Widow's limited estate under Hindu property law does not confer karta status or validate a family partnership deed.

A widow who inherited her husband's share under the Hindu Women's Rights to Property Act, 1937 acquired only a limited estate and a right to claim partition; she did not become a coparcener in the joint Hindu family. Because managership under Hindu law depends on coparcenary status, she could not act as karta or represent the family on behalf of the minors. On that reasoning, a partnership deed executed by her in a representative capacity could not be treated as validly registrable under section 26-A of the Income-tax Act, 1922.

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Issues: Whether a widow who had succeeded to her husband's interest under the Hindu Women's Rights to Property Act, 1937 could, by reason of that devolution, act as karta or managing member of the joint Hindu family so as to validly execute a partnership deed on behalf of the minors and obtain registration of the firm under section 26-A of the Income-tax Act, 1922.

Analysis: The widow's interest under the Hindu Women's Rights to Property Act was held to be only a Hindu woman's estate in the deceased husband's share. The Act conferred a limited right in property and a right to claim partition, but it did not make the widow a coparcener in the joint family. Managership under Hindu law depends on coparcenary status, and the power to represent the family as karta does not extend to a female member who is not a coparcener. The reasoning of the Nagpur High Court, which treated the widow as having such representative capacity, was not accepted.

Conclusion: The widow had no legal capacity to act as karta of the joint Hindu family, and the partnership deed executed on that basis was not validly registrable.

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