The Supreme Court has held that once a government employee acquires a “family”, any prior General Provident Fund (GPF) nomination made in favour of a person outside the family becomes invalid, even if formal modification of the nomination was not carried out. Consequently, upon death, the GPF amount must be distributed among eligible family members in accordance with Rule 33 of the General Provident Fund (Central Service) Rules, 1960.
Setting aside the Bombay High Court’s view that the original nomination in favour of the mother continued to subsist, the Bench observed that the nomination form itself stipulated invalidation upon the employee acquiring a family through marriage. Therefore, the mother could not claim exclusive entitlement to the GPF amount merely on the basis of the outdated nomination.
The Court reiterated the settled principle that nomination does not confer beneficial ownership; it only identifies the person authorised to receive the amount, which must ultimately devolve under the applicable law of succession. Reliance was placed on earlier rulings including Sarbati Devi v. Usha Devi and Shakti Yezdani v. Jayanand Salgaonkar.
Upholding the Central Administrative Tribunal’s order, the Court directed equal distribution of the GPF between the deceased employee’s widow and mother. The widow having already received her 50% share, the remaining amount deposited with the High Court was ordered to be released to the mother.
Accordingly, the appeal was allowed and the High Court judgment was set aside
Smt. Bolla Malathi v. B. Suguna & Ors.
Citation: 2025 INSC 1391