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A Project on

VESTED INTEREST & CONTINGENT INTEREST: AN


ILLUSTRATIVE STUDY
Submitted to Mr. Shyamtanu pal
(Faculty of Transfer of Property)

Submitted by vivek kumar sai


Roll No. 146
Semester-IV
B.A. LL.B. (Hons.)

HIDAYATULLAH NATIONAL LAW


UNIVERSITY, RAIPUR (C.G.)

Table of Contents

Acknowledgements................................................................................................................3
Introduction............................................................................................................................4
Objective................................................................................................................................5
Research methodology...........................................................................................................5

Vested interest & Contingent interest under TPA...............................................6


Analysis of Vested and Contingent interest........................................................7

Difference between vested and contingent interest............................................16


Conclusion............................................................................................................17
Reference.............................................................................................................................18

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Acknowledgements
In preparing this project I took help from many people but it is very difficult to list
every name. First and foremost I would like to express my heartfelt gratitude to Mr.
Shyamtanu pal for putting his trust on me, by giving me such a topic and for him unstinted
support by helping me in all possible ways. I hope that I have not disappointed him and have
done justice to it.
I also want to express my gratitude to the staff and administration of HNLU and to the
library and IT Lab that was a source of great help for the completion of this project. I would
also like to thank all my seniors who always guided me without their help, it would have been
impossible for me to complete this project.
Vivek kumar sai
Roll no.146

IntroductionPage | 3

By its very existence, society mandates interaction, exchange or transfer. A property, movable
or immovable, is transferred from one person to another under various different situations and
circumstances and for different values. The transfer may be a gift, an inheritance or an asset
acquired by paying full value.
When a movable property is transferred inter-vivos (between two living persons), Sales of
Goods Act, 1930 comes into play. When an immovable property is transferred from living
person to living person(s), the Transfer of Property Act, 1882 comes into play.
In India, the personal laws governed the transfer of property assisted by orders of Courts
under Civil Procedure Code before the Transfer of Property Act, 1882 came into existence.
Transfer of movable goods was regulated to an extent by the Indian Contract Act, 1872.
Interestingly, nowhere does the Act define What is a transfer of property. But it does define
transfer as a standalone in Section 5. The word transfer in the Act has been to mean either
transfer of all rights and interests in the property or transfer of one or more of subordinate
rights in the property. The word property is used in any of the following senses- tangible
material things, e.g., land and houses; rights which are exercised over material things, e.g.,
right to enjoy and possess, right to sell or to make a gift of things; rights which are not
exercised over any material, e.g., a right to repayment of a debt. The expression transfer of
property may imply any one of the following things: transfer of things, e.g., sale of a house;
transfer of one or more of the rights in a thing e.g., mortgage of a house; transfer of debt.
Section 19 and Section 21 of the Transfer of Property Act, 1882 elucidate the expressions
vested interest and contingent interest in the context of transfer of property. A reading of
the plain language of the sections makes it clear that an interest can be said to be a vested
interest where there is immediate right of present enjoyment or a present right for future
enjoyment. An interest can be said to be contingent if the right of enjoyment is made
dependent upon some event which may or may not happen. On the happening of the event, a
contingent interest becomes a vested interest.

Objective
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To study the Section 19 and 21 under Transfer of Property Act.


To analysis Section 19 and 21 of TPA with the help of case laws and illustrations
To study the difference between vested interest and contingent interest.

Research Methodology
This research is descriptive and analytical in nature. Secondary sources have been used to
gather information and data about topic. Other references as guided by Faculty have been
primarily helpful in giving this project a firm structure. Help has also been taken from web
sites, reference books etc.

Vested interest and Contingent interest under Transfer of


Property Act, 1882
SECTION 19- Vested interest: Page | 5

Where, on a transfer of property, an interest therein is created in favour of a person without


specifying the time when it is to take effect, or in terms specifying that it is to take effect
forthwith or on the happening of an event which must happen, such interest is vested, unless a
contrary intention appears from the terms of the transfer.
A vested interest is not defeated by the death of the transferee before he obtains possession.
Explanation: An intention that an interest shall not be vested is not to be inferred merely from
a provision whereby the enjoyment thereof is postponed, or whereby a prior interest in the
same property is given or reserved to some other person, or whereby income arising from the
property is directed to be accumulated until the time of enjoyment arrives, or from a
provision that if a particular event shall happen the interest shall pass to another person.
SECTION 21- Contingent interest
Where, on a transfer of property, an interest therein is created in favour of a person to take
effect only on the happening of a specified uncertain event, or if a specified uncertain event
shall not happen, such person thereby acquires a contingent interest in the property. Such
interest becomes a vested interest, in the former case, on the happening of the event, in the
latter, when the happening of the event becomes impossible.
Exception: Where, under a transfer of property, a person becomes entitled to an interest
therein upon attaining a particular age, and the transferor also gives to him absolutely the
income to arise from such interest before he reaches that age, or directs the income or so
much thereof as may be necessary to be applied for his benefit, such interest is not
contingent.

Analysis of Section 19 and 21 under Transfer of Property Act,


1882
SECTION 19Page | 6

A transfer of property involves transfer of interests. From the point of view of the quantum
(quantity) the interest may be either absolute or partial. From the point of view of the time of
accruing (i.e. when transferee gets the interest) the interest may either be vested or
contingent. Where the interest transferred is vested, the transferee gets that interest
immediately. Where the interest is contingent, the transferee gets the interest only upon the
happening of an uncertain future event specified in the transfer. In a transfer of property if the
interest transferred is contingent the title of the transferee is not complete unless the specified
event happens. An interest created on a transfer of property in favour of a person is said to be
vested wherei.
No time is a specified for it to take effect, or
ii.
It is expressed to take effect forthwith, or
iii.
It is to take effect on the happening of an event which must happen.
There are three stages which may be marked in regard to interests. An interest may be vested
in possession, it may be vested and be yet not in possession; or may be contingent. It may be
vested in possession as where a transfer is made in general terms without specifying the time
when it is to take effect, or is expressed to take effect forthwith, or if it may be an interest
vested even though it does not give a right to immediate possession in any one of the
situations mentioned in the Explanation to the section. There is a presumption that on a
transfer of property, the transferor intends to confer a vested interest in the transferee unless a
contrary intention appears from the terms of the transfer. Normally, when a property is
transferred, the transferor simply affects it according to procedure prescribed for the same. He
may not mention the date as to when the interest shall pass on to transferee. In such cases, the
intention of transferor is that the transferee shall get the interest forthwith. Such intention is
presumed by law if the transferor does not specify as to when the interest shall accrue to
transferee. On the other hand, in order to be more specific, the transferor may express his
intention that interest shall accrue to transferee with immediate effect. In both cases the
interest transferred is a vested interest. Where the transferor provides that the transfer shall
take effect upon the happening of an event of must nature which is bound to occur in future,
the interest of the transferee is vested interest. For example, any future date or year, any
particular age of the transferee or, death of any person is future events of must nature.
Where transfer of property is to take effect upon the death of a person, the interest accrues to
the transferee immediately. The reason behind this is that death is as certain as birth,
therefore, where it is provided that the property is transferred upon the death of a person the
interest of the transferee is vested because although death is a future event, it is certain. There
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is no certainty as to when a person dies or whether or not a person survives up to a particular


age or year but, his death, as such, is certain. Similarly, any future date or future year is also
an event of must nature because they are bound to occur. Thus, in 1993, if a person makes
gift for his property to take effect in 1995, the done gets a vested interest because after 1993
the year 1995 is bound to come.
Vested interest is nonetheless a vested interest even where the transfer deed contains a
provision whereby:
a. The enjoyment thereof is postponed, or
b. A prior interest in the same property is given to some other person, or
c. The income arising from the property is directed to be accumulated until the time of
enjoyment arrives, or
d. On the happening of a particular event, the interest passes to another person.

Illustrations:a. A makes a gift of his house to B. He simply executes the gift deed but does not specify any
date on which the ownership is to be transferred. The interest of B is a vested interest.
b. A makes a gift to B of Rs. 100 to be paid to him on the death of C. B gets a vested interest
in the sum transferred, and if he dies before C, his representatives are entitled to the sum of
money so transferred. The interest of B takes effect on the happening of an event that is
certain and so it is vested). The event, namely Cs death is certain and therefore Bs interest
is vested.
c. A transfers the whole of his property to B upon trust to pay certain debts out of the income,
and then to make over the property to C. C has a vested interest in the property. The payment
of debts postpones enjoyment, but the interest vests immediately.
d. A property is transferred to A, B and C in equal shares to be paid to them on their attaining
the age of 18 with a proviso that, if all of them die under the age of 18, the property shall go
to D. A, B and C acquire a vested interest even though it is liable to be divested on the
happening of the event specified.

ExplanationExplanation to Section 19 makes it clear that vested interest is not affected by the fact that
right of enjoyment has been postponed. The vested interest remains unaffected also when the
title is to pass on to another person on the happening of a particular event in future. The
explanation provides that in the following situations, although it may appear that the
transferee has no vested interest, nevertheless the interest is vested:
1. Postponement of enjoyment- Postponement of the enjoyment of property does not mean
that the interest of the transferee is not vested. In a transfer of property, the primary thing is
the transfer of interest of title. Possession of the property is secondary. Therefore, from the
fact that right of enjoyment has been postponed, it cannot be inferred that vested interest has
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not been given. Possession or enjoyment of property, being secondary, it may be postponed
for some time. Where A transfers his properties to B to be given to B on Bs attaining the age
of majority, the interest of B is vested although he is to get the possession and enjoyment of
property only on attaining the age of majority. As soon as he attains the age of majority, he is
to get possession and enjoyment. However, if B dies before attaining the age of majority, the
possession and enjoyment of the property shall go to Bs representatives or legal heirs
together with title which B already had and died having it. The postponement of enjoyment of
property, therefore, does not prevent the vesting of interest in favour of the transferee. On the
contrary, in the case of Sewdayal v. Official Trustee, a condition which postpones the
enjoyment (beyond the age of majority) is itself void after the transferee has attained
majority.1 The enjoyment of the property may be postponed till any future date or a future
event which is of must nature and is bound to happen. In Lachman v. Baldeo2, A made a
gift of his property to B and directed that B was to take possession of a portion of the
property only after the death of A and As wife. It was held that the interest of B was a vested
interest.
2. Prior interest- Where a prior interest is created in the same transfer, there is postponement of
the property. The vesting of interest is not postponed. Where A transfers property to B for life
and then to C the interest of C is a vested interest. Here, C has a vested interest immediately
when the transfer was made but his right of enjoyment is postponed till the life of B. Bs
death is a future event of must nature. Accordingly, although a prior life interest intervenes
yet, C gets immediate vested interest.
3. Direction for accumulation of income- Direction for accumulation of income is valid
provided it is within the period prescribed in Section 17 of the Act. Where a property is
transferred with such direction, the interest of the transferee is nevertheless vested. In such
cases too it is only the right of enjoyment which is postponed; vesting is not postponed.
However, when in a transfer of property, if the direction is that right of enjoyment is to
terminate only on the death of the transferor, the transfer does not create a vested interest. In
Kokilambal v. N. Raman Kokilambal,3 there is a deed of family settlement in which the
settlor created a limited interest (right to receive the income from rents). The property of the
1 AIR 1931 Cal 651
2 (1919) 21 O.C.312: 48 I.C. 396
3 AIR 2005 SC 2468
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settler was to vest in the settlee (brothers of the settlor) only on the death of the settler. The
Supreme Court held that the family settlement did not create a vested interest in favour of the
settlee and settlee could not be absolute owner during the life of the settler. Therefore, the
settlee could not succeed the property on the settlors death.
4. Conditional limitation- A condition that upon the happening of a particular event the interest
vested in a person shall pass on to another person is called a conditional limitation under
English law. In India, this provision is contained in Section 28 of the Transfer of Property
Act. In a transfer of property, a conditional limitation does not prevent the vesting of the
interest. Rather, it is implied that the interest which had already been vested may be divested
and may vest somewhere else. For example, A transfers his house to B with a condition that if
B does not take possession of this house within six months from the date of the transfer, the
house shall belong to C. The interest of B is a vested interest although it is likely to be
divested in case B does not fulfil the condition within six months.
Nature of Vested Interest
a. Present Fixed Right: - Vested interest is a present fixed right to property. In a transfer of
property where a vested interest is created in favour of the transferee, the transferee gets a
present fixed right to property. On the other hand, where the interest created is contingent the
transferee gets merely a future possible right in property. Contingent interest may or may not
become vested in future depending upon the happening or not happening of future event. But
where the interest is vested, it accrues to the transferee immediately. In a vested interest the
title of the transferee is complete as soon as the transfer is completed. An interest may be
vested in possession or vested not in possession. Where the interest is vested not in
possession, there is a present indefeasible right to future possession in which case the
transferee gets the possession or enjoyment not immediately but in future. Thus, a vested
interest confers a present right to property even though the right of enjoyment is postponed or
b.

suspended.
Transferable and heritable interest: - Vested interest is transferable and heritable. Being a
present fixed right and also since the title of the transferee is complete, a vested interest is
divisible and transferable interest.4 A vested interest is such a present fixed right of the
transferee that it is regarded as his property. It is transferable interest within the meaning of

4 Elokassee Dasee v. Darponarain, 5Cal. 59


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Section 6 of the Act even though the transferee has no possession or right of enjoyment.
Further, a vested interest can also be attached and brought to sale in execution of a decree. 5

Test of heritability of the interest whether the interest is contingent or


vestedIn a transfer of property, the interest of transferee is heritable, the interest is undoubtedly
vested. But, where it is found that interest is not heritable, the interest is a contingent interest.
Rajes Roy v. Shanti Devi6
Fact of case-In this case, Ramani Kanta Roy executed a trust- deed. The deed provided that
the trust existed for the payment of debts incurred by settlor Ramani Kanta Roy. After
termination of the trust, the property was to belong absolutely to settlors two sons. The trust
was to terminate
1. Upon the death of the settler and
2. Full payment of all the debts.
The deed provided that if either of the sons died before the payment of all debts, the heirs of
the sons were entitled to get the shares of the sons. The settler died before total discharge of
debts.
Question raised before the Court was: whether the interest of the two sons was vested
interest?
The Supreme Court held that under the trust deed the interest conferred upon the two sons
was a vested interest. The Supreme Court observed that the scheme of the trust- deed was that
the enjoyment was to be restricted until the debts are discharged. What was postponed was
not the vesting of property but the income thereof burdened with certain monthly payments
and with the obligation to discharge debts there from. The Court further observed that since it
was provided in the deed that if either of the two sons died before full payment of debts, his
heirs were entitled to get their shares the interest of the sons was a heritable interest. And,
since the interest conferred upon the two sons was made heritable, their interest was vested.
Time of vesting interest- On a transfer of property, ordinarily the interest created in favour
of the transferee vests immediately. Section 19 provides that the interest created is vested
when no time of its vesting is specified or it is to vest immediately or where though
enjoyment is postponed but it is intended to vest with immediate effect. However, the
transferor may specify particular time of vesting of the interest.
5 Lal Bahadur Singh v. Rajendra Narain Singh, (1934) Oudh 454
6 A.I.R. 1957 S.C. 255
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Where the transferor

specifies any particular time of vesting this would constitute his contrary intention as
contemplated under Section 19 by the words unless a contrary intention appears. The
intention of the transferor is to be gathered from the words used by him in the deed. In
construing whether certain words mean to convey vested interest or contingent interest, the
words used must be interpreted in their plain ordinary meaning. According to the Supreme
Court, the question is really one of intention to be gathered from a comprehensive view of
all the terms of a document and also that a Court has to approach the task of construction, in
such cases, with a bias in favour of a vested interest unless the contrary is definite and clear.7
However, where words used are to be paid or payable or to be given to the transferee at a
certain age, the interest is a vested interest and only enjoyment is postponed. But, where the
words used are when or if or provided the transferee attains a certain age, the interest is a
contingent interest.
Illustrations of Vested interesta. A transfers his property to B and C in equal shares to be paid (or to be given) to them on their
attaining age of 18years and if B and C die under the age of 18years, the property shall go to
D. B and C have vested interest even though their interests are likely to be divested upon the
happening of an uncertain future event.
b. In trust deed, the settler directed that after the death of the tenant for life and after making
provision out of the trust fund for the payment of a monthly allowance to the widow for life,
the trustee was to hold the rest of the trust- property for the use and benefit of his sons to be
made over to them on their attaining the age of 21 years. It was held that the language of the
trust- deed suggested that vested interest was conferred to the sons.8
c. A husband made settlement on his wife for her life and thereafter the sons born to them were
to take the property absolutely. The sons acquired vested remainder (interest).9

Section 21 of Transfer of Property Act


Contingent Interest- Contingency means uncertain future event. In a transfer of property
with the vesting of interest depends on any contingency i.e. uncertain future event, the
interest is contingent. In a transfer of property where the vesting of estate is dependent upon

7 Rajes Kanta Roy v. Shanti Devi, AIR 1957 S.C. 255


8 Sewdayal v. Official Trustee of Bengal, AIR 1931 Cal 651
9 Adimoloa v. Pavadai Padayachi, (1958) 2 Mad. L.J.57.
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an event that may or may not happen the interest is contingent. 10 A contingent interest is an
interest which is created to take effect only whena) Some specified uncertain future event happens or
b) Specified uncertain event does not happen.
Where the creation of interest is made dependent on the happening or not happening of any
uncertain future event, it does not vest in the transferee immediately. It vests only upon the
happening or not happening, as the case may be, of that event. For example, where A makes a
gift to B provided X survives (i.e. lives up to) the age of 20 years, the interest of B is
contingent. Similarly, where A makes a gift to B provided X does not survive (i.e. dies
before) the age of 20 years, here too the interest of B is contingent. In both the examples, the
vesting of interest in favour of B depends on an event which is uncertain. In the first, the
vesting would take effect on the happening (i.e. survival) of that event whereas in the second,
it depends on not happening of that event. The happening or not happening of a happening
of an uncertain future event is the condition precedent for vesting. Until the condition
precedent is fulfilled, the transfer does not take place and the interest of the transferee
remains a contingent interest. In contingent interest becomes vested only upon the fulfilment
of the condition precedent i.e. upon the happening of the contingency.
Contingency or specified uncertain event may be of two kinds.
1. Where the happening or not happening of the event depends upon the will and desire of the
parties e.g. marriage, payment of a sum of money or execution of a deed etc. For example, A
makes a gift to B provided C marries within one year of the transfer. The interest of B until C
marries is a contingent interest.
2. Where specified event does not depend on the will or desire of the parties e.g. death of a
person on or before a certain age. Thus, where A makes a transfer of his property to B
provided C dies at the age of 40 years, the interest of B is contingent.
Death of a person is a certain event therefore where property is transferred with a condition
precedent of the death of any person; the interest of the transferee is vested. But when and at
what age does a person die, is an uncertain future event. Therefore, where a transfer is made
with words: when, provided or, if a person dies at a given age, or in a specified year or, dies
before or after the death of another person, the interest of the transferee is contingent.
Exception- Exception to Scetion21 provides that where a transferee is to get the interest at a
particular age but is entitled to get absolutely the income of that interest before attaining that
age, the interest given to him is a vested interest. Where an interest is created in favour of a
person on attaining a particular age, his interest is contingent. But, if the transferor gives to
the transferee also an absolute right in the income arising out of that interest (property) or
10 Chinna Reddy v. Pujari Keshanna, A.I.R. 1954 Hyd. 185.
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directs that so much of such income as is necessary for his benefit be applied with immediate
effect, the interest of the transferee is a vested interest.
Nature of Contingent interest
a. Future possible interest- Contingent interest is a future possible interest. In a transfer of
property where the transferees interest is contingent, he has only a future possible right in
respect of property transferred to him. It is neither a present right nor a certain right. Since the
happening or not happening of the event, is uncertain, the interest dependent on it is also
uncertain. In a contingent interest, the right of enjoyment is also dependent on some event or
condition which may or may not happen or be performed.11
b. Not heritable- A contingent interest is not a heritable interest. Where a person having
contingent interest dies (i.e. dies before vesting) his legal heirs do not get anything, not even
the contingent interest. After the death of person his legal heirs are entitled to inherit only
those properties in which he had a vested interest at the time of his death. In Rajes Kanta
Roy v. Smt. Shanti Devi12, the Sumpreme Court observed thus:
In the case a contingent interest, one of the features is that if a person dies before the
contingency disappears and before the vesting occurs, the heirs of such person do not get
benefit of the gift (transfer).
c. Transferable interest- Contingent interest is a transferable interest. However, since a
contingent interest is itself an uncertain interest in the property and transferors own title is
not perfect, the transferee too gets an imperfect title. If the contingent interest subsequently
becomes vested, the transferees interest also becomes vested. But, if the contingency could
not happen the transferee does not get any title in the property.
Sale of inchoate contingent interest prior to vesting- In case of Bay Berry Apartments P.
Ltd v. Shobha13, a father and his son purported to transfer certain property as owners when in
fact the father had only life interest in it and the son has an inchoate contingent interest which
had not become vested, i.e. an undivided share in the family property which was to vest on
his fathers death. The sale was held to be in efficacious till partitioning of the property.
Illustrations of Contingent Interest
1. A makes a gift of his property to B when he attains the age of 18years or, marries under
that age with the consent of C with a condition that if B neither attains that age nor

11 Shashi Kantha v. Promode Chandra, (1932) Cal.600


12 A.I.R. 1957 S.C. 255.
13 AIR 2007 SC 226
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marries with the consent of C the property shall go to D. B and D both take a contingent
interest in the property.
2. A transfers his farm of Sultanpur Khurd to B if B shall convey his own farm of Sultanpur
Buzurg to C. Interest of B in the farm Sultanpur Khurd is contingent. It may become
vested if B conveys his farm Sultanpur Buzurg to C.
3. A bequeaths to B Rs. 500/- when B shall attain the age of 18 years and directs that a
certain sum, out of another fund shall be applied for Bs benefit until he reaches that age,
the legacy in favour of B would be vested under the exception to Section 21.

Differences between Vested Interest and Contingent Interest


1.

Meaning: An estate is said to be vested in ownership when it gives a present right to


the immediate possession and ownership of the property. While an estate which gives a
present right to the further possession of property is said to be vested interest. Whereas
contingent interest is that which awaits or depends on the happening or non-happening of
certain or uncertain event.

2.

Nature of title-In a vested interest, the transferees is complete and already perfect.
In a contingent interest, the title is not yet perfect. But it may become perfect. If happen

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certain condition annexed to the deed. The transferee owns the right absolutely, whereas in
contingent interest the transferee owns it merely conditionally.
3.

Heritability-The vested interest is heritable. But the contingent interest is not


heritable.

4.

A vested interest is not defeated by the death of the transferee before he obtains
possession. The property passes to his heirs. But a contingent interest is defeated by the
death of the transferee before he obtains possession.

5.

When an interest is vested, the transfer is complete and the transferee acquires all
rights of a full owner. Whereas when an interest is contingent, the transfer is not complete.

6.

Illustration of Vested interest: X promised A, B and C to give Rs. 1, 00,000/- each


of them if their marriages occur before his death. B married before the death of X. on such
marriage, the gift become a vested one in case of B.
Illustration of Contingent Interest: If A and C did not marry before Xs death, and not the
contingency contemplated did not, therefore, happen. Hence A and C could not take Rs. 1,
00,000/-.

7.

Fulfilment of condition in Vested interest: It does not depend upon the fulfilment of
any condition. It creates an immediate right through the enjoyment may be postponed to a
future date.
Fulfilment of condition in Contingent interest: It is solely depended upon the fulfilment of
the condition so that if the condition is not fulfilled, the property would not be passed.

8.

The ownership is absolute. Whereas in contingent, the ownership is merely


conditional.

9.

The investiture fact from which a person derives the right is complete. The investiture
fact from which a person derives the right is incomplete.

ConclusionSection 19 and Section 21 of the Transfer of Property Act, 1882 elucidate the expressions
vested interest and contingent interest in the context of transfer of property. A reading of
the plain language of the sections makes it clear that an interest created on a transfer of
property in favour of a person is said to be vested where-no time is a specified for it to take

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effect, or it is expressed to take effect forthwith, or it is to take effect on the happening of an


event which must happen.
An interest on a transfer of property in favour of a person is said to be contingent when it is
expressed to take effect: on the happening of a specified uncertain event; or if a specified
uncertain event shall not happen. Such interest becomes a vested interest, in the former case,
on the happening of the event, in the latter, when happening of the event becomes impossible.

REFERENCES

DOMESTIC STATUTES
TRANSFER OF PROPERTY ACT 1882

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CASES
Sewdayal v. Official Trustee, AIR 1931 Cal 651
Lachman v. Baldeo ,(1919) 21 O.C.312: 48 I.C. 396
Kokilambal v. N. Raman Kokilambal, AIR 2005 SC 2468
Elokassee Dasee v. Darponarain, 5Cal. 59
Lal Bahadur Singh v. Rajendra Narain Singh, (1934) Oudh 454
Rajes Roy v. Shanti Devi, AIR 1957 SC 255
Adimoloa v. Pavadai Padayachi, (1958) 2 Mad. L.J.57.
Chinna Reddy v. Pujari Keshanna, A.I.R. 1954 Hyd. 185
Shashi Kantha v. Promode Chandra, (1932) Cal.600
Bay Berry Apartments P. Ltd v. Shobha, AIR 2007 SC 226
BOOKS
Dr. Shri Hari Singh Gour, commentary on Transfer of property Act (IV of 1882), 11th
ed., vol.1, 2008, Delhi Law House.
G.P. Tripathi, Transfer of property Act, 1882, 17th ed. 2011, Central Law Publication,
Allahabad.
Dr. Saxena. Ponnam Pradan. Property Law. Lexis Nexis Butterworths Wadhwa
Nagpur. 1st Edition. Third Reprint. 2010. New Delhi
DF Mulla. The Transfer of Property Act, 1882. Lexis Nexis Butterworths Wadhwa
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