad And Ors. on 23 July, 1957

In the case of Rama Ayodhya Missir v. Raghunath Missir (1) and in the case of Mt. Janki Kuer v. Chhathu Prasad (2) the Patna High Court took the view that the effect of ss. 14 and 15 of the Act was that a reversioner recognised as such under the Hindu law was no more a reversioner, as a female Hindu possessing any property, whether acquired before or after the commencement of the Act, held not a limited estate but an absolute estate therein, and after the coming into force of the Act, he had no right of reversion or any kind Of Spes successionsis.
Patna High Court Cites 9 - Cited by 11 - Full Document

Ram Ayodhya Missir And Ors. vs Raghunath Missir And Ors. on 8 November, 1956

In the case of Rama Ayodhya Missir v. Raghunath Missir (1) and in the case of Mt. Janki Kuer v. Chhathu Prasad (2) the Patna High Court took the view that the effect of ss. 14 and 15 of the Act was that a reversioner recognised as such under the Hindu law was no more a reversioner, as a female Hindu possessing any property, whether acquired before or after the commencement of the Act, held not a limited estate but an absolute estate therein, and after the coming into force of the Act, he had no right of reversion or any kind Of Spes successionsis.
Patna High Court Cites 8 - Cited by 22 - V Ramaswami - Full Document

Mt. Lukai W/O Katikram And Ors. vs Niranjan Dayaram And Ors. on 31 January, 1958

The High Courts of Calcutta, Andhra Pradesh and Madhya Pradesh have taken a view which does not support the view expressed by the Patna High Court in the aforesaid cases, The High Court of 'Madhya Pradesh in the case of Mt. Lukai v. Niranjan (3) dissented from the decisions of the Patna High Court in the above-mentioned cases.' Indeed, the Patna High Court in the case of (1)A.I.R. 1957 Pat. 480. (2) A.I.R. 1957 Pat. 674.
Madhya Pradesh High Court Cites 5 - Cited by 5 - M Hidayatullah - Full Document
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