Angadi Chandranna v. Shankar and Others
- Vaishnavi Majji
- Oct 16
- 2 min read
Updated: Oct 21
In Angadi Chandranna v. Shankar and Others (2025 INSC 532), decided on April 22, 2025, the Hon’ble Supreme Court dealt with a long standing dispute over whether a piece of land formed part of the ancestral joint family property or was the self-acquired property of one coparcener. The case arose from a 1986 registered partition deed executed among three brothers dividing their joint family property. Subsequently, one brother purchased a portion of land from another in 1989 and later sold it in 1993.
The plaintiffs, being the children of the brother who sold his property, claimed that the property was still joint family property and sought partition. The defendants contended that the 1989 purchase was made by the brother from his own earnings and a bank loan, and hence it was self-acquired property over which he had full rights of ownership and alienation.
The Hon’ble Supreme Court agreed with the defendants, holding that once a registered partition deed is executed, each coparcener’s share becomes his independent and self-acquired property. The Court emphasized that there is no legal presumption that property remains joint merely because the family continues to exist as a unit.
The Court found that the 1989 transaction was made with the brother’s own resources, and therefore, his sale in 1993 was valid. It also reiterated that under Section 100 of the Code of Civil Procedure, a High Court can interfere in a second appeal only on a substantial question of law and cannot reassess factual findings. By setting aside the High Court’s contrary view, this judgment underscores the sanctity of registered partition deeds and reinforces the finality of property rights emerging from such partitions.
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