Partition-created life estate qualified as a disposition under estate duty law and attracted the statutory exemption.

A partition arrangement that created a fresh life estate in favour of a widow over agricultural land was treated as a disposition within section 24 of the Estate Duty Act, 1953, because the term covers an agreement or arrangement and the property reverted to the disponers in proportion to their interests. The proviso to section 24 did not apply, as the widow had not been competent to dispose of the land before the partition. The life interest therefore fell within the statutory exemption, and the value of the 25 acres was exempt from estate duty.

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Issues: Whether the value of 25 acres of wet land, settled on the widow under the partition arrangement, was exempt from estate duty under section 24 of the Estate Duty Act, 1953.

Analysis: The widow's prior rights in the joint family property arose under the Hindu Women's Rights to Property Act, 1937, and the partition deed of 16 June 1943 created a fresh life estate in her favour over agricultural land. The arrangement was treated as a disposition because the term includes an agreement or arrangement, and the reversion of the property was to all the disponers in proportion to their interests. The proviso to section 24 was held inapplicable because the widow had not been competent to dispose of the agricultural land before the partition.

Conclusion: The life interest created by the partition deed fell within section 24, and the value of the 25 acres was exempt from levy of estate duty.

Ratio Decidendi: A partition arrangement that creates a life estate in favour of a person who had no prior power to dispose of the property, with reversion to the disponers, constitutes a disposition within section 24 of the Estate Duty Act, 1953 and attracts the statutory exemption.

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