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The Supreme Court ruled on January 13, 2026, that a Hindu daughter-in-law who becomes a widow after her father-in-law's death qualifies as a "dependant" under Section 21(vii) of the Hindu Adoptions and Maintenance Act, 1956 (HAMA), entitling her to maintenance from his estate.​

Case Background

Geeta Sharma, daughter-in-law of late Dr. Mahendra Prasad (died Dec 2021), filed for maintenance after her husband died in March 2023. The Family Court dismissed it, but the High Court reversed, deeming her a dependant.​

Key Ruling

A Bench of Justices Pankaj Mithal and SVN Bhatti held that "any widow of his son" under Section 21(vii) includes all such widows, regardless of the son's death timing relative to the father-in-law. Section 22 obliges heirs to maintain dependants from inherited estate, provided she cannot sustain from her husband's or children's estate.​

Legal Reasoning

The Court applied literal interpretation, noting the absence of "predeceased" before "son." Classifying widows by timing violates Article 14 (equality) and Article 21 (dignity), lacking rational nexus with HAMA's welfare object.

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Test Date: 29/01/2026

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BA LLB course fees are ₹5,999 for 3 months.​ LLM fees stand at ₹9,999 for 2-3 months.​

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Judiciary (Law Subjects) online fees are ₹24,999 for 18-24 months.​ Regular Judiciary fees are ₹19,999 for 12-15 months.​

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