Provident fund nomination gives a right to receive, not beneficial title, and succession law continues to govern heirs' entitlement.

A nomination under the Employees' Provident Funds law authorises the nominee to receive provident fund , but it does not confer beneficial ownership or override succession law. The Court held that the term "vests" in Section 10(2) has limited effect, so the nominee holds the amount for transmission to the person legally entitled under succession. A contrary nomination cannot defeat the rights of the deceased member's heirs, and the provident fund amount remains part of the estate for succession purposes.

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Issues: Whether a nominee under the Employees' Provident Funds and Miscellaneous Provisions Act, 1952 and the Employees' Provident Fund Scheme, 1952 acquires beneficial title to the provident fund amount, or merely a limited right to receive it, so that succession law continues to govern the entitlement of the deceased member's heirs.

Analysis: The Court held that the Scheme permits nomination and, in certain situations, distribution among nominees, but those provisions do not displace the law of succession. Relying on the settled principle that the expression "vests" in Section 10(2) of the Act is of limited import, the Court concluded that the nominee is only the person authorised to receive the amount and that such receipt is for transmission to the person legally entitled under succession law. The Court followed the view that nomination under provident fund law does not confer absolute or beneficial ownership on the nominee, and that a contrary nomination cannot defeat the rights of the heirs who succeed to the estate.

Conclusion: The plaintiff, though a nominee, had no enforceable right to claim the provident fund amount to the exclusion of the deceased member's legal heir. The amount formed part of the deceased's estate and the respondent, being the heir entitled in succession, was entitled to it.

Ratio Decidendi: A nomination under provident fund law authorises receipt of the amount but does not create beneficial title in the nominee or override the law of succession.

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