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Supreme Court Says Minors Can Void Guardian Sales Through Conduct

The ruling in K S Shivappa v. K Neelamma restores the trial court decree, placing the onus on subsequent purchasers to seek relief.

Overview

  • Delivering judgment on October 7, a bench of Justices Pankaj Mithal and P.B. Varale held that a now‑adult can repudiate a guardian’s unauthorized sale either by filing a suit or through unequivocal conduct such as re‑selling the property.
  • The court clarified that transfers by a natural guardian without prior court permission under the Hindu Minority and Guardianship Act, 1956 are voidable at the minor’s instance, not void.
  • Repudiation must occur within the limitation period after majority, with the court noting practical reasons for allowing avoidance by conduct when a suit may be impractical or unnecessary.
  • The Supreme Court restored the Davanagere trial court’s decree in favor of K S Shivappa and dismissed K Neelamma’s claim, finding no valid title had passed through the earlier chain of sales.
  • The judgment reaffirmed that power‑of‑attorney holders cannot testify on matters within the principal’s personal knowledge, faulting the plaintiff for relying on proxy evidence to prove title.