Wednesday, 19 February 2014

In proceedings for heirship certificate Court is not required to determine title of deceased to any property



  In a proceedings for heirship certificate, the Court is 
not required to determine title of the deceased to any property.  It 
is required only to consider whether the persons claiming  heirship 
certificate   are   the   heirs   of   the   deceased.     If   any   person   comes 
forward   to   claim   nearer   kinship   than   the   applicants,     the   rival 
claims for the applicant and   the person claiming nearer kinship 
and to be an heir would be considered by the Court.   The Court 
may   decline   to   grant   heirship   certificate   to   any   applicant     and 
come   to   the   conclusion   that   the   applicant   is   not   an   heir   of   the 
deceased  or   that  there  are   nearer  kins  who  are  entitled to the 
heirship certificate.  The question of title to the property allegedly 
held   by   the   deceased   is   alien   to   such   enquiry.   Whether   the 

deceased had any title to the property is not and indeed cannot be 
decided by the Court in an application for an heirship certificate 
made under the Regulation. 

IN THE  HIGH COURT OF JUDICATURE AT BOMBAY
 APPELLATE SIDE
WRIT PETITION NO.1995 of 2010
Group Grampanchayat, Sasavane at
post Kolgaon

  versus
Sunanda Shamrao Bandishti & ors.

   CORAM :   D.G. KARNIK, J.
          
DATED :  14th  July  2010 
Citation;2011(5)BomCR162, 2011(2)MhLj424


Rule, returnable forthwith.   By consent of the parties, taken 
1.
up for hearing.

2.
WP No.1995/10
By this petition,  the petitioner challenges the order dated 6 
January   2010   passed   by   the   learned   Civil   Judge,   Sr.Division, 
Baramati   allowing   the   application   of   the   respondents   for 
amendment.
3.
Learned   counsel   for   the   respondent   raises   a   preliminary 
objection for maintainability of the writ petition at the instance of 
the   petitioner   on   the   ground   that   petitioner   is   not   a   “person 
aggrieved” by the impugned order and writ petition at his instance 
should not be entertained.  For deciding the preliminary objection, 
it is necessary to refer a few facts which is mentioned below.
4.
The   Respondents   filed   an   application   under   the   Bombay 
Regulation VIII of 1827 for an heirship certificate as heirs of  late 
Radhabai Damodar Joshi/Bhatt/Tisgaonkar/Newaskar.   Radhabai 
died on 1 January 1990 leaving behind her certain movable and 
immovable properties including Gat No.145 (Old survey no.46/1). 
Since the present petitioner i.e. Group Grampanchayat Sasavane, 
was   not   willing  to  recognise   the   respondents  to   be   the   heirs   of 

Radhabai,   the   petitioner   applied   to   the   court   of   Civil   Judge, 
Sr.Division,   Baramati   for   an     heirship   certificate   under   Bombay 
Regulation   VIII   of   1827.     In   the   application   for   the   heirship 
certificate,   the   respondents   initially   gave   the     description   of   all 
properties     left   behind   by   Radhabai.     Though   in   my   view 
unnecessary, the respondents  joined the  State of Maharashtra and 
the Group Grampanchayat Sasavane, (petitioner herein) as parties 
to   the   application     for   heirship   certificate.     Later   on,   the 
respondents   made   an   application   for   amendment   of   their 
application so as to delete the description of the properties alleged 
to have been inherited by them from Radhabai and addition of the 
following prayer:
“The   heirship   certificate   may   kindly   be 
granted   in   favour   of   the   present   applicants 
(respondents   in   the   writ   petition)   thereby 
declaring   them   to   be   the   sole   legal   heirs   of 
deceased Radhabai Damodar Joshi”
By an order dated 6 January 2010, the   application was allowed. 
That order is impugned in this petition.  

5.

Bombay Regulation VIII of 1827 (for short “ the Regulation”) 
was issued  on 1 January 1827 to provide for formal recognition, 
of   heirs,   executors   and   administrators   and   for   appointment   of 
administrator   and   managers   of   the   property   by   the   Courts. 
Preamble to the Regulation reads:
“WHEREAS, at the same time that it is in general 
desirable   that   the   heirs,   executors   or   legal 
administrators of persons deceased should, unless 
their right is disputed, be allowed to assume the 
management or sue for the recovery for Courts of 
justice,   it   is   yet   in   some   cases   necessary   or 
convenient   that   such   heirs,   executors   or 
administrators,   in   order   to   give   confidence   to 
persons   in   possession   of,   or   indebted   to,   the 
estate   of   acknowledge   and   deal   with   them, 
should   obtain   a   certificate   of   heirship, 
executorship, or administratorship, from the Zila 
Court;
And whereas, whenever there is no person 
on the spot entitled or willing to take charge of 
the property of a person deceased, or when the 

right   of   succession   is   disputed   between   two   or 
more   claimants,   none   of   whom   has   taken 
possession or where the heirs are incompetent to 
the management of their affairs and have no near 
relations  entitled  and  willing  to  take   charge  on 
their   behalf,   or   where   a   person   possessed   of 
property dies intestate and without known heirs, 
it is essential that the Zila Court should appoint 
an   administrator   for   the   management   of   the 
estate; the following rules are therefore enacted”
In Re Anthony Fernandez and others, 1993(1) Bom.C.R. 580 this 
Court has held that Bombay Regulation VIII of 1827 continues to 
be in force and the provisions thereof are supplemented in certain 
respects   by   the   Indian   Succession   Act,   1925.   Consequently,   an 
application for  recognition of a person as an heir of the  deceased 
can be made under the Regulation.   The present application was 
so made.  Clauses 7 and 8 of the Regulation are material and reads 
thus:­
7.
First : Recognized heirs, etc., competent to 
manage property:

An   heir,   executor   or   administrator, 
holding the proper certificate, may do all acts and 
grant all deeds competent to a legal heir, executor or 
administrator, and may sue  and obtain judgment in 
any Court in that capacity.
Second   :   But   recognition   gives   no   title   to 
property:
But, as the certificate confers no right to 
the property, but only indicates the person who, for 
the time being, is in the legal management thereof, 
the   granting   of   such   certificate   shall   not   finally 
determine nor injure the rights of any person; and 
the certificate shall be annulled by the Zila Court, 
upon   proof   that   another   person   has   a   preferable 
right.
Third   :     No   relief   from   responsibility   to 
claimants:
An   heir,   executor  or   administrator,   holding  a 
certificate, shall be accountable for his acts done in 
that capacity to all persons having an interest in the 
property, in the same manner as if no certificate has 
been granted.

8.

Refusal   of   a   recognition   no   judgment 
against claim of applicant:
The refusal of a certificate by the Judge shall 
not finally determine the rights of the person whose 
application is refused, but it shall still be competent 
to   him   to   institute   a   suit   for   the   purpose   of 
establishing his claim.”
6.
Interpreting the Regulation,   in  Aloysius Manuel D’souza & 
ors. Vs. Mary Kamala William Manuel D’souza, 2006(6) Bom.C.R. 
56,   a   Division   Bench   of   this   Court   has   held   that   the   grant   of 
heirship   certificate   does   not   establish   the   right   of   a   party   in 
property of the deceased by itself.   The right, if any, of a person 
claiming ownership in the property of the deceased are not taken 
away by grant of an  heirship certificate to an heir.  On the other 
hand,   clause   7   makes   it   clear   that   heirship   certificate   holder   is 
accountable to all persons having an interest in the property for 
the acts done by him.  Based on the heirship certificate simplicitor 
the heirship certificate holder cannot be said to have acquired any 
right, title or interest in the estate of the deceased. 

7.

The   only   contention   which   was   raised   by   the   petitioner 
before me was that Radhabai was not the owner of the property 
but   that   the   petitioner   was   the   owner.     Grant   of   an   heirship 
certificate to the petitioner would affect its rights in the property 
and therefore it was a person aggrieved having a right to challenge 
the impugned order.  In view of clauses 7 and 8 of the Regulation 
and    the  decision  of  the   Division  Bench  in   the   case  of  Aloysius 
D’Souza (supra) the contention cannot be accepted.  The grant of 
an heirship certificate to the respondents would not in any way 
affect  the right, title or interest, if there be any, of the petitioner in 
any of the properties   of the deceased Radhabai.   The petitioner 
does   not   claim   to   be   an   heir   of   Radhabai.     Consequently,   the 
present petitioner would not be a person aggrieved by any  order 
of grant or refusal of grant of the heirship certificate.     As such, 
the petitioner cannot be  a person aggrieved by the order allowing 
the amendment and would have  no right to contest the said order 
and challenge it by a writ petition. 

8.

Learned   counsel   for   the   petitioner   submitted   that 
respondents themselves had joined the petitioner as a party to the 
original application heirship certificate and being a party they have 
a   right   to   challenge   the   impugned   order.       In   my   view,   the 
petitioner  was not at all a necessary, not even a proper  party to 
the   application   made   by   the   respondents   for   the   heirship 
certificate.   In a proceedings for heirship certificate, the Court is 
not required to determine title of the deceased to any property.  It 
is required only to consider whether the persons claiming  heirship 
certificate   are   the   heirs   of   the   deceased.     If   any   person   comes 
forward   to   claim   nearer   kinship   than   the   applicants,     the   rival 
claims for the applicant and   the person claiming nearer kinship 
and to be an heir would be considered by the Court.   The Court 
may   decline   to   grant   heirship   certificate   to   any   applicant     and 
come   to   the   conclusion   that   the   applicant   is   not   an   heir   of   the 
deceased  or   that  there  are   nearer  kins  who  are  entitled to the 
heirship certificate.  The question of title to the property allegedly 
held   by   the   deceased   is   alien   to   such   enquiry.   Whether   the 

deceased had any title to the property is not and indeed cannot be 
decided by the Court in an application for an heirship certificate 
made under the Regulation.  
9.
The preliminary objection raised by the respondent for the 
maintainability of the writ petition at the instance of the present 
petitioner is upheld.   The present petitioner not   being   a person 
aggrieved and being not a necessary party to the original heirship 
application itself is not entitled to challenge the impugned order. 
It   must   also   be   mentioned   that   since   the   petitioner   is   not   a 
necessary party to the application, the trial Court may on its own 
consider   striking   off   the   name   of   the   petitioner   no.2   from   the 
heirship application in exercise of its powers under Order 1 Rule 
10(2), if the respondents  do not apply for such deletion.
10.
For   these   reasons   the   Writ   Petition   is   dismissed.     Rule 
discharged with no order as to costs.
(D.G. KARNIK,J.)

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