RAM JIVAN vs SMT. PHOOLA (DEAD) BY LRS. & ORS.

The Supreme Court held that under Section 172 of the U.P. Zamindari Abolition and Land Reforms Act, 1950, the holding of a bhumidar who dies after vesting devolves upon the nearest surviving heir. The Court clarified that the distinction between a widow inheriting from her husband (Section 172) and a widow with an independent interest (Section 174) is significant. The appeal was allowed, affirming that the respondent's mother, having inherited the holding, did not pass on her interest upon her death, as the appellant's claim was based on a misinterpretation of the law regarding succession.