Hindu Undivided Family status may continue after marriage where family property and membership remain recognised.

A Hindu undivided family may exist even with a single male member and female members, and the absence of a second male coparcener does not defeat HUF status. On marriage, a wife can become a member of the family, and the governing Hindu law principles show that family property and family status may continue after marriage rather than being treated as wholly separate individual property. Applying these principles, income derived from the property was assessable as belonging to the HUF unit, not as the income of an individual.

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Issues: Whether, after the assessee's marriage, his status for income-tax purposes was that of a Hindu undivided family or an individual.

Analysis: A Hindu joint family is wider than a coparcenary and may consist of a single male member with female members. The absence of a second male coparcener does not, by itself, prevent recognition of a Hindu undivided family. The legal position under Hindu law and the relevant provisions governing maintenance and devolution of property show that a wife can become a member of the family on marriage and that the coparcener does not have unfettered power of disposal as though the property were wholly separate. Applying these principles, the income derived from the property could be treated as belonging to the family unit after marriage.

Conclusion: The assessee was rightly assessable in the status of a Hindu undivided family and not as an individual.

Ratio Decidendi: A Hindu undivided family may exist with a single male member and female family members, and where the facts show the continuance of family property and family status after marriage, the income is assessable in the status of a Hindu undivided family.

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