Bhagat Ram v Teja Singh Case
🧑⚖️ Bhagat Ram v. Teja Singh (2002)
Citation: AIR 2002 SC 1
Court: Supreme Court of India
🔍 Background / Facts of the Case:
Parties:
Bhagat Ram (Appellant)
Teja Singh (Respondent)
The dispute involved the validity of a gift deed.
Bhagat Ram (the donor) had gifted immovable property to Teja Singh.
Later, Bhagat Ram tried to revoke or cancel the gift, claiming it was not accepted properly.
⚖️ Legal Issues Raised:
Is a gift valid if it is not accepted by the donee?
What are the essential conditions for a valid gift under the Transfer of Property Act, 1882?
📜 Relevant Law:
Section 122 of the Transfer of Property Act, 1882:
A gift is a voluntary transfer without consideration.
It must be accepted by the donee during the lifetime of the donor, while the donor is still capable of giving.
🧠 Key Legal Principles Applied:
A gift is incomplete and invalid unless the donee accepts it.
Acceptance can be expressed verbally, in writing, or through conduct (e.g., taking possession).
The burden of proof lies on the donee to show acceptance.
🏛️ Supreme Court’s Decision:
The Supreme Court held that:
The gift deed was not valid, as Teja Singh did not accept the gift properly.
Just executing a gift deed is not enough — acceptance is mandatory under law.
Since there was no proof of acceptance, the gift was ineffective and revocable.
✅ Significance of the Case:
Clarified that acceptance is a must in gift transactions.
Reinforced that a donee cannot benefit from a gift without proving acceptance.
Serves as a leading case on gift law under Hindu and general property law.
📝 Summary Table:
| Element | Decision in Bhagat Ram v. Teja Singh |
|---|---|
| Type of Case | Validity of a gift under Transfer of Property Act |
| Key Issue | Was the gift accepted? |
| Supreme Court Held | No valid acceptance = No valid gift |
| Legal Rule Applied | Section 122, Transfer of Property Act |
| Outcome | Gift deed declared invalid |
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