SC: Hindu widow's limited Bhumidhari right under Delhi Land Reforms Act vested absolutely on her 1973 death

The dispute concerned about 45 bighas of agricultural land in Bhawana village, Delhi, held by Khajano, who was declared a Bhumidhar -- a protected tenant with inheritable rights -- under the Delhi Land Reforms Act, 1954, after her first husband Mauji Ram's line ended. On her death in 1973, her sons from a second marriage, Chand Ram and Chander Bhan, sought mutation as her heirs, opposed by the reversioners (the deceased's male collaterals), who argued Khajano held only a limited life estate that should revert to them under the pre-1956 Shastric law. The Supreme Court held that Section 51(2)(a) of the 1954 Act, which governs succession to a Bhumidhari interest a woman inherited 'before the commencement of the Act', uses the present tense ('dies') to fix the trigger point for succession, so the operative date is the date of the Bhumidhar's actual death, not the date she first acquired the interest.

Since Khajano died in 1973, her personal law on that date was the Hindu Succession Act, 1956, under whose Section 14 a Hindu woman's limited estate automatically matures into absolute ownership. Her limited interest in Mauji Ram's holding had therefore already become absolute before her death, so it devolved on her own sons under Section 53 of the 1954 Act, and the reversioners' claim failed. The appeal from the Delhi High Court's judgment was dismissed.