Customary succession and surrender doctrine limit daughters' exclusion and require complete self-effacement for accelerated succession.

Entries in a Riwaj-i-am are relevant evidence of custom and ordinarily carry an initial presumption of correctness, but the presumption is weak where female succession rights are affected and, unless clearly shown otherwise, such entries are treated as confined to ancestral property. On that basis, the customary record did not establish a special rule excluding daughters from succession to non-ancestral property among Grewal Jats. The doctrine of acceleration or surrender by a limited owner also requires complete self-effacement and surrender of the entire interest; a partial gift benefiting only some reversioners does not validly accelerate succession. A selective transfer therefore could not confer absolute title beyond the widow's lifetime.

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Issues: (i) Whether the entries in the Riwaj-i-am for Ludhiana district governed succession to non-ancestral property among Grewal Jats so as to exclude daughters in favour of collaterals; and (ii) whether a widow's gift of property to the daughters, who were the next reversioners only in respect of the non-ancestral portion, operated as a valid acceleration of succession beyond the widow's lifetime.

Issue (i): Whether the entries in the Riwaj-i-am for Ludhiana district governed succession to non-ancestral property among Grewal Jats so as to exclude daughters in favour of collaterals?

Analysis: The entries in a Riwaj-i-am are relevant evidence under Section 35 of the Indian Evidence Act, 1872, and ordinarily carry an initial presumption of correctness. But the presumption is weak where the recorded custom affects female rights, and it must yield where the entries are shown to relate only to ancestral property. The accepted principle was that, unless there is clear indication to the contrary, questions and answers in such customary compilations are ordinarily confined to ancestral property. On that basis, the entry relied upon did not establish a special custom excluding daughters from succession to non-ancestral property.

Conclusion: The Riwaj-i-am did not prove a custom among Grewal Jats excluding daughters from succession to non-ancestral property, and daughters remained preferential heirs over collaterals for that property.

Issue (ii): Whether a widow's gift of property to the daughters, who were the next reversioners only in respect of the non-ancestral portion, operated as a valid acceleration of succession beyond the widow's lifetime?

Analysis: The doctrine of acceleration or surrender by a limited owner rests on complete self-effacement and requires surrender of the entire interest in the entire property. A gift that benefits some reversioners, transfers part of the estate to strangers, and leaves part with the widow does not amount to the total effacement necessary to accelerate succession. The doctrine of surrender cannot be split into separate parts for different reversioners, and there was no customary law shown to support such partial surrender. The argument under Section 14 of the Hindu Succession Act, 1956 was not adjudicated on merits in the absence of the necessary factual foundation.

Conclusion: The gift was not valid beyond the widow's lifetime and did not confer an absolute title on the daughters.

Final Conclusion: The appeal failed because the challenged gift could not defeat the respondents' rights in the non-ancestral property, and the decree in favour of the plaintiffs was maintained.

Ratio Decidendi: Entries in a customary-law record are ordinarily construed as relating to ancestral property unless clearly shown otherwise, and a limited owner can accelerate succession only by a complete surrender amounting to total self-effacement, not by a partial gift or selective effacement.

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