Absolute vesting in Hindu widow's inherited property survives later adoption and does not become joint family property by mere hotchpotch claim.

Property inherited by a Hindu widow vests in her absolutely under section 14(1) of the Hindu Succession Act, 1956, and a later adoption does not divest that vested ownership. On that basis, the widow remains assessable in her individual capacity in respect of the inherited property. The text also states that a female member cannot unilaterally blend her separate property with joint family property, as the power of blending is confined to coparceners; a mere claim of hotchpotch is insufficient unless the property is actually shown to have been thrown into the common stock. Consequently, the inherited property retains its individual character and does not become Hindu undivided family property by reason of subsequent adoption.

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Issues: (i) Whether the assessment of the widow as an individual in respect of property inherited from her husband remained valid after the adoption of a minor child; (ii) Whether the adoption of the son altered the character of the inherited property from individual property to joint family property.

Issue (i): Whether the assessment of the widow as an individual in respect of property inherited from her husband remained valid after the adoption of a minor child.

Analysis: The widow inherited the properties on her husband's death and, by virtue of section 14(1) of the Hindu Succession Act, 1956, became full owner of the property. Adoption made after the coming into force of the Hindu Adoptions and Maintenance Act, 1956, did not operate to relate back so as to divest property already vested in the widow. The adopted son therefore could not unsettle the individual ownership already acquired by her.

Conclusion: The assessment as an individual was valid, against the assessee.

Issue (ii): Whether the adoption of the son altered the character of the inherited property from individual property to joint family property.

Analysis: A female member cannot blend her separate property with joint family property merely by unilateral act, and the right of blending is confined to coparceners. The alleged throwing of property into the hotchpotch was not proved, and in any event the relevant valuation date preceded the filing of the return relied upon for that plea. The property therefore did not become Hindu undivided family property.

Conclusion: The property retained its individual character, against the assessee.

Final Conclusion: The legal position confirmed that the widow remained assessable in her individual capacity and the inherited properties did not become joint family assets by reason of the subsequent adoption.

Ratio Decidendi: Property inherited by a Hindu female and vested in her absolutely under section 14(1) of the Hindu Succession Act, 1956 is not divested by a subsequent adoption, and a female member cannot unilaterally blend her separate property into joint family property by a mere claim of hotchpotch.

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