Urmila Dixit Vs. Sunil Sharan Dixit and Ors. [Civil Appeal No. 10927 of 2024 arising out of SLP (Civil) No. 720 of 2023]
- ByPravleen Kaur --
- 15 Jun 2025 --
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The Supreme Court of India, in Urmila Dixit vs. Sunil Sharan Dixit and Ors. [Civil Appeal No. 10927 of 2024 arising out of SLP (Civil) No. 720 of 2023], delivered a landmark judgment on January 2, 2025, reinforcing the protective objectives of the Maintenance and Welfare of Parents and Senior Citizens Act, 2007 (MWPSC Act).
Facts and Background
Urmila Dixit, an elderly mother, purchased a property in 1968. In 2019, she executed a Gift Deed transferring this property to her son, Sunil Sharan Dixit, accompanied by a promissory note (vachan patra), wherein Sunil promised to maintain her for life. The note also stipulated that failure to maintain her would entitle Urmila to revoke the gift deed. After the transfer, Urmila alleged neglect and mistreatment by her son and sought cancellation of the gift deed under Section 23 of the MWPSC Act, which allows annulment of property transfers if the transferee fails to provide maintenance.
The Maintenance Tribunal and subsequently the Collector upheld Urmila’s claim and declared the gift deed null and void. However, the Madhya Pradesh High Court reversed these orders, validating the gift deed and rejecting the revocation.
Legal Issues
The Supreme Court examined:
Whether Tribunals under the MWPSC Act have the power to annul property transfers and order eviction when maintenance conditions are violated.
The scope of Section 23 of the MWPSC Act concerning revocation of property transfers due to neglect.
The balance between property rights and the welfare and dignity of senior citizens.
Court’s Analysis and Findings
The two-judge bench, led by Justices Sanjay Karol and C.T. Ravikumar, held that the MWPSC Act must be liberally construed to uphold its humanitarian objectives. The Court affirmed that Tribunals have the authority to annul gift deeds and order eviction of transferees who fail to maintain their senior citizen parents, emphasizing the moral and legal obligation of children to care for their parents.
The Court rejected the High Court’s narrow interpretation that treated the gift deed as irrevocable despite neglect. It underscored that property rights cannot override the fundamental right of senior citizens to live with dignity and receive maintenance.
The judgment highlighted that the promissory note executed alongside the gift deed was a valid instrument creating enforceable obligations. Failure to honor such commitments justifies revocation of property transfer to protect senior citizens from exploitation.
Conclusion
The Supreme Court set aside the High Court’s decision, reinstating the Maintenance Tribunal’s order to annul the gift deed and uphold Urmila Dixit’s rights. The ruling:
Confirms the power of Tribunals under the MWPSC Act to revoke property transfers on failure to maintain.
Reinforces the legal and moral duty of children to care for their elderly parents.
Affirms a liberal and purposive interpretation of the MWPSC Act to protect senior citizens from neglect and abuse.
This judgment is a landmark in safeguarding senior citizens’ rights, balancing property law with social justice, and ensuring that elderly parents are not left vulnerable after transferring property to their children.
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