The appellants in the present case are the defendants (represented through their legal representatives), while the respondents are the plaintiffs. The dispute arises from a partition deed executed in 1933, which granted certain property rights to one Smt. Veerabhadramma, the second wife of Kallakuri Swamy. The deed stipulated that after her death, the property would be divided equally between the two branches of her husband’s heirs: the sons from his first marriage (the plaintiffs) and his second marriage (the defendants).

Upon Smt. Veerabhadramma’s death in 1973, a dispute erupted regarding the division of the land, and the plaintiffs sought a partition of the land to claim their half share. The appellants, however, contended that Smt. Veerabhadramma had executed a will in 1968 bequeathing the property to one of the defendants, which the plaintiffs denied, arguing that she had only the right to enjoy the property for life as per the partition deed.

The plaintiffs filed a suit for partition, claiming their rightful share of the property. In the written statement, the defendants argued that Smt. Veerabhadramma’s rights were not limited by the partition deed and that under the Hindu Succession Act, her rights to the property had evolved into absolute ownership, especially after the enactment of Section 14(1) of the HSA, 1956, which grants absolute ownership to female Hindus who hold property in lieu of maintenance.

The trial court, however, sided with the plaintiffs. It concluded that Smt. Veerabhadramma’s rights were restricted by the partition deed and did not extend to absolute ownership. The court relied on the interpretation of Section 14(1) and Section 14(2) of the HSA, 1956, as clarified in previous landmark judgments, particularly V. Tulsamma v. V. Sesha Reddy and Gulwant Kaur v. Mohinder Singh. The court held that since the property was given to Smt. Veerabhadramma for her lifetime and not as an absolute right, the succession to the property after her death would follow the partition deed, with the land being divided equally between the two branches of the family.

The matter was appealed to the High Court, which upheld the trial court's decision. The High Court delved into the interpretation of Section 14 of the Hindu Succession Act, particularly the distinction between property given in lieu of maintenance and property granted for other reasons. The court highlighted the important distinction between the rights conferred under Section 14(1) and Section 14(2) of the HSA, 1956.

Section 14(1) grants a female Hindu absolute ownership of property if it is acquired in lieu of maintenance or arrears of maintenance. This provision was held to be applicable when property was given to a woman for her maintenance, transforming her life interest into full ownership.

Section 14(2), on the other hand, applies to cases where property is acquired under a will or other instrument, which explicitly creates a restricted estate.

In the present case, the High Court found that the property in dispute was given to Smt. Veerabhadramma for her maintenance, thus applying Section 14(1) to determine that she did not acquire absolute ownership over the entire property. The land given to her for maintenance was held to be subject to the partition deed, and the remaining property, where she had absolute rights, was separate.

The Court relied heavily on previous judgments, such as V. Tulsamma and Gulwant Kaur, which established the principle that property given to a female Hindu in lieu of maintenance evolves into absolute ownership, subject to certain conditions. The court also referred to Raghubar Singh v. Gulab Singh and Mangat Mal v. Punni Devi, where the importance of providing adequate maintenance for the woman was emphasized. It was concluded that if the maintenance provision was sufficient to allow the woman to live a lifestyle similar to what she had previously enjoyed, the property given in lieu of maintenance would become her absolute property.

When the matter reached the Supreme Court, the primary issue was whether Smt. Veerabhadramma, by virtue of Section 14(1) of the Hindu Succession Act, could be considered the absolute owner of the disputed property. The Court upheld the findings of the lower courts and ruled that Smt. Veerabhadramma’s rights were not absolute in the context of the 3.55 cents of land, which was given to her for life interest. It emphasized that the statutory recognition of her maintenance rights had been satisfied, and therefore, the property would be divided according to the 1933 partition deed.

The appeal was thus dismissed, with the Court affirming the decision of the High Court and upholding the concurrent findings that Smt. Veerabhadramma’s rights were limited to a life interest in the disputed property.

This case serves as an important reminder of the application of Section 14 of the Hindu Succession Act, 1956, and the legal principles governing property rights of Hindu women. It underscores the distinction between property given in lieu of maintenance and other types of property transactions, as well as the evolving nature of women’s rights in Hindu law. The judgment reinforces that the Hindu Succession Act does not automatically grant absolute ownership to female heirs unless certain preconditions are met, including the provision of adequate maintenance. The decision also affirms the longstanding principle that women’s rights in property, especially in cases of inheritance and partition, must be determined by the specific terms of the deeds, wills, and statutes in question.