Minor's acceptance of a gift can be valid through guardians, making the gift complete and non-revocable by the donor.

A non-onerous gift of immovable property can be validly accepted on behalf of a minor, and acceptance may be express or implied through conduct or by natural guardians acting for the minor. Reading Sections 122, 123, 126 and 127 of the Transfer of Property Act together, the gift becomes complete once accepted and cannot be revoked merely at the donor's will, except in the limited cases recognised by law. Reserving possession, management and enjoyment to the donor during lifetime does not by itself defeat the transfer. On the stated facts, knowledge of the gift, retention of the deed, non-repudiation on majority, and no indication of non-acceptance supported validity of the gift deed.

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Issues: Whether a minor donee can validly accept a gift of immovable property and whether a gift made in his favour, once accepted, can be revoked by the donor.

Analysis: Under the Transfer of Property Act, 1882, a gift is complete only when it is accepted by or on behalf of the donee, and a valid gift cannot thereafter be revoked except in the limited cases contemplated by law. The Act does not prohibit a gift to a minor. Reading Sections 122, 123, 126 and 127 together, a minor is capable of accepting a non-onerous gift, and acceptance may be express or implied, including through conduct or by the natural guardians acting on the minor's behalf. The donor in this case had transferred ownership while reserving possession, management and enjoyment to herself during her lifetime, which did not defeat the transfer. The circumstances showed knowledge of the gift by the minor and his parents, continued retention of the deed, non-repudiation on attaining majority, and no indication in the cancellation deed that the gift had not been accepted. Those facts supported acceptance by the minor or on his behalf and negatived the view that no title passed.

Conclusion: The minor donee validly accepted the gift, the gift became complete in law, and the donor had no right to cancel it or to deal with the property by will.

Final Conclusion: The judgment restoring the first appellate court was affirmed in substance, and the challenge to the validity of the gift deed failed.

Ratio Decidendi: A non-onerous gift in favour of a minor may be accepted by the minor or on his behalf, and once such acceptance is established, the gift becomes complete and is not revocable at the mere will of the donor.

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