Doctrine of blending applies only to coparceners; a non-coparcener cannot convert self-acquired property by unilateral declaration.

A female Hindu member who is not a coparcener cannot, by unilateral declaration, impress her self-acquired property with the character of joint family property. The doctrine of blending applies only where a coparcener voluntarily abandons separate rights in favour of the joint family estate; a non-coparcener lacks that capacity. The existence of ancestral or joint family property is not a prerequisite for a coparcener to blend separate property, but that principle does not extend to a non-coparcener. Accordingly, the declared conversion was ineffective and the income remained assessable in her individual hands.

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Issues: Whether a female Hindu member who is not a coparcener can impress her self-acquired property with the character of joint family property by a unilateral declaration, and whether such conversion requires the existence of joint family property or a coparcenary nucleus.

Analysis: The rule of blending, as applied in Hindu law, rests on the existence of a coparcenary and on the act of a coparcener voluntarily abandoning separate rights in favour of the joint family estate. A female member who is not a coparcener does not possess that legal capacity. The Court further held that the existence of ancestral or joint family property is not a condition precedent for a coparcener to impress separate property with joint family character, but that principle does not assist a non-coparcener. The assessee's declaration was otherwise complete, yet it could not operate to transfer the character of the property into joint family property because she was not a coparcener.

Conclusion: The assessee could not convert her share in the business into Hindu undivided family property by declaration alone, and the income remained taxable in her individual hands.

Ratio Decidendi: The doctrine of blending is available only to a coparcener; a non-coparcener female member cannot, by unilateral declaration, throw self-acquired property into the joint family hotch-potch.

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