Facts:
The appellants, legal heirs of Rai Bahadur Randhir Singh (the donor), filed a suit in 1998 to reclaim possession of 38 Bighas 8 Biswas of land gifted in 1953 to the respondents’ forefathers, claiming the gift was conditional upon the recipients rendering services to the donor and his heirs. The respondents denied any breach, asserting that the gift was absolute and they had continued providing services to the donor’s heirs until they left the village.
Contentions of the Appellant:
The appellants contended that the oral gift recorded in 1953 was conditional upon the donees rendering lifelong services to the donor and his heirs. They argued that the discontinuation of such services violated the terms of the gift, requiring the land to revert to the donor’s heirs.
Contentions of the Respondent:
The respondents argued that the gift was unconditional and absolute, with no terms requiring lifelong services. They highlighted their uninterrupted possession of the land for over four decades, asserting they had complied with any implicit conditions until the donor’s heirs ceased residing in the village.
Issues:
- Whether the gift made in 1953 was conditional upon the perpetual rendering of services.
- Whether the condition of continuous service constituted forced labor, violating constitutional rights.
- Whether the appellants’ suit was barred due to the delay of 45 years.
Observations/Findings by the Supreme Court:
The Court noted that the condition of perpetual service as claimed by the appellants would amount to forced labor, violating Articles 14, 21, and 23 of the Constitution of India. It held that the gift should be construed as absolute, with “services” referring only to past contributions or, at most, services to the donor during his lifetime. The appellants failed to provide evidence of specific breaches by the respondents, while the respondents demonstrated uninterrupted possession since 1953. The Court also emphasized the inordinate delay of 45 years in filing the suit, undermining the appellants’ claim.
Principle of the Case:
Conditions in a gift deed that violate fundamental rights, such as requiring perpetual service, are invalid. Courts must interpret such transactions contextually, ensuring they align with constitutional principles and equity.
Final Order:
The Supreme Court dismissed the appeal, upholding the High Court’s judgment that the appellants had no case. All interim orders were vacated, and pending applications were disposed of.
Impact on Public Law and Order:
This judgment reaffirms that conditions in legal transactions cannot override constitutional safeguards. It upholds the principle that gifts, even if conditional, must respect equity and justice, discouraging claims rooted in outdated practices that contravene modern legal and constitutional frameworks.
Case Citation:
Supreme Court of India, Smt. Naresh Kumari & Ors. v. Smt. Chameli & Ors., Civil Appeal No. 8244 of 2009, Decided on December 11, 2024, Justices Sudhanshu Dhulia and Prasanna B. Varale presiding.
