Nomination in provident fund dues does not create ownership; heirs retain succession rights over the amount.

Nomination for provident fund and allied dues authorises the nominee to receive payment and give a valid discharge, but it does not confer beneficial ownership or an independent title in the nominee. The amount remains part of the deceased's estate and must be distributed under the applicable succession law. Applying that principle, the fund was required to be shared among the heirs of the deceased under the Hindu Succession Act, 1956. The widow was therefore entitled to her share, and release of her half share was directed.

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Issues: Whether nomination of a family member in respect of provident fund and allied dues confers beneficial ownership on the nominee, or whether the amount remains liable to be distributed among the heirs under the law of succession.

Analysis: The governing principle applied was that a nomination only identifies the person authorised to receive payment and secure a valid discharge to the payer. It does not divest the estate of the deceased of beneficial ownership, nor does it create an independent title in the nominee. The amount received by the nominee remains part of the estate to be dealt with according to the succession law applicable to the deceased. On the facts, the deceased left behind his widow and mother as the relevant heirs, and the provident fund amount had therefore to be shared in accordance with the Hindu Succession Act, 1956.

Conclusion: The nomination did not confer any beneficial interest on the nominee. The widow was entitled to her share in the provident fund and the direction was issued for release of her half share.

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