The Supreme Court dismissed the appeal, upholding the High Court’s decision that the property was rightly determined to be the exclusive asset of the partnership firm under Section 14 of the Partnership Act.

The Court reiterated settled law that when an individual partner contributes property to the firm, it becomes the firm’s property. The evidence of intention to contribute the property was established through the conduct and partnership deeds.

High Court’s Interpretation of Section 14 of the Partnership Act — (Paras 11–12) Legal Precedents Cited — (Paras 13–14) Clarification of Ownership in Favor of the Firm — (Paras 15–16) Dismissal of Appeal — (Para 18)

Acts and Sections Discussed:

• Constitution of India, 1950 — Article 136 — Special Leave to Appeal — Jurisdiction of the Supreme Court

• Indian Partnership Act, 1932 (Partnership Act) — Section 14 — Property of the Firm — Determination of Partnership Property

• Transfer of Property Act, 1882 — Modes of Transfer — Validity of Relinquishment Deed

Subjects:
Property of Firm — Partnership Deed — Relinquishment Deed — Title and Ownership — Legal Heirs — Registered Document — Contribution of Property — Section 14 of Partnership Act

Nature of the Litigation:
The case arose from a dispute over the ownership and possession of property claimed to be the asset of a partnership firm, where the appellant contested the rights of the firm over the property.

Relief Sought:
The appellant sought reversal of the High Court’s order, challenging the ownership of the property declared in favor of the partnership firm.

Reason for Filing the Case:
The appellant claimed rights over the property purchased by his late father and alleged that the firm had no exclusive ownership over the same.

Previous Decisions:

• Trial Court Judgment (December 22, 2020): Decreed in favor of the partnership firm, holding it as the sole owner of the property.

• High Court Order (March 9, 2022): Clarified that the decree must be read solely in favor of the firm, M/s Hotel Alka Raje.

Issues:
a) Whether the High Court was correct in clarifying ownership in favor of the firm alone.
b) Whether transfer of property rights could take place through a relinquishment deed.

Submissions/Arguments:

• Appellant: Contended that ownership could not be transferred through a relinquishment deed and required formal transfer methods under the Transfer of Property Act.

• Respondents: Did not appear, and the matter remained uncontested from their side.