Hey learners,
In a quiet village, two brothers lived together sharing ancestral property passed down through generations. The elder brother died first, leaving behind his widow Sitabai, who continued to stay with her younger brother-in-law, Dulichand. Over time, a child named Ramchandra was born from their relationship.
Years later, Sitabai formally adopted a young boy named Suresh Chandra, hoping to secure a successor for her late husband’s lineage. When Dulichand eventually passed away, both boys — one adopted and one biological — stood on opposite ends of a legal battle over who had the rightful claim to the ancestral house and land.
The dispute became more than a family matter — it raised powerful legal questions about whether a widow can adopt a child who gains full coparcenary rights, and whether a biological son born out of an irregular relationship has priority over a lawfully adopted son.
This case became a defining moment in Hindu adoption and coparcenary law.
Smt. Sitabai & Another vs. Ramchandra (1969) Case Details
| Particular | Information |
|---|---|
| Court | Supreme Court of India |
| Date of Judgment | 20 August 1969 |
| Citation | AIR 1970 SC 343 |
| Area of Law | Hindu Adoption & Coparcenary Property |
| Key Issue | Competing inheritance rights between an adopted son and an illegitimate biological son |
| Want to study more Case Briefs? | Read Now |
Facts of the Case
- Two brothers jointly owned ancestral family property.
- The elder brother, Bhagirath, died and his widow Sitabai continued living in the joint household.
- A child, Ramchandra, was later born to Sitabai and Dulichand (the surviving brother).
- Before Dulichand’s death, Sitabai formally adopted a boy named Suresh Chandra.
- After Dulichand passed away, Ramchandra claimed rights to the entire ancestral property.
- Sitabai and the adopted son argued that adoption legally made Suresh a coparcener entitled to ancestral rights.
- The matter escalated through multiple courts and eventually reached the Supreme Court.
Legal Issues
- Can a widow validly adopt a child who then becomes a coparcener in ancestral family property?
- Does ancestral property retain its character as joint family property when only one coparcener remains alive?
- Does the adopted son have priority over an illegitimate biological son in inheritance rights?
Arguments of Both Sides
Plaintiffs (Sitabai & Adopted Son)
- The adoption was lawful, and the adopted son must be treated exactly like a natural born son.
- Joint family property does not lose its legal character merely because only one male member remains.
- The adopted son therefore becomes a coparcener with full inheritance rights.
Defendant (Ramchandra)
- As the biological son of the last surviving coparcener, he argued he should automatically inherit the entire property.
- He claimed that the widow’s adoption could not override his natural right of inheritance.
Judgment
The Supreme Court ruled in favour of Sitabai and the adopted son. The Court held:
- A widow has the legal authority to adopt a son, and such adoption gives the adopted child the same status as a natural born son.
- The ancestral property does not become private or self-acquired property simply because only one coparcener remains.
- Therefore, the adopted son became a rightful coparcener entitled to share in the ancestral property.
- The illegitimate biological son could not exclude or defeat the rights of the legally adopted son.
Legal Principle (Ratio)
- Adoption by a widow creates full legal rights equivalent to that of a natural born son.
- Joint family property retains its ancestral character regardless of the number of surviving coparceners.
- An adopted son stands equal in law and cannot be displaced by an illegitimate biological heir.
Why the Case Is Important
- This judgment strengthened the legal position and dignity of adopted children in Hindu families.
- It clarified uncertainties about inheritance when only one male member survives in a joint family.
- It reinforced that adoption is not symbolic — it carries complete legal and property consequences.
The ruling in Sitabai & Another vs. Ramchandra remains a cornerstone judgment on Hindu adoption law. The Court upheld the idea that lawful adoption ensures continuity of lineage and property rights within a Hindu family. It also confirmed that legal adoption stands on equal footing — and sometimes higher — than biological relationships formed outside marriage.
This case continues to guide courts in matters involving adoption, ancestral property, and legitimacy of heirs.