Smt. Bolla Malathi vs. B. Suguna and Ors. (2025)

The Supreme Court holds that pre-marriage GPF nomination becomes invalid after marriage, and funds must be shared between wife and mother.
Supreme Court of India

Legal provisions involved: Rule 33 of the General Provident Fund (Central Service) Rules, 1960; Note 2 to Rule 476(V) of the Official Manual (Part V)

Judgement by: Supreme Court

Judge/Bench: Justices Sanjay Karol and Nongmeikapam Kotiswar Singh

Facts

The government employee had named his mother as the nominee for his General Provident Fund (GPF) in the year 2000. Later, when he got married in 2003, he changed the nominations for some service benefits in favour of his wife but did not update the GPF nomination. After his death in 2021, his wife received the other service benefits. However, the GPF money was not paid to her because the official records still showed his mother as the nominee for the GPF.

Key legal provisions

Issues raised

  1. Whether the mother’s pre-marriage nomination became invalid after the employee married?
  2. Whether the GPF amount should go only to the nominee or be shared among the rightful family members?

Arguments of the case

The wife argued that the pre-marriage nomination became invalid after the employee married, so the GPF money should be shared with the family. The mother argued that the nomination remained valid since the employee had not officially changed it, showing he wanted her to receive the money.

Judgement

The Supreme Court ruled that the mother’s pre-marriage GPF nomination became invalid after the employee married, and the funds must be equally shared between the wife and mother, overturning the Bombay High Court’s decision.

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