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Supreme Court settles nomination dispute over GPF, rules wife and mother of deceased must share fund as per legal norms

Vivek G.

Supreme Court settles GPF nomination dispute, ruling wife and mother must share deceased employee’s fund equally; explains nominee has no exclusive right. - Smt. Bolla Malathi vs. B. Suguna & Ors.

Supreme Court settles nomination dispute over GPF, rules wife and mother of deceased must share fund as per legal norms

In a packed courtroom on Friday, the Supreme Court of India untangled an emotional family dispute that had snowballed into a complex legal battle: Who should receive the General Provident Fund (GPF) of a deceased government employee the wife or the mother?

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The bench of Justice Sanjay Karol and Justice Nongmeikapam Kotiswar Singh heard arguments from both sides, ultimately restoring an earlier order that mandated equal distribution of the fund between the two women.

Background

Bolla Mohan, who worked with the Defence Accounts Department, married in 2003 and passed away in service in July 2021. His wife, Smt. Bolla Malathi, the appellant, had already received other employment-related benefits amounting to Rs. 60 lakh. But when she applied for the GPF savings, the authorities denied her claim the nominee on record was the deceased’s mother, B. Suguna.

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The dispute moved through multiple legal forums. The Central Administrative Tribunal (CAT) had ordered a 50-50 split of the GPF, holding the mother’s original nomination became invalid once Mohan married and formed a “family”. But the Bombay High Court reversed that order, directing that the entire GPF be given only to the mother.

Court’s Observations

The Supreme Court disagreed with the High Court’s reasoning. It highlighted that while the deceased did not update his GPF nomination, the rules themselves clearly state that a nomination becomes invalid once a subscriber acquires a family.

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Justice Karol remarked that the purpose of the regulations is to prevent situations where valid dependents are unfairly excluded merely due to paperwork delay or oversight. The bench observed:

“The condition stipulated in the nomination form rendered such nomination, at the time of death, void.”

The judges also reiterated the settled principle that a nominee is only a recipient, not the final owner of funds after a subscriber’s death. “Nomination only indicates the hand which is authorised to receive the amount,” the judgment reminded.

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Both the wife and mother are legally recognised dependents. The Court emphasized that ignoring the wife’s entitlement would be unjust, particularly when she was already acknowledged in other employment benefits and had shared responsibility during the marriage.

Decision

The Supreme Court allowed the wife’s appeal and restored the CAT decision ordering equal sharing of the GPF. It directed that the mother’s half of the deposit, currently lying with the Bombay High Court registry, be released in her favour upon application within two weeks.

With that, the Court closed the matter, bringing relief and clarity to a dispute driven as much by personal grief as by legal complexities.

Case Title:- Smt. Bolla Malathi vs. B. Suguna & Ors.

Case Number:- Civil Appeal No. 14604 of 2025

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