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Issues: Whether children born from a void marriage are confined under Section 16(3) of the Hindu Marriage Act, 1955 to the self-acquired property of their parents or are entitled to claim rights in the property of their parents generally, and whether the earlier narrow interpretation of the provision required reconsideration.
Analysis: The provision uses the word "property" without limiting it to self-acquired property, while the legislative object of Section 16 is to remove the stigma of illegitimacy and confer legitimacy on such children. The provision must be read as a beneficial enactment in the light of constitutional values, including equality, dignity, the protection of children, and the constitutional guarantee against deprivation of property except by authority of law. The earlier view that children of void marriages could inherit only self-acquired property of the parents was held to be too restrictive, and the Court considered that such children, once declared legitimate, should not be denied rights in property that becomes the property of their parents, though their rights remain confined to parental property.
Conclusion: The earlier interpretation of Section 16(3) was not accepted, and the matter was directed to be reconsidered by a larger Bench.
Final Conclusion: The judgment does not finally decide the substantive property-rights question on merits and instead sends the issue for reconsideration by a larger Bench.
Ratio Decidendi: A beneficial provision declaring legitimacy must receive a purposive interpretation consistent with constitutional values, and the statutory limitation in Section 16(3) confines the child only to the property of the parents, not merely to their self-acquired property.