In Brief
A widow (Jaichha Kuwar) who held a limited estate in property before the Hindu Succession Act 1956 came into force challenged whether she acquired absolute ownership under Section 14(1). The Supreme Court held that she did acquire full ownership. The widow's right to maintenance is a pre-existing right against joint family property. When property is allotted in lieu of maintenance, it merely recognises this right rather than creating new title. Section 14(1) abolished limited ownership for any Hindu female in possession of property, requiring absolute ownership. The widow was in possession on the Act's commencement date with nothing showing dispossession, thus acquiring full ownership rights.
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