Interplay between Land Reform Codes and Enlarged Personal Law Rights:

Land reform statutes (such as the Delhi Land Reforms Act, 1954) that refer to "personal law" to determine whether an estate is limited or absolute seamlessly absorb Section 14(1) of the HSA, 1956. When a female Bhumidhar's limited life estate matures into absolute ownership under Section 14(1) HSA during her lifetime, she holds the property absolutely at death. Devolution of such absolute holdings proceeds under statutory provisions governing absolute owners (e.g., Section 53 of the DLR Act) rather than reversionary provisions (Section 50). Restrictions on testamentary disposition (e.g., Section 48(2) DLR Act) apply strictly to limited holders and do not restrict female Bhumidhars who acquired absolute status. (Sultan Singh Vs. The Financial Commissioner | 2026 INSC 1107)