MOOL CHAND vs KEDAR (DECEASED) BY L.RS. . — C.A. No. 648/2000

Case Summary: Mool Chand v. Kedar (Deceased) by L.Rs. Court Decision: The Supreme Court dismissed the appeal, holding that when a female Hindu inherits bhumidhari land from a male under customary Hindu law (outside the Bombay School), she acquires only a limited life estate, not absolute ownership. Upon her death, Section 172(2)(a)(i) of the U.P. Zamindari Abolition Act applies, causing the property to devolve to surviving co-tenure holders by survivorship under Section 175, not to her husband. Key Reasoning: Although female bhumidhars possess absolute rights to transfer property during their lifetimes, succession upon death is governed by the deceased's personal law rights. Since Smt. Kaushalya Devi inherited from her father before the 1956 Hindu Succession Act came into force, she held only a limited estate under personal law, requiring application of Section 171 succession rules where the husband is not an heir. This case analysis is maintained by casestatus.in based on publicly available court records.