Hindu undivided family status for Jat Sikhs upheld under binding precedent, defeating the customary-law objection.

Binding Full Bench authority had already settled that Jat Sikhs in Punjab can constitute a joint Hindu family, so the customary-law argument advanced by the Revenue could not prevail. On that basis, Jat Sikhs were not shown to be excluded from Hindu law for this purpose, and the deceased was treated as having constituted a Hindu undivided family for estate duty purposes, in favour of the accountable person.

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Issues: Whether Jat Sikhs in Punjab are governed by customary law or Hindu law, and whether the deceased could be treated as having constituted a Hindu undivided family for estate duty purposes.

Analysis: The answer was governed by the binding Full Bench decision which had already held that Jat Sikhs can constitute a joint Hindu family. In view of that authoritative pronouncement, the legal position stood settled against the Revenue's contention based on customary law.

Conclusion: The question was answered in the affirmative. Jat Sikhs in Punjab are not shown to be excluded from Hindu law for this purpose, and the deceased was held to have constituted a Hindu undivided family, against the Revenue and in favour of the accountable person.

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