Purposive reading of senior-citizen maintenance law supports setting aside a gift deed when promised care is not provided.

Section 23 of the Maintenance and Welfare of the Parents and Senior Citizens Act, 2007 must be construed purposively and liberally to advance senior-citizen welfare. Where a transfer, read with its surrounding documents, is made on the footing that the transferee will maintain the transferor and that obligation is not honoured, the statutory conditions for voiding the transfer are satisfied. The Tribunal's relief under Section 23 was therefore protected, and the gift deed was liable to be set aside in favour of the senior citizen transferor.

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Issues: Whether the High Court was correct in setting aside the order granting relief under Section 23 of the Maintenance and Welfare of the Parents and Senior Citizens Act, 2007 and in holding that the gift deed could not be invalidated.

Analysis: Section 23 of the Act is a beneficial provision intended to secure the welfare of senior citizens. Its interpretation must therefore be purposive and liberal so as to advance the legislative object and not defeat it by an unduly strict construction. Where the transfer documents, read together, show that the transfer was made on the footing that the transferee would maintain and provide for the transferor, and that obligation is not honoured, the statutory conditions for invoking Section 23 are satisfied. The Tribunal's power under the Act is not confined so narrowly as to nullify effective relief necessary to protect the senior citizen.

Conclusion: The High Court was not correct in interfering with the relief granted under Section 23. The gift deed was liable to be set aside and the relief stood in favour of the senior citizen transferor.

Ratio Decidendi: Section 23 of the Maintenance and Welfare of the Parents and Senior Citizens Act, 2007 must receive a purposive, welfare-oriented construction, and a transfer made subject to the transferee's obligation to maintain the senior citizen can be declared void when that obligation is not fulfilled.

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