DHANRAJ vs SMT. SURAJ BAI

The Supreme Court held that under Section 6(ii) and Section 9(1) of the Hindu Adoptions and Maintenance Act, 1956, a step-mother lacks the capacity to give her step-son in adoption, as the term 'mother' refers to the natural mother. The Court emphasized that the physical act of giving and receiving is essential for a valid adoption, and a person over the age of 15 cannot be adopted unless permitted by custom. The appeal was dismissed, affirming the lower courts' decisions regarding the invalidity of the adoption.