HON’BLE SUPREME COURT · SOURCE-REVIEWED NOTE
Smt. Sathyaprema Manjunatha Gowda v. Controller of Estate Duty, Karnataka
Civil Appeal No. 3021 of 1986
[1997] 3 SCR 586 ·
Hindu Law Women's Rights Act, 1933 (Mysore Act VIII of 1933): section 8(1)(d) · Estate Duty Act, 1953: sections 5, 6 and 64(1)
Sources & disclosures includedDownload original judgment / order
2-judge bench; unanimous order of the Court. · K. Ramaswamy, J. · D. P. Wadhwa, J.
Assessment years: Death on 18 August 1971
01 · Facts of the case
At a 4 May 1965 family partition, Manjunatha Gowda received a 4/5 share. After his 1971 death, his widow claimed that her share and the unmarried daughter's share should be excluded from estate duty under section 8(1)(d) (SCR pp.586-588; PDF pp.1-3).
Source: Primary judgment: facts
02 · Discussion by the Hon’ble Court
Clause (d) operated only where property passed to a sole coparcener by survivorship. The Court distinguished a Hindu joint family from the narrower coparcenary and held that this allotment became the deceased's individual property through partition, not survivorship. A contradictory phrase at SCR p.591 was treated as a report-level inconsistency in light of the reasoning and order (SCR pp.588-592; PDF pp.3-7).
Source: Primary judgment: discussion
03 · Judicial decision
The Court held that the widow and daughter had no section 8(1)(d) share, dismissed the appeal and made no costs order (SCR p.592; PDF p.7).
Source: Primary judgment: decision
04 · Outcome / in whose favour
In favour of Revenue: the claimed estate-duty exclusion failed (SCR p.592; PDF p.7).
Source: Primary judgment: outcome
05 · AKHB REVIEW POINT
AKHB analysis: identify the precise legal route by which family property reached the deceased. A partition allotment is not automatically property passing by survivorship; the historical statutory trigger controlled (based on SCR pp.591-592; PDF pp.6-7).
Source: Primary judgment: review point
Source & verification
Download original judgment / order · Open cited source rendition
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Statutory scope
The ruling concerns repealed estate-duty law and a historical Mysore Hindu-law enactment; it is not current succession or women's-property-rights advice.
Later treatment
Source checked 2026-10-11. Later judicial treatment and current statutory applicability have not been comprehensively checked; no current-law or citator clearance is represented.
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