DINAJI &ORS vs DADDI

The Supreme Court held that the widow, after executing the deed of adoption, retained her rights in the property as the adoption does not divest her of her ownership under Section 12(c) of the Hindu Adoptions and Maintenance Act, 1956. The Court clarified that the adopted child does not acquire rights to the property until the widow's death, and thus, the deed of adoption, which attempted to create immediate rights for the adopted son, required registration under Section 17(1)(b) of the Indian Registration Act, 1908. The appeal was allowed, overturning the High Court's decision that had dismissed the appellant's claim to the property.