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Supreme Court of India 2022-09-05 allowed

PUSHPALATA vs VIJAY KUMAR (DEAD) THR. LRS. & ORS

Bench: 3 — Uday Umesh Lalit, S. Ravindra Bhat, Sudhanshu Dhulia

In Brief

A father purchased land in his minor sons' names with his own funds for the family's benefit. When one son sold the property, his sisters sued to recover it, claiming benami (nominal) ownership. The trial court and first appeal rejected the claim as barred by the Benami Transaction (Prohibition) Act, 1988. The Supreme Court allowed the appeal, holding that while benami transactions are prohibited, an exception applies when property is held by a coparcener in a Hindu Undivided Family for the family's benefit. The evidence—showing the father paid for the property, the sons were minors with no income, and the father retained possession—established this exception applied, making the sale invalid and entitling the family to recover the property.

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Property Law Benami Transactions Hindu Undivided Family Civil Procedure Evidence Fiduciary Relationships Real Owner v Ostensible Owner

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