Sri Mahesh vs Sangram (2025) Case Analysis

Why in Spotlight? - Sri Mahesh vs Sangram (2025)

Recently, the 2-Judge Bench of the Supreme Court comprising Justice C.T Ravikumar and Justice Prashant Kumar Mishra analysed the applicability of the doctrine of relation back in the case of Sri Mahesh vs Sangram (2025) regarding the Hindu Succession and Adoption laws.

Introduction of Sri Mahesh vs Sangram (2025)

Sri Mahesh vs Sangram (2025) centers around the issue of whether an adopted son can claim ownership over absolute property of his adoptive mother acquired before his adoption. The Supreme Court analysed the applicability of the Doctrine of Relation Back in the context of Hindu Succession and Adoption laws specifically regarding the property rights of an adopted child in relation to the ownership of an adoptive mother.

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Historical Context and Facts of Sri Mahesh vs Sangram (2025)

The case at hand centres around the appeal of a partition suit filed by the Appellant Sri Mahesh challenging the legality of sale and gift deeds executed by his adoptive mother Parvatibai after the death of her husband. The Supreme Court examined the applicability of the Doctrine of Relation back. The following are the brief facts of the case of Sri Mahesh vs Sangram -

Facts of the Case

The Appellant Sri Mahesh (Plaintiff in the original suit) sought partition and separate possession of the suit schedule properties. The Appellant claimed entitlement to a half share as the adopted son of Parvatibai. Parvatibai was the widow of Bhavakanna Shahapurkar who was the original owner of the properties. Bhavakanna had married Laxmibai during his lifetime without the dissolution of marriage. As a result, conflict arose between the widows and their descendants, which resulted in a compromise decree.

Adoption of the Appellant

The Appellant Sri Mahesh was adopted on 16th January, 1994 at the age of 21 and claimed inheritance rights as legal heir of Bhavakanna. The Appellant contested the legality of a sale deed dated 13th December, 2007 which was executed by Parvatibai in favor of Defendants 2 and 3 and a gift deed dated 27th August, 2008 which was executed in favor of Defendants 4 and 5 asserted that they were invalid without his consent.

Defense by Parvatibai and Other Defendants

Parvatibai in her written statement accepted the adoption but she argued that it did not divest her of the absolute ownership of the properties. She maintained that the properties were allotted to her following the compromise decree. Defendants 2 to 5 also supported her claim and contended that they were the rightful owners under the sale and gift deeds.

Trial Court Judgment

Parvatibai passed away during the proceedings. The Trial Court partially decreed the suit on 31st March, 2018. The Court declared the gift deed dated 27th August, 2008 as invalid, granted ownership of the properties in schedules B and C to the Appellant and upheld the legality of the sale deed dated 13th December, 2007.

Appeals Before the Karnataka High Court

Aggrieved by the decision of the Trial Court both the Appellant and Defendants 4 and 5 filed appeals. The High Court of Karnataka reviewed the case and upheld the compromise decree. Thus, the Court ruled that the ownership of Parvatibai was absolute under the compromise decree and the claim of the Appellant was unsubstantiated.

Appeal in the Supreme Court

The Appellants, dissatisfied by the decision of the High Court of Karnataka, approached and filed an appeal in the Supreme Court.

Issue addressed in Sri Mahesh vs Sangram (2025)

Whether an adopted son could claim ownership rights over his adoptive mother absolute property acquired before his adoption and acknowledging the applicability of the Doctrine of Relation Back and the provisions under the Hindu Succession Act and Hindu Adoption and Maintenance Act was addressed in the case of Sri Mahesh vs Sangram.

Legal Provisions involved in Sri Mahesh vs Sangram (2025)

Section 14 of Hindu Succession Act and Section 12 of Hindu Adoption and Maintenance Act played a significant role. The following are the analysis of these provisions -

Section 14 of Hindu Succession Act: Property of a Female Hindu to Be Her Absolute Property

Section 14 grants a woman full ownership of her property. It aims to improve the rights of women and is applicable to properties owned by a woman when the Act came into force.

Section 12 of Hindu Adoption and Maintenance Act: Effect of Adoption

According to Section 12, an adopted child is considered the child of the adoptive parents from the adoption date. However, the child cannot marry someone they could not have married in their birth family, property owned before adoption remains with the child and the child cannot divest any estate vested before adoption.

Judgment and Impact of Sri Mahesh vs Sangram (2025)

On 2nd January, 2025 the 2-Judge Bench of the Supreme Court comprising Justice C.T Ravikumar and Justice Prashant Kumar Mishra examined the applicability of the Doctrine of Relation Back in cases involving Hindu Succession and Adoption laws. The case of Sri Mahesh vs Sangram addressed whether an adopted son could claim ownership rights over his adoptive mother absolute property or not?

The Supreme Court held that the Doctrine of Relation Back is applicable when an adopted child asserts coparcenary rights in joint property which take effect from the date of death of the adoptive father and not from the adoption date. The Court in Sri Mahesh vs Sangram also stated that this principle does not extend to absolute property of a female Hindu acquired posthumously by the adoptive mother.

The Supreme Court explained that under Section 14(1) of Hindu Succession Act (HSA) 1956 a female Hindu can acquire absolute ownership of property after the death of her husband. On the other hand, Section 12(c) of Hindu Adoption and Maintenance Act (HAMA) 1956 prohibits the adopted child from divesting anyone of any estate vested in them before the adoption. Therefore, the absolute property of the adoptive mother acquired before the adoption remains her exclusive property and the adopted child in such a case has no right to challenge transactions involving that property after adoption.

The Supreme Court in Sri Mahesh vs Sangram relied on previous precedents such as Kasabai Tukaram Karvar v. Nivruti (2022) and Shripad Gajanan Suthankar v. Dattaram Kashinath Suthankar (1974).

Thus, the Supreme Court in Sri Mahesh vs Sangram ruled that adoption ensures the adopted child inherits rights as if born to the deceased adoptive father and does not retroactively affect lawful actions or ownership established by the adoptive mother.

Conclusion

In Sri Mahesh vs Sangram (2025) the Supreme Court ruled that the Doctrine of Relation Back allows an adopted child to assert rights over coparcenary property from the death of adoptive father and it does not extend to the absolute property of a female Hindu acquired posthumously.