Smt. Bolla Malathi Vs B. Suguna And Ors. (Supreme Court of India)
Nominee Not Absolute Owner: Supreme Court Applies Succession Principles to GPF Dispute- GPF Nomination Automatically Invalid After Marriage — Wife & Mother Get 50% Each
Supreme Court dealt with dispute between wife & mother of deceased Central Government employee over entitlement to GPF. Deceased joined service in 2000 & nominated his mother for GPF/CGEIS/DCRG. After marriage in 2003, he changed nomination for CGEIS & DCRG in favour of wife but did not amend GPF nomination. He died in 2021. Wife received all terminal benefits of Rs.60 lakhs except GPF. Authorities refused her GPF claim citing mother as nominee.
CAT held original GPF nomination became invalid once deceased “acquired family”, as per GPF(CS) Rule 5 & Note 2 to Rule 476, resulting in equal distribution between mother & wife. High Court reversed CAT, holding no auto-cancellation unless subscriber formally cancels nomination under Rule 5(6).
SC rejected High Court’s reasoning. It held that when nomination form explicitly states it becomes invalid on acquiring family, the nomination becomes void by operation of condition. SC reaffirmed Sarbati Devi, Shakti Yezdani & Shipra Sengupta that nomination only indicates the person authorised to receive, not beneficial entitlement. Since earlier nomination was void, GPF amount must be distributed under Rule 33, i.e., equally among eligible family members. SC restored CAT order, directing release of remaining 50% GPF to mother.
