Case law and Judgment (Hiba, husband should not take back his hiba gift)

 شوہر نے بیوی کو اراضی ہبہ (گفٹ ) کی اور بعد میں ہبہ (گفت) کی منسوخی کے لئے دعوی دائر کر دیا. '

لاہور ہائیکورٹ نے قرار دیا کہ شوہر ایک بار اراضی بیوی کو ہبہ (گفٹ کرنے کے بعد اس کو واپس نہیں لے

سکتا ہے ۔


The husband gifted the land to his wife and later filed a suit for cancellation of the gift. Lahore High Court (LHC) has ruled that a husband should not take back his wife once he has given her a gift(hiba)


Muhammad Riaz Vs. Province of Punjab through Collector & others Petitioner by: Mian Muhammad Ismail Thaheem, Advocate Respondents N.1 to 3 by: Mr. Muhammad Arif Raja, Additional Advocate General, Punjab. Respondents No.4 & 5 

by: Rana Mazhar Iqbal, Advocate Date of hearing: - 22.10.2020 

2020 LHC 2509

Judgment 

SHAHID WAHEED, J:- I have been presented with a case which reflects the social malaise where a husband being wearied of the withering beauty of his wife not only accuses her of dishonesty but also in the lure of his materialistic desire wants to take back his gift which he once made to her while recognizing her services, care and love. It is a trite saying that meaning of a legal system is derived from values in a given society. It would not be an overstatement to say that values are treated by our society on ethical basis, which are uncompromising in the matter of woman’s rights and do not allow her to labour under any legal disability. This value system stems from the concept of Islam which lay strong emphasis on the position of a wife. Within the Islamic traditions, the first and most important right that a wife has over her husband is to be treated with respect and kindness. When a woman gets married, she has financial rights over her husband in that he must provide her with all the necessities for her to live a comfortable life. It is thus, incumbent upon the husband to offer the provisions of house, food, clothing, healthcare and other tools required for her subjective standard of living. Given this values and in keeping with Articles 2-A, 3, 9, 25(3), 31, 34, 35, 37 and 38 of the Constitution of the Islamic Republic of Pakistan, 1973 (the Constitution), the legislatures have made special provisions to help woman in distress and for her protection against moral and material abandonment. The object of all our laws is that ill-used wives and discarded divorcees should not be driven to material and moral dereliction to seek sanctuary in the streets. And so we must appreciate the Islamic ethos and the general sociological background for the resolution of all such disputes. From this coign of vantage, I will view the present case.

2. Here the plaintiff, Muhammad Riaz, after the death of his first wife, married Fatima Bibi, defendant No.4, who was a divorcee and mother to two daughters. On 15th June, 1995 the plaintiff through mutation No.595 gifted 56 Kanals of his total 144 Kanals of land to his wife (defendant No.4). This land is situated within the revenue estate Chaito, Tehsil Phalia, District Mandi Bahauddin. Ten years later, Fatima Bibi sold 4 Kanals of the gifted land to Muhammad Anwar, defendant No.5, vide mutation No.840 dated 4th May, 2005. It appears that the plaintiff for his diminishing initial warmth and mutual affection made the said sale as the cause to bring a suit for the revocation of gift. The plaintiff in his suit for declaration joined Province of Punjab through Collector, Mandi Bahauddin (defendant No.1), Tehsildar, Phalia (defendant No.2), Patwari Halqa Chaito, Tehsil Phalia (defendant No.3), his wife Fatima Bibi (defendant No.4) and subsequent vendee, namely, Muhammad Anwar (defendant No.5). Prayer in the suit was that a declaration be granted that gift mutation No.595 dated 15th June, 1995 and sale mutation No.840 dated 4th May, 2005 were against law and facts, result of collusion and thus, ineffective upon his proprietary rights.

3. The allegations made in the plaint were denied by the wife of the plaintiff, Fatima Bibi (defendant No.4) and the subsequent vendee, Muhammad Anwar (defendant No.5) through a joint contesting written statement with a plea that the gift was rightly sanctioned in the revenue record as the plaintiff voluntarily fulfilling the conditions of the gift in presence of the witnesses handed over the possession of the land to his wife, who still had it. It was also maintained in the reply that the plaintiff was aware of the sale as it was made, with his consent, in favour of Muhammad Anwar and possession was delivered.

4. The pleadings of the parties call upon this Court to examine the validity of two transactions. The first transaction was dated 15th June, 1995 when the land stood transferred in the name of defendant No.4 by way of gift vide mutation No.595 whereas second was the transaction of sale, of the portion of the gifted land, made in favour of defendant No.5 through mutation No.840 dated 4th May, 2005. These two transactions were brought under discussion before the Courts below through issue Nos.1 & 2, which on examination of evidence were found to be valid. Since the plaintiff has sought revision of the concurrent findings, it is essential to first appraise the legality of gift transaction because upon the fate of it hinges the existence of other transaction of sale. So let’s see what was the plaintiff’s first objection to the gift. He alleged that gift mutation No.595 dated 15th June, 1995 was the outcome of the collusion of the defendants; and, that he was not aware of the gift at the time of affixing his thumb impression. Such type of allegation upon its prove acts as a catalyst bringing the beneficiary under burden to establish the validity of transaction. Since the allegation of collusion  4. The pleadings of the parties call upon this Court to examine the validity of two transactions. The first transaction was dated 15th June, 1995 when the land stood transferred in the name of defendant No.4 by way of gift vide mutation No.595 whereas second was the transaction of sale, of the portion of the gifted land, made in favour of defendant No.5 through mutation No.840 dated 4th May, 2005. These two transactions were brought under discussion before the Courts below through issue Nos.1 & 2, which on examination of evidence were found to be valid. Since the plaintiff has sought revision of the concurrent findings, it is essential to first appraise the legality of gift transaction because upon the fate of it hinges the existence of other transaction of sale. So let’s see what was the plaintiff’s first objection to the gift. He alleged that gift mutation No.595 dated 15th June, 1995 was the outcome of the collusion of the defendants; and, that he was not aware of the gift at the time of affixing his thumb impression. Such type of allegation upon its prove acts as a catalyst bringing the beneficiary under burden to establish the validity of transaction. Since the allegation of collusion 

5. There is another good reason to hold that the plaintiff was not entitled to the decree as prayed for in the plaint. The mutation proceedings were conducted in a public assembly and in that connection the plaintiff and his wife (defendant No.4) personally appeared before the revenue officer and in presence of the witnesses, namely, Muhammad Shafi, Lambardar (DW-1) and Shera (PW-2), acknowledged and confirmed the oral gift and delivery of possession. It was on this statement that the land then mutated in the name of Fatima Bibi (defendant No.4). Copy of mutation No.595 dated 15th June, 1995 was retained on record as Ex.P.1. A perusal of record indicates that this mutation was given effect to and incorporated in jamabandi of mouza Chaito for the year 1996-1997, 2000-01 and 2004-05, copies whereof were produced as Ex.P.3, Ex.P.4, and Ex.P.5 respectively. When entries of mutation get incorporated in  jamabandi (that is annual record) then it is presumed to be true until the contrary is proved or a new entry is lawfully substituted therefor1 . As against the aforesaid entries, mere verbal statements did not extend any help to the plaintiff for that the documentary evidence could not be rebutted by oral evidence2 . In this scenario, the plaintiff could not be heard saying that he was not aware of the gift at the time of making of thumb impression. I find that the plaintiff had been unsuccessful in rebutting the entries made in the jamabandi and thus, interference therewith was uncalled for. 

6. Before moving on to the next objection, I would pause here so as to examine the motive which according to the plaintiff led the defendants to collude with each other for obtaining the sanction of gift mutation. As stated in the plaint, wife of the plaintiff is very clever and cunning woman who took him to defendants No.2 and 3 with the impression that the documents for obtaining agriculture loan could be prepared but she in collusion with defendants No.2 & 3 got his thumb prints on the mutation of gift. When this averment is read in conjunction with the statement of the plaintiff which he made during the course of his cross-examination as PW-1, it transpires that obtaining a loan and making a gift are two incidents which took place on different dates and year. It is to be noted that cross-examination of the plaintiff was recorded on 13th October, 2011. As regards the mutation of gift, the plaintiff upon being asked during crossexamination stated that it happened sixteen years ago. If these sixteen years are counted from the date of cross-examination, it 1 “Bhagwan Das v. Mangal Sain” (A.I.R. 1929 Lahore 93) “Abdul Ahad and others v. Roshan Din and 36 others” (PLD 1979 SC 890) “Ahmad Ali and others v. Muhammad Iqbal and another” (1986 SCMR 244) “Divisional Evacuee Trust Property Committee, Hyderabad v. Deputy Commissioner and another” (1989 SCMR 1610) “The Evacuee Trust Property Board and others v. Haji Ghulam Rasul Khokhar and others” (1990 SCMR 725) “Syed Muhammad Haider Zaidi and others v. Abdul Hafeez and others” (1991 SCMR 1699) “Mazloom Hussain v. Abid Hussain and 4 others” (PLD 2008 SC 571) 2 “Mt. Wallan v. Fazla and others” (A.I.R. 1939 PC 114) almost corresponds with the date of gift mutation i.e. 15th June, 1995. So, it is clear that transaction of gift took place in the year 1995. Now I need to know the year when the plaintiff obtained a loan. The plaintiff said in his cross-examination that he had obtained a loan and used it to build a house with three large rooms, a drawing-room, a boundary-wall and a door; that they used to live in the same house before; that there was a single room when he married Fatima; and, that it has been six years since the house was built. This statement conclusively suggests that the incident of loan happened in the year 2005 whereas the gift was made in the year 1995 and thus, the conclusion is that the plaintiff had been failed to prove the alleged motive of collusion. It means the facts constituting the foundation of the cause to challenge the mutation of gift were false. 

7. I will now turn to the second objection raised by the plaintiff to the gift. He stated that the three essential requisites for a valid gift, that is, the offer of the gift; acceptance thereof; and, delivery of possession in pursuance thereunder were not complied with, therefore, the gift was not complete. This objection does not hold water. While examining this objection, it should be kept in mind that it was an inter-spousal gift. I have said this above and now I repeat it here to answer this objection that at the time of attestation of Mutation No.595 dated 15th June, 1995 the husband (the plaintiff) and wife (the defendant No.4) had confirmed and acknowledged the fulfillment of the required conditions of the gift in front of the witnesses and before the revenue officer. The said mutation was incorporated in the subsequent Khasra Gardawaris (Ex.D.4 & Ex.D.5) as well as the record of rights (Ex.P.3, Ex.P.4, Ex.P.5) showing the transfer of possession of the land in favour of defendant No.4 pursuant to the gift; presumption of correctness, though rebuttable, is attached to them. In the present case the plaintiff had not been able to rebut the said presumption and to satisfy the Court  that the elements of offer and acceptance of gift or delivery of possession of land to establish a valid gift were missing. It would, therefore, be taken that mutation was effected by the plaintiff himself. It is now well settled that once mutation of names has been proved, the natural presumption arising from the relation of husband and wife existing between them is that the husband’s subsequent acts with reference to the property were done on his wife’s behalf and not on his own1 . This principle indicates that the theory of constructive possession is very well applicable to gifts between husband and wife2 . Applying this principle to the facts of the present case the wife (defendant No.4) would be deemed to be in possession of the land under the gift3 .  1 “Amina Bibi v. Khatija Bibi” (1864) I Bom. H. C. 157 “Ma Mi v. Kallander Ammal” (AIR 1927 PC 22) “Emnabai v. Hajirabai” (1889) 13 Bom 352 “Abdul Rehman Nachiyal v. Muhammad Nurdin Maracayer” (23 IC 547) “Bee Jan Bee v. Fatima Beebee” (8 IC 431) 2 Neaz Begum v. Manzur Ahmad (11 IC 534) 3 “Abdul Mateen and others v. Mst. Mustakhia” (2006 SCMR 50)

8. In the end, the plaintiff in his plaint has also stated that even if the gift proves to be valid in favour of his wife, he revokes it. This is highly abominable. There is a tradition in the Sahih alMuslim that the Holy Prophet (Sallallahu Alayhi Wa Sallam) said, “the person who revokes his gift, is like the dog that licks up what it disgorges”4 . The desire to revoke the gift indicates that the plaintiff’s intention is only to hurt his wife who is now stated to be a patient of multiple diseases. Instead of taking care of her, he, undeterred by his failure in Courts below, is dragging her in the litigation up to the level of this Court. This is the same wife who gave birth to the plaintiff’s children and looked after his house. The plaintiff has not denied her love, her affection, her care and her services. Thus, it would not be inapt to say that the plaintiff had made the gift to his wife so as to make more congeniality. In such like events, the law  does not give the plaintiff (husband) any right to revoke the gift1 . The reason of this prohibition may be explained by referring Hamilton’s Hedaya by Grady wherein at page 486 it has been stated that if a husband makes a gift of anything to his wife or a wife to her husband, it cannot be retracted because the object of the gift is an improvement of affection (in the same manner as in the case of presents to relations); and as the object is obtained, the gift cannot be retracted. Explaining it further, in the foot-note, Hedaya says that the increase of affection excited in the wife by the gift is supposed, by the law, to be a return which she pays for it, and which consequently deprives the donor of the power of retraction. 4 Al-Muslim: Shaih, Cairo, Kitab al-Hibat, P.64. 1 “Abdul Majid Khan and another v. Mst. Anwar Begum” (PLD 1989 SC 362)

9. It is now fully established that defendant No.4, Fatima Bibi, was the owner in possession of the suit land on the basis of gift. Since she was the lawful owner, she had the right to sell her land to whomever she wanted. Defendant No.4 while appearing before the Trial Court as her own witness as DW.2 said in her statement that she had sold 4 Kanals of gifted land to defendant No.5, Muhammad Anwar, with the consent of the plaintiff to meet the marriage expenses of her two daughters, who were from her first husband. This admission was sufficient to hold that sale made in favour of defendant No.5 vide mutation No.840 dated 4th May, 2005 (Ex.P.6) was valid

10. Upshot of the above discourse leaves no room for doubt that the suit brought by the plaintiff was based on mala fide and false allegations and its sole purpose was to rob defendant No.4 of her property so that she would spend the rest of her life in contempt. The plaintiff has been unable to identify any infirmity in the findings returned by the Courts below and thus, interference therewith is not warranted.

11. Before parting with this judgment, I must say that man and woman are of equal rank, but they are not identical. They are a peerless pair, being supplementary to one another, each helps the other, so that without the one the existence of the other cannot be conceived, and, therefore, it follows as a necessary corollary from these facts, that anything that will impair the basic right of a woman to be treated with decency and proper dignity will not only involve the infringement of Article 9 of the Constitution which guarantees that no person shall be deprived of life or liberty save in accordance with law but also ruin our social fabric which is interwoven with the family bond. Prophet Muhammad (Peace Be Upon Him) said: “the best of you is the best to his family and I am the best among you to my family. The most perfect believers are the best in conduct and best of you are those who are best to their wives” (Ibn-Hanbal No.7396). In the case at hands the plaintiff through his callousness, carelessness and negligence has exhibited a conduct unbecoming of a Muslim. By falsely accusing his wife, the plaintiff has not only tarnished her chastity but also made a despicable attempt to seize her property. This Court would loathe approving this conduct and would burden the plaintiff with a heavy costs which will to some extent serve as balm to relieve the defendant No.4’s pain of her wounds inflicted by the plaintiff.

12. In the result, the revision sought for through this application is declined with costs of Rs.100,000/-. 


(SHAHID WAHEED) JUDGE   

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