The Jharkhand High Court has held that nomination in a Life Insurance Corporation (LIC) policy does not override succession rights of Class I heirs under the Hindu Succession Act, 1956, particularly when the nominee is deceased. The decision upholds the established principle that succession certificates in respect of such policies must issue to Class I legal heirs, reaffirming binding precedent for succession proceedings and clarifying the exclusion of Class II heirs when Class I heirs exist.
Summary
| Category | Data |
|---|---|
| Case Name | MA/104/2025 of DINESH MANDAL ALIAS DINESH PRASAD MANDAL Vs SMT. ALKA RANI |
| CNR | JHHC010399522024 |
| Date of Registration | 28-03-2025 |
| Decision Date | 30-10-2025 |
| Disposal Nature | Dismissed |
| Judgment Author | HON’BLE MR. JUSTICE GAUTAM KUMAR CHOUDHARY |
| Court | High Court of Jharkhand |
| Bench | Single Bench |
| Precedent Value | Binding authority for subordinate courts in succession certificate disputes |
| Overrules / Affirms | Affirms established principle under Hindu Succession Act, 1956 regarding rights of Class I heirs |
| Type of Law | Succession / Inheritance Law |
| Questions of Law | Whether a nominee under an LIC policy has inheritance rights over Class I legal heirs after the nominee’s demise? |
| Ratio Decidendi |
The Court held that nomination of a person (in this case, mother) in an LIC policy does not confer succession rights over Class I legal heirs if the nominee dies. Issuance of a succession certificate is governed by the Hindu Succession Act, 1956, which provides that Class I heirs (here, the widow and son) are entitled, to the exclusion of Class II heirs (such as brothers and relatives). The challenge based solely on nomination was rejected since the nominee (mother) had predeceased, and the lawful claim passed to the widow and minor son. The appeal by the objectors (Class II heirs) was dismissed as lacking merit. |
| Judgments Relied Upon | Cites the legal position under the Hindu Succession Act, 1956 (as expressly noted in the order). |
| Logic / Jurisprudence / Authorities Relied Upon by the Court | Emphasises the statutory hierarchy of heirs under the Hindu Succession Act, where Class I heirs exclude Class II heirs; nomination does not override statutory succession. |
| Facts as Summarised by the Court |
The deceased (husband of respondent no.1) had obtained LIC policies and nominated his mother, who subsequently died. Respondent no.1 (widow) and her minor son sought a succession certificate. The objectors (brothers and other relatives) challenged the grant, arguing based on the mother’s nomination. The trial court issued the certificate to the widow and son; the High Court affirmed, noting the nomination right was extinguished due to the nominee’s death and Class I heirs’ priority. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts within Jharkhand in succession certificate and inheritance matters |
| Persuasive For | Other High Courts, particularly in issues concerning the effect of nomination on succession rights |
| Follows | Statutory scheme of the Hindu Succession Act, 1956 regarding Class I and Class II heirs |
What’s New / What Lawyers Should Note
- Reaffirms: Nomination in an LIC policy gives no preference or special right over statutory heirs under the Hindu Succession Act; upon nominee’s death, rights devolve strictly according to succession law.
- Clarifies: Class I heirs take precedence, and Class II heirs are expressly excluded when Class I heirs exist.
- Practical Use: Lawyers can cite this judgment in succession certificate disputes where nominees have predeceased or are not Class I heirs.
- Dismisses: Objections by relatives (Class II heirs) solely on the ground of nomination, especially when statutory succession dictates otherwise.
Summary of Legal Reasoning
- The Court found no dispute on material facts: the deceased died leaving behind LIC policies naming his mother as nominee, who herself died after the policyholder.
- The appellants, who are brothers and relatives (Class II heirs), objected to the grant of succession certificate to the widow and son (Class I heirs), relying on nomination in the LIC policy.
- The Court reasoned that the law under the Hindu Succession Act, 1956, clearly provides that where there are Class I heirs (such as widow and son), Class II heirs cannot claim succession.
- The plea based solely on nomination was deemed inapplicable since the nominee had already died, thus extinguishing that right, and no statutory right passes to other relatives via nomination.
- The Court affirmed the trial court’s decision to issue the certificate to the widow and son, dismissing the appeal with costs for lack of merit.
Arguments by the Parties
Petitioner
- Contended that the deceased’s wife had mentally and physically tortured him and had been residing separately.
- Argued that the mother (now deceased) was made nominee in the LIC policy, implying entitlement passed through her.
Respondent
- Defended the judgment on the basis there was no dispute regarding the widow’s status as wife of the deceased.
- Submitted proof of entitlement to the succession certificate for the LIC policies as widow and minor son, supported by the trial court’s findings.
Factual Background
The deceased obtained LIC insurance policies and designated his mother as nominee. After his demise on 11.04.2021, the nominee (his mother) also passed away on 02.09.2021. The widow and minor son applied for a succession certificate. Brothers and other relatives objected, arguing primarily on the basis of the mother’s earlier nomination. The trial court granted the certificate to the widow and son; the objectors appealed to the High Court.
Statutory Analysis
The Court applied the Hindu Succession Act, 1956, specifically the provision that Class I heirs (including widow and son) are entitled to succeed to a deceased Hindu’s estate to the exclusion of Class II heirs (brothers, sisters, etc.). The judgment reaffirms that nomination for insurance policies does not override the order of succession specified by statute.
Dissenting / Concurring Opinion Summary
No dissenting or concurring opinions are recorded in this judgment.
Procedural Innovations
No procedural innovations, new guidelines, or changes to evidence rules are recorded in this judgment.
Alert Indicators
- ✔ Precedent Followed – Existing law under Hindu Succession Act, 1956, is affirmed and applied.