Registration of an adoption deed is not essential for its validity under the Hindu Adoptions and Maintenance Act.

The applicant, B. Nagmohan Rao, claimed to be the adopted son of late B. Rajkumari, a Railway employee who died in service on 21.08.2008.

The applicant presented an adoption deed dated 20.01.2000 and obtained a decree from the 8th Civil Judge Class 2, Durg, on 27.01.2011, declaring him the validly adopted son and legal heir.

While the respondents paid the settlement dues based on a Succession Certificate, they rejected his application for compassionate appointment via letter dated 21.01.2010 on the grounds that the adoption deed was not registered under the Hindu Adoptions and Maintenance Act, 1956.

The applicant challenged this rejection through a representation in 2017, which was denied on 08.09.2017.

1. Whether registration of an adoption deed is a mandatory prerequisite for it to be considered legally valid for the purpose of granting compassionate appointment.

2. Whether the decree of a competent Civil Court declaring the applicant’s status as an adopted son is binding on the respondent authorities.

Hindu Adoptions and Maintenance Act (HAMA), 1956, specifically noting that the Act prescribes the method of adoption but does not mandate registration as the only proof of validity.

Section 16 of the HAMA regarding the presumption of registered documents.

Union of India vs. Sukhpreet Kaur (2025), which held that adoption can be performed via customary methods (giving and taking) without a registered deed.

Shanu Kumar v. The Nagar Ayukt Municipal Commissioner and Chandrasekhara Mudaliar v. Kulnadaivelu Mudaliar, establishing that administrative officers cannot ignore civil decrees or registered deeds based on technicalities.

The Tribunal found that the respondents’ rejection was based on an erroneous interpretation of law.

The court reasoned that under HAMA, the core requirement is the ceremony of "giving and taking," and while registration provides a legal presumption under Section 16, its absence does not automatically invalidate an adoption.

The Tribunal emphasized that a competent Civil Court had already declared the applicant as the legally adopted son in 2011, and the respondents had no authority to "disbelieve" or "brush aside" a judicial decree that remained unchallenged.

Consequently, the Railway Board’s denial based solely on the lack of registration was deemed arbitrary and contrary to existing legal principles.

The order dated 08.09.2017 was quashed and set aside, and respondents were directed to consider the applicant’s case for compassionate appointment within three months.