Scope of section 21(vii) defining widowed daughter-in-law as a dependant

Section 21(vii) of the Hindu Adoptions and Maintenance Act, 1956, explicitly defines the relatives of a deceased Hindu who qualify as dependants entitled to maintenance from the estate. The statutory definition includes "any widow of his son" provided she is unable to maintain herself from her husband's estate, her children's estate, or her father-in-law's estate. The plain language of the statute employs the phrase "any widow of his son" without inserting any qualifying temporal restrictions or prefixing the term with "predeceased". This indicates a clear legislative intent to cover any widowed daughter-in-law seeking support from the deceased father-in-law's estate, regardless of the precise timing of her husband's demise. The statutory definition creates an enforceable legal right for a widowed daughter-in-law to seek maintenance against those who inherit the deceased's estate. Courts cannot read restrictions into this clear definition that the legislature intentionally chose to omit. Consequently, a daughter-in-law who becomes a widow after the death of her father-in-law falls squarely within the statutory ambit of a dependant under the Act. (Kanchana Rai v. Geeta Sharma & Ors. | 2026 INSC 54)