Source-based succession under Hindu law preserves parental-line devolution despite enlargement into absolute ownership

For succession to a female Hindu's property, the decisive factor under Section 15(2)(a) is the source of inheritance. Where the property came from her father or mother, it devolves, in the absence of issue, on the heirs of the father rather than under Section 15(1). Enlargement of a limited estate into full ownership under Section 14(1) does not alter the original source of the property or displace the source-based succession rule. The property therefore remained subject to Section 15(2)(a), preserving the parental line of devolution.

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Issues: Whether property inherited by a female Hindu from her mother, which later enlarged into full ownership under Section 14(1), devolves on her heirs under Section 15(1) or on the heirs of her father under Section 15(2)(a) of the Hindu Succession Act, 1956.

Analysis: The governing consideration is the source from which the female Hindu inherited the property. Where the property originally came from her father or mother, Section 15(2)(a) applies and the property devolves, in the absence of issue, on the heirs of the father. Enlargement of a limited estate into full ownership under Section 14(1) does not change the source of the property or alter the special rule of succession enacted in Section 15(2). The source-based rule preserves the legislative intent that property from the parental line returns to that line.

Conclusion: The property was governed by Section 15(2)(a), not Section 15(1), and it devolved on the heirs of the father. The conclusion is in favour of the appellant.

Final Conclusion: The appeal succeeded because the earlier view applying the special succession rule to the inherited property was affirmed, and the respondent had no right in the estate.

Ratio Decidendi: For succession to the property of a female Hindu, the decisive factor under Section 15(2) is the source of inheritance, and conversion of a limited estate into absolute ownership under Section 14(1) does not displace that source-based rule.

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