The Supreme Court examined the effect of Section 14(1) of the Hindu Succession Act, 1956, on a Hindu widow's limited ownership of agricultural land. The dispute concerned agricultural land in Bhawana Village, Delhi, which had originally been held by Khajano as a Hindu widow with a limited estate. The question was whether her limited interest had subsequently become absolute ownership under the Hindu Succession Act, allowing the property to devolve upon her own legal heirs. The Court interpreted Section 51(2) of the Delhi Land Reforms Act, 1954, and clarified that the relevant personal law must be considered as it existed on the date of the woman's death rather than being frozen as on the commencement of the 1954 Act. It held that Section 14(1) of the Hindu Succession Act converted Khajano's limited interest into absolute ownership. Consequently, the property devolved upon her heirs under the applicable succession provisions. The judgment reinforces women's property rights, Section 14 of the Hindu Succession Act and the principles of statutory interpretation.