Narayana Swami v Pandiyan
Rule established
Hindu reversioner's interest is a present vested right, not spes successionis; transferable
Facts
- Hindu reversioner claimed a present right to challenge alienation by a widow
- Opposing party argued this was spes successionis (mere hope)
Issue
- Whether a Hindu reversioner's right is a spes successionis under S.6(a) or a present transferable interest.
Held
- The reversioner has a present right which is more than a mere expectation. It is not spes successionis. The interest is vested and capable of transfer.
Ratio Decidendi
A reversionary interest is a present right to revert upon termination of the prior limited estate. It exists NOW even though enjoyment is future. It is fundamentally different from a mere hope of inheriting from a living person.
How to use it in an exam
Cite to distinguish vested reversionary interest (transferable) from spes successionis (non-transferable). Key line: "A reversioner's interest is a present right, not a future hope."
Source
Source: AIR 1923 Madras 607
This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.
Cited in study notes
Transferable and Non-Transferable PropertyS.6(a): what is NOT spes successionis