
The Supreme Court reversed the High Court's decision and restored the trial court and first appellate court findings. It determined that the deed executed in 1963 in favor of Govindammal was a valid settlement deed, not a gift deed, and upheld her heirs’ entitlement to 2/3rd share of the disputed property. The court emphasized that consideration need not always be monetary and that the High Court erred in re-evaluating concurrent findings of fact without sufficient justification.
Parties Involved:
Key Issue:
Rulings:
Ratio Decidendi:
Outcome: The appellants’ claim was upheld, restoring their 2/3rd share in the property.
The dispute over property began with a suit for partition filed in 1995. Successive judgments in the trial and appellate courts favored Govindammal’s heirs, validating the settlement deed executed in her favor in 1963. The High Court, however, classified the deed as a gift and revised the property shares, prompting the present appeal.
The property, originally Hindu joint family property, was divided between three brothers. One brother, Chenga Reddy, transferred his 1/3rd share to Govindammal through a 1963 settlement deed, making her owner of 2/3rd of the property. Disputes arose over the classification of this deed and the ownership claims.
The deed specified that Govindammal was entitled to the property in return for caring for the transferors and conducting charitable activities. The court emphasized that such familial obligations qualify as valid consideration for settlement deeds.
The High Court’s classification of the deed as a gift was based on a narrow interpretation of "consideration." The Supreme Court found this erroneous, holding that the broader legal definition of consideration includes familial care.
The judgment reiterates that High Courts should respect concurrent findings of lower courts unless clear legal errors or substantial questions of law are involved.
Transfer of Property Act, 1882:
Indian Stamp Act, 1899:
Indian Contract Act, 1872:
Code of Civil Procedure, 1908:
Property Law, Familial Disputes, Settlement Deeds.
Hindu Joint Family Property, Gift vs. Settlement, Consideration, Second Appeals, Supreme Court Rulings.
Case Title: RAMACHANDRA REDDY (DEAD) THR. LRS. & ORS. VERSUS RAMULU AMMAL (DEAD) THR. LRS.
Citation: 2024 LawText (SC) (11) 140
Case Number: CIVIL APPEAL NO. 3034 OF 2012
Date of Decision: 2024-11-14