The Supreme Court has ruled that when a government employee nominates a parent for General Provident Fund (GPF) benefits, but the nomination form states that it will become invalid once the employee acquires a family through marriage, the nomination automatically loses validity after marriage even without formal cancellation. In such cases, the GPF amount must be shared equally among eligible family members.
A Bench of Justice Sanjay Karol and Justice Nongmeikapam Kotiswar Singh delivered the decision while allowing an appeal filed by Smt. Bolla Malathi, widow of deceased Defence Accounts Department employee Bolla Mohan. The Bombay High Court had previously awarded the entire GPF amount to the employee’s mother, but the Supreme Court reversed that ruling.
The dispute centered on GPF benefits after the employee’s death in July 2021. He had nominated his mother when he joined service in 2000. After marrying in 2003, he changed nominations in favor of his wife for CGEIS and DCRG benefits but did not alter the GPF nomination. The wife later claimed the GPF share, but authorities rejected her request because the mother remained the nominee on record.
The Central Administrative Tribunal held that under Rule 33 of the General Provident Fund (Central Services) Rules, 1960, and the wording of the original nomination form, the earlier nomination became invalid upon marriage. Since no valid nomination existed at the time of death, the GPF amount had to be divided equally between family members. The Tribunal therefore granted 50 percent each to the wife and mother.
The Supreme Court affirmed this interpretation and observed that although the Rules do not expressly provide for automatic cancellation, the conditions in the nomination form clearly stated that it would become invalid upon marriage. The Court also cited established precedent that nomination does not create a beneficial right but only identifies who receives the amount initially.
The judgment restored the CAT’s order and directed release of the remaining 50 percent due to the mother, which had been deposited with the Registrar of the Bombay High Court.
Case: Smt. Bolla Malathi v. B. Suguna & Ors., Civil Appeal No. 14604 of 2025
Order: Appeal allowed; equal sharing of GPF upheld
