Section 14(1) Hindu Succession Act applies only to possession linked to a pre-existing right, not bare possession without title.

Section 14(1) of the Hindu Succession Act enlarges only an existing limited estate or a pre-existing right into absolute ownership; mere possession without a legally cognisable title does not qualify. The Explanation covers property acquired through recognised modes such as inheritance, devise, partition, maintenance, or gift, while Section 14(2) preserves restricted estates created for the first time by instrument, decree, or award. On the facts, the appellant's possession was not referable to any such title or pre-existing right, the earlier declaratory proceedings could not confer absolute ownership, and the later will was not duly proved. The respondents' title therefore prevailed.

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Issues: Whether a female Hindu who was in possession of property, but without any vestige of title or right under the recognised modes of acquisition, became full owner under Section 14(1) of the Hindu Succession Act, 1956, and whether the earlier declaratory decree or the subsequent wills could defeat the respondents' claim.

Analysis: Section 14(1) enlarges only an existing limited estate or a pre-existing right into absolute ownership. The expression "possessed by" does not include a mere trespasser or a person in possession without title. The Explanation to Section 14(1) covers property acquired by inheritance, devise, partition, maintenance, gift, or similar legally recognised sources. Section 14(2) preserves restricted estates created for the first time by instrument, decree, or award. On the facts, the appellant's possession of the suit property was not found to be under any legally cognisable title or pre-existing right falling within Section 14(1), and the prior declaratory proceedings could not confer absolute ownership. The Court also found no perversity in the concurrent finding that the later will relied upon by the appellant was not duly proved.

Conclusion: The appellant did not acquire absolute ownership under Section 14(1), and the respondents' title based on the restored succession position and proved will prevailed.

Ratio Decidendi: Mere possession of property by a female Hindu does not attract Section 14(1) unless such possession is referable to a pre-existing right or other recognised title; where no such title exists, the estate is not enlarged into absolute ownership.

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