Disposition of watan lands under the Estate Duty Act excludes reverter-based estate inclusion where life enjoyment is validly created.

Agreements dated 18 April 1931 and 22 December 1934 are explained as constituting a disposition of watan lands under section 24 of the Estate Duty Act, 1953, because they conferred a life right to possess and enjoy the lands on the widow. The 1931 agreement was treated as a valid transfer or surrender of the enjoyment right during her lifetime and not as a mere family arrangement. Even if that agreement were disregarded, the 1934 agreement independently confirmed and created the same life enjoyment. On that basis, the property fell within section 24(1) and was not treated as passing merely by reason of reverter on the widow's death.

---

---

Issues: Whether the agreements dated 18 April 1931 and 22 December 1934 amounted to a disposition of the watan lands within the meaning of section 24 of the Estate Duty Act, 1953, and whether the value of those lands was includible in the deceased's estate under section 24(1).

Analysis: The right to possess and enjoy the watan lands for life was found to have been conferred by the 1931 agreement, which was valid in law and operated as a transfer or giving up of the right to enjoy the lands during the widow's lifetime. The arrangement was not treated as a mere family adjustment, because the widow did not give up any pre-existing right under that document. The court further held that even if the 1931 agreement were not treated as the operative disposition, the 1934 agreement independently confirmed and created the same life enjoyment in favour of the widow. Once such a disposition existed, the case fell within section 24(1), and the property was not deemed to pass merely because of reverter on the widow's death.

Conclusion: The agreements constituted a disposition of the watan lands within section 24 of the Estate Duty Act, 1953, and the value of those lands was not includible in the deceased's estate under section 24(1).

---