Showing posts with label minor'property. Show all posts
Showing posts with label minor'property. Show all posts

Wednesday, 6 February 2019

Whether Mother Can Alienate Minor Son's Property When She's Not His Natural Guardian?

 In the light of these facts, it is crystal clear that when the
property inherited and owned by the plaintiff which is not a Hindu
Joint Family property or interest in the joint Hindu Family and when
father was not shown to be not taking care of the minor, mother is
not natural guardian. She as a de facto guardian has no right to
alienate the property of her minor son.
21. When the transaction is voidable, it is voidable at the
option of the minor. Minor's father or natural guardian cannot
exercise the option which a minor alone can exercise. Obviously, the
minor can exercise it after attaining the majority. Therefore, when
the sale is voidable, the ruling in Narayan Gilankar's (supra) would
be applicable but when the sale is void and there was threat of
dispossession or there was actual dispossession, it was not necessary
for minor to wait for attaining majority. His natural guardian could
have filed suit to protect his interest and his civil rights in the
property. Thus, the suit filed by the plaintiff during his minority
through his father a natural guardian as next friend is certainly
maintainable. The period of limitation in such matters will be 12
years and not 3 years as there is no necessity of claiming any
declaration. The question of legal necessity as held in Vishwambhar's
case (supra) is irrelevant. The sale is void and the transfer can be

repudiated on attaining majority. I therefore find that the learned
first appellate Court committed error in not properly appreciating the
above facts and did not follow the settled principles of law as laid
down in the above rulings. The sale could have been voidable only if
father was neglecting the child and was in care, custody and
maintenance of the mother. In this regard, reliance can be placed on
the judgment of the Apex Court in Githa Hariharan (Ms) Vs.
Reserve Bank of India reported in (1999) 2 SCC 228.
46. In our opinion, the word 'after” shall have to be
given a meaning which would subserve the need of the
situation, viz., the welfare of the minor and having due
regard to the factum that law courts endeavour to retain the
legislation rather than declare it to be void, we do feel it
expedient to record that the word “after” does not necessarily
mean after the death of the father, on the contrary, it depicts
an intent so as to ascribe the meaning thereto as “in the
absence of” be
it temporary or otherwise or total apathy of
the father towards the child or even inability of the father by
reason of ailment or otherwise and it is only in the event of
such a meaning being ascribed to the word “after” as used in
Section 6 then and in that event, the same would be in
accordance with the intent of the legislation, viz., the welfare
of the child.
47. In that view of the matter, the question of ascribing
the literal meaning to the word “after” in the context does not
and cannot arise having due regard to the object of the
statute, read with the constitutional guarantee of gender
equality and to give a full play to the legislative intent, since
any other interpretation would render the statute void and
which situation, in our view, ought to be avoided.

22. There are neither pleadings nor evidence to make out these
situations which could have made the mother as natural guardian.
Hence, the sale effected by mother is void and the suit filed for
challenging the same and for claiming perpetual injunction and later
on for possession was perfectly maintainable.

IN THE HIGH COURT OF JUDICATURE AT BOMBAY,
BENCH AT AURANGABAD.
SECOND APPEAL NO. 650 OF 2003

Rameshwar Babasaheb Paul, Vs  Shivaji  Eknathrao Paul,

CORAM : A. M. DHAVALE, J.

DATED : 21.01.2019.
Citation: AIR 2019 Bom 77

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Sunday, 11 November 2018

Whether quandom minor can get possession of property sold in absence of prayer for setting aside alienation?

 The second question pertains to whether it was necessary for the original plaintiffs to have prayed for setting aside of the sale-deed dated 30.03.1974 executed by their mother while seeking possession of the suit property. In the present case, the original plaintiffs have contended that they were minors when the aforesaid sale-deed was executed by their mother and that upon attaining majority, they were entitled to possession of the suit property as their mother could not have executed the aforesaid sale-deed. The Hon'ble Supreme Court in the case of Nagappan v. Ammasai Gounder and others (supra) held that when a minor claims that an alienation of property by a guardian was not sustainable, such alienation is voidable upon the minor attaining majority. In such a situation, the minor, upon attaining majority and in order to avoid such alienation must seek setting aside of such alienation and then seek possession of the suit property. It was held that in the absence of a prayer for setting aside alienation a suit seeking possession would not be maintainable. The aforesaid case was concerned with absence of permission under Section 8 of the aforesaid Act and it was held that in the absence of such permission when a sale-deed was executed, it was voidable at the instance of minor and that in such a situation a prayer for setting aside of the sale-deed was necessary.

15. In the case of Kisan Ramji Khandare v. Kaussalyabai Gangaram Korde and others (supra), this Court has placed reliance on the aforesaid judgment of the Hon'ble Supreme Court in the case of Nagappan v. Ammasai Gounder and others (supra) and the position of law has been followed to the effect that when the sale-deed was voidable at the instance of a minor, a prayer for setting aside the sale-deed was necessary.

16. The learned Counsel appearing on behalf of respondent Nos. 1 to 4 has relied upon the judgments of the Hon'ble Supreme Court in the case of G. Annamalai Pillai v. District Revenue Officer and others (supra) and State of Maharashtra v. Pravin Jethalal Kamdar (supra) to contend that there was no need to seek a declaration for setting aside of the sale-deed in the present case and that suit simpliciter for possession was maintainable. In the present case, since respondent Nos. 1 to 4 upon attaining majority, approached the Court to prove that the aforesaid sale-deed dated 30.03.1974 was not executed properly in the eyes of law by their mother without seeking permission of the Court, it was at best voidable at their instance. In such a situation, unless the respondent Nos. 1 to 4 prayed for setting aside of the aforesaid sale-deed, they could not have sought a decree for possession. Hence, the second substantial question of law framed by this Court is also answered in favour of the appellant and against respondent Nos. 1 to 4.

IN THE HIGH COURT OF BOMBAY (NAGPUR BENCH)

Second Appeal (SA) No. 582 of 2006

Decided On: 04.05.2018

 Vasantrao Gulabrao Thakre Vs. Sudhakar Wamanrao Hingankar 

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Saturday, 28 February 2015

Disposal of minor's property for legal necessity by natural guardian whether voidable?



Hindu Minority and Guardianship Act, 1956 - Sections 6 and 8-The necessity for a natural guardian to obtain permission or sanction from the Court before alienating the minor's property will not be attracted so far as the minor's undivided interest in the joint family property is concerned.
Section 8(3) of the Act lays down that any disposal of immovable property by a natural guardian, in contravention of sub-section (1) or sub-section (2) is voidable at the instance of the minor or any person claiming under him. When Section 8 does not take within its ambit the minors undivided interest in the joint family property, Section 8(3) would not be applicable.
The recitals of legal necessity in a deed do not by themselves prove legal necessity. The recitals are, however, admissible in evidence, their value varying according to the circumstances in which the transaction was entered into. The recitals may be used to corroborate other evidence of the existence of legal necessity. The weight to be attached to the recitals varies according to the circumstance.
What the alienee is required to establish is legal necessity for the transaction and it is not necessary for him to show that every bit of the consideration which he advanced was actually applied for meeting family necessity. The reason is that the alienee can rarely have the means of controlling and directing the actual application of the money paid or advanced by him unless he enters into the management himself.
The natural guardian of a minor has the necessary competence to deal with even the separate property of the minor. Nonetheless the natural guardian remains a guardian of the minor in other senses also. Natural guardian who has a share in the property along with the minors' undivided interest in the property is legally competent to alienate the property as a whole, either in the capacity of the minor's guardian or as a Manager.
Karnataka High Court
A. Chidananda (Deceased) By L.Rs. ... vs Smt. Lalitha V. Naik And Ors. on 19 January, 2006
Equivalent citations: AIR 2006 Kant 128, 2006 (2) KarLJ 67,2006(3)KCCR1403

Bench: H G Ramesh
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Whether mother can transfer properties of minor without obtaining permission of court?

KARNATAKA High Court in a case of Gangoji Rao And Anr. vs H.K. Channappa And Ors. Decided on 9/12/1982. Reported in 1983 (1) Kar. L.J. 177; observes as follows

The view that I have taken finds support in the ruling rendered by the High Court of Rajasthan in the case, Girdhar Singh v. Anand Singh. In a similar case, the High Court of Rajasthan, in para 12 of the judgment, has held thus : "As regards the question of taking permission from a competant Court of law in this case, I am in agreement with the view taken in Sunnamani Dei v. Babaji Das that when the minor and his mother constitute a Hindu Joint Family, each with a moiety of undivided interest in any movable property be longing to the family, in the absence of the father, the mother as natural guardian, can alienate even the minor's half share in the immovable property under the personal law. Section 8 of the Hindu Minority and Guardianship Act will not apply to such alienation. This view finds support from Smt. Suggabai v. Hira Lal ."



In Re. Krishnakant Maganlal, , Bhagwati J., delivering the judgment has observed. (at p. 73) "The restrictions contained in Section 8 do not apply in respect of the undivided interest of a minor in joint family property and Section 8 does not debar a Manager and Karta of a joint family from alienating joint family property without obtaining the previous permission of the Court even if the Manager and Karta happens to be the natural guardian in respect of the separate property of any one or more of the minor coparceners. Of course the alienation would have to be justified under Hindu Law, but Section 8 does not require that any previous permission of the Court should be obtained before effecting such alienation........"

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