A wife’s registered title stands despite failure to prove independent purchase funds.

The plaintiff sued for a declaration concerning land measuring 3 acres 19 guntas, asserting that he had paid the purchase price, although the registered sale deed was executed in his wife’s name.

He also sought an injunction against its transfer.

The defendant claimed the land as her own and denied that the plaintiff had funded its purchase.

The Trial Court dismissed the suit, finding that the plaintiff had not proved the property was joint-family property and that the defendant had not proved purchase from her independent income; it nevertheless held her to be the owner, relying on Section 14(1) of the Hindu Succession Act, 1956.

The First Appellate Court dismissed the plaintiff’s appeal. He then brought this second appeal.

Section 14(1) of the Hindu Succession Act, 1956 provides that property possessed by a female Hindu, whether acquired before or after the Act, is held by her as full owner; the provision’s Explanation includes property acquired by purchase and in other ways.

The Court cited Gangamma v. G. Nagarathnamma, (2009) 15 SCC 756, for the principle that “acquired” in Section 14(1) is to be construed broadly.

It also applied the second-appeal principle that concurrent findings are not ordinarily disturbed unless shown to be perverse, contrary to the evidence, or vitiated by an error of law giving rise to a substantial question of law.

The Court held that the defendant’s failure to prove that she paid the purchase price from her independent income did not, by itself, determine ownership.

The registered sale deed stood in her name, and the Court considered that fact alongside the concurrent findings of the Courts below that she was the absolute owner.

It concluded that the absence of proof of her independent funds did not make those findings legally unsustainable, and found no basis for interference in the second appeal.

It dismissed the appeal and confirmed the judgments and decrees dismissing the suit.