HUF status ends on death of sole male coparcener; later adoption cannot revive joint family character or divest vested property.

Where a sole male coparcener dies leaving only female members, the Hindu undivided family character ends and the coparcenary interest devolves by succession on the surviving female members under section 6 of the Hindu Succession Act, 1956. A later adoption by the widow under sections 8, 11 and 12 of the Hindu Adoptions and Maintenance Act, 1956 operates only prospectively, cannot restore HUF status retrospectively, and cannot divest property already vested in the female members. The discussion also notes that a female member cannot blend separate property into a joint family hotchpotch to convert it into HUF property.

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Issues: Whether, on the death of the sole male member leaving only female members, the property retained the character of a Hindu undivided family property; whether a subsequent adoption by the widow related back so as to revive the Hindu undivided family status; and whether the adopted child could divest the property already vested in the female members.

Analysis: The ruling proceeded on the combined effect of section 6 of the Hindu Succession Act, 1956 and the provisions governing adoption. On the death of the male member, the coparcenary interest devolved by succession upon the surviving female members and the joint family status came to an end in the absence of any surviving male member. The subsequent adoption under sections 8, 11 and 12 of the Hindu Adoptions and Maintenance Act, 1956 took effect only from the date of adoption and could not operate retrospectively to create a Hindu undivided family for the interregnum or divest property that had already vested in the widowed female members. The view was reinforced by the principle that a female member cannot blend her separate property into the joint family hotchpotch so as to convert it into Hindu undivided family property.

Conclusion: The property had to be assessed in the hands of the assessee as an individual, and the claim to Hindu undivided family status failed.

Ratio Decidendi: Where a sole male coparcener dies leaving only female members, the family status ends by succession, and a later adoption by the widow cannot retrospectively restore Hindu undivided family character or divest property already vested in the female members.

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