Family settlement and religious renunciation claims: forfeiture was unenforceable, and the compromise was upheld as binding.

Legislation reflected in Section 9 of Regulation VII of 1832 and Act XXI of 1850 was treated as barring deprivation of property rights on the ground of religion or renunciation, so a claim to a father's share based on apostasy-related forfeiture was not enforceable in court or through heirs. The 1860 compromise was upheld as a family arrangement because it settled existing competing claims on the footing of antecedent rights, with mutual relinquishment by the parties; it was therefore distinguishable from an alienation by a limited owner and binding on reversioners. The appellate decrees were set aside and the original dismissal restored.

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Issues: (i) Whether the legislation on religious renunciation prevented enforcement of any forfeiture-based claim to the father's share in the joint family property. (ii) Whether the compromise of 1860 was a binding family arrangement or an alienation not binding on the reversioners.

Issue (i): Whether the legislation on religious renunciation prevented enforcement of any forfeiture-based claim to the father's share in the joint family property.

Analysis: Section 9 of Regulation VII of 1832 and Act XXI of 1850 were treated as expressing the legislative policy that a party should not be deprived of property rights by reason of religion or renunciation of religion. On that footing, the conversion of Ratan Singh did not give Daulat Singh an enforceable right to his father's share which could be asserted in a British court or transmitted for enforcement by his heirs.

Conclusion: The claim based on forfeiture from apostasy was not enforceable.

Issue (ii): Whether the compromise of 1860 was a binding family arrangement or an alienation not binding on the reversioners.

Analysis: The arrangement was made to settle existing family disputes between persons asserting competing claims, each side relinquishing part of its claim and recognising the others' asserted rights to the shares allotted. Such a transaction was treated as a family settlement founded on antecedent claims, not as a transfer deriving title from a limited owner. A compromise of this kind was therefore distinguishable from an alienation by a life tenant and could be upheld against reversioners.

Conclusion: The compromise was a binding family arrangement and was not void as an unauthorised alienation.

Final Conclusion: The decrees of the appellate court were set aside and the original dismissal of the suits was restored, with costs awarded against the respondents.

Ratio Decidendi: Where a compromise settles competing family claims on the footing of antecedent title, it is a family arrangement and not an alienation by a limited owner; and where legislation has withdrawn enforceability of forfeiture for religious renunciation, no enforceable inheritance claim can be founded on that forfeiture.

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