Section 14(1) enlarged a female Hindu's limited estate into absolute ownership, validating her will and the legatees' title.

A female Hindu's limited estate was enlarged into absolute ownership by Section 14(1) of the Hindu Succession Act, 1956, and a compromise decree that only rendered an earlier gift ineffective did not curtail that enlargement. As absolute owner, she had full testamentary capacity, so the will executed by her was valid. The finding that the will was genuine and duly executed further supported the legatees' title, and the contrary view of the High Court was unsustainable.

---

---

Issues: Whether, on the true construction of the compromise decree and the effect of Section 14(1) of the Hindu Succession Act, 1956, the female holder acquired an absolute estate enabling her to validly execute the will.

Analysis: The compromise decree declared the earlier gift ineffective and left the female holder in enjoyment of the property as a limited owner until the Hindu Succession Act, 1956 came into force. On the operation of Section 14(1), her limited estate was enlarged into full ownership. The decree did not divest her of ownership, but only recognised that the gift would not operate beyond the limited period. As she was absolute owner when the will was executed, she had full testamentary capacity. The factual finding that the will was genuine and duly executed further supported the legatees' title.

Conclusion: The will was valid and the appellants, as legatees, were entitled to succeed. The High Court's contrary view was unsustainable.

Ratio Decidendi: Where a female Hindu's limited estate is enlarged into absolute ownership by Section 14(1) of the Hindu Succession Act, 1956, she acquires full power to dispose of the property by will, and a prior compromise decree recognising an earlier alienation as ineffective does not defeat that power.

---