{"id":6236,"date":"1998-08-03T00:00:00","date_gmt":"1998-08-02T18:30:00","guid":{"rendered":"https:\/\/www.legalindia.com\/judgments\/trustees-of-sahebzadi-oalia-vs-the-controller-of-estate-duty-a-p-on-3-august-1998"},"modified":"2018-12-29T18:11:34","modified_gmt":"2018-12-29T12:41:34","slug":"trustees-of-sahebzadi-oalia-vs-the-controller-of-estate-duty-a-p-on-3-august-1998","status":"publish","type":"post","link":"https:\/\/www.legalindia.com\/judgments\/trustees-of-sahebzadi-oalia-vs-the-controller-of-estate-duty-a-p-on-3-august-1998","title":{"rendered":"Trustees Of Sahebzadi Oalia … vs The Controller Of Estate Duty, A.P on 3 August, 1998"},"content":{"rendered":"
Supreme Court of India<\/div>\n
Trustees Of Sahebzadi Oalia … vs The Controller Of Estate Duty, A.P on 3 August, 1998<\/div>\n
Author: M S Manohar.<\/div>\n
Bench: Sujata V. Manohar, M. Srinivasan<\/div>\n
           PETITIONER:\nTRUSTEES OF SAHEBZADI OALIA KULSUM TRUST\n\n\tVs.\n\nRESPONDENT:\nTHE CONTROLLER OF ESTATE DUTY, A.P.\n\nDATE OF JUDGMENT:\t03\/08\/1998\n\nBENCH:\nSUJATA V. MANOHAR, M. SRINIVASAN\n\n\n\n\nACT:\n\n\n\nHEADNOTE:\n\n\n\nJUDGMENT:\n<\/pre>\n
\t\t      J U D G M E N T
\nMrs. Sujata V. Manohar. J.\n<\/p>\n
     On 21st of March, 1953, the Nizam of Hyderabad, Sir Mir
\nOsman Ali  Khan, executed  a deed  of trust  under which  he
\nsettled certain\t jewellery and other properties on trust for
\nthe benefit  of Sahebzadi  Oalia Kulsum,  his grand daughter
\nfor life  and thereafter for her children and their children
\nfor life  etc. and  ultimately for the maintenance of a holy
\nshrine. On  the same  date, he also executed a deed of trust
\nin favour of his daughter-in-law, Sahebzadi Anwar Begum, the
\nwife of\t second Prince\tMuazzam Jah.  The terms\t of the\t two
\ntrust deeds are similar. For the sake of convenience, we are
\nreferring only\tto the\ttrust deed  executed  in  favour  of
\nSahebzadi Oalia Kulsum.\n<\/p>\n
     Under the\tdeed of trust, the settlor who was a Muslim,
\ncreated\t a   trust  in\trespect\t of  certain  jewellery\t and
\nornaments and  other properties for the benefit of his grand
\ndaughter oalia\tKulsum who  was given  a right\tto wear\t the
\njewellery after\t her marriage or on completing the age of 30
\nyears whichever\t was earlier.  She was\tallowed to  wear the
\njewellery and  ornaments during\t her life time and after her
\ndeath the  trustees were  directed to sell the ornaments and
\ninvest the  sale proceeds,  thus turning them into an income
\nyielding investment.  A further\t direction was\tgiven to the
\ntrustees to  pay the  income to the children of Oalia Kulsum
\nor  remoter   issue  of\t Prince\t Muazzam  Jah  Bahadur\tfrom
\ngeneration to generation in the ratio of two shares for male
\nand  one   share  female   heirs.  In  the  absence  of\t the
\ncontingencies mentioned above, the income was directed to be
\npaid to\t remoter issues\t of Prince  Muazzam Jah Bahadur from
\ngeneration to generation in the ratio of two shares for male
\nand one\t share for female. On the death of the last survivor
\nof the\tpersons entitled  to the net income of the fund, the
\nincome was  directed to\t be utilised  for the benefit of the
\nholy shrine  at Khum  in Iran.\tThus the  trust was  in\t the
\nnature of  wakf-alal-Aulad. In fact the recital in the trust
\ndeed is to the same effect:\n<\/p>\n
     “AND WHEREAS  out of  natural  love
\n     and  affection  which  the\t settlor
\n     bears   towards\this    relatives
\n     hereinafter   mentioned   and   for
\n     divers  other   good   causes   and
\n     considerations him thereunto moving
\n     he\t the   settlor\tis  desirous  of
\n     making a  settlement  and\twakf-ul-<\/p><\/blockquote>\n
     aulad  in\tthe  name  of  the  most
\n     merciful God in respect of the said
\n     articles specified\t in the\t   First
\n     Schedule\t\t       hereunder
\n     written………… for the purpose
\n     of the  maintenance and  support of
\n     the members  of his  family and his
\n     descendants and  ultimately for the
\n     religious and  charitable\tpurposes
\n     hereinafter mentioned in the manner
\n     hereinafter appearing….”<\/p><\/blockquote>\n
     Pursuant  to  the\tdeed  of  trust\t the  jewellery\t and
\nornaments and  certain other  properties were transferred by
\nthe settlor as a wakf.\n<\/p>\n
     The settlor  Sir Mir  Osman Ali Khan expired on 24th of
\nFebruary,  1967.  By  an  order\t passed\t by  the  Additional
\nAssistant Collector  of Estate\tDuty dated  25th of January,
\n1973, the  properties which were the subject matter of these
\ntwo trusts  were deemed to pass on the death of the deceased
\nand were   and were treated as property passing on the death
\nof the\tdeceased for the purposes of estate duty. The appeal
\nof the\tpresent\t appellant,  however,  was  allowed  by\t the
\nAppellate Controller  of Estate\t Duty by his order dated 2nd
\nof June,  1975. In  the further\t appeal to the Tribunal, the
\nTribunal by  its order dated 7th of July, 1976 dismissed the
\nappeal of  the department  and confirmed  the order  of\t the
\nAppellate Controller  by  holding  that\t the  value  of\t the
\nproperty forming  the corpus of the trust cannot be included
\nin the principal value of the estate of the deceased.\n<\/p>\n
     From this\tfinding of  the Tribunal,  the following two
\nquestions were\treferred to the High Court of Andhra Pradesh
\nat Hyderabad:\n<\/p>\n
     “A: Whether on the facts and in the
\n     circumstances of the case the trust
\n     created   by    the   deceased   on
\n     21.3.1953 known  as Sahebzadi Oalia
\n     Kulsum Trust is ab initio void?
\n     B:\t Whether on the facts and in the
\n     circumstances of  the case\t and  on
\n     the  interpretation  of  the  trust
\n     deed the value of the corpus of the
\n     Shabzadi  Oalia   Kulsum  Trust  is
\n     liable  to\t  be  included\t in  the
\n     Principal value  of the  estate  of
\n     late Sir Osman Ali Khan Bahadur?”<\/p><\/blockquote>\n
     Similar questions\twere referred in connection with the
\nsecond trust.  The High\t Court by  its impugned judgment and
\norder dated  9th of  December, 1983 decided the questions in
\nfavour of  the revenue and against the assessee. The present
\nappeals arise  from the\t impugned judgment of the High Court
\ndated 9th of December, 1983.\n<\/p>\n
     It is  contended by  the respondent i.e. the department
\nthat the  trusts created  under the  said deeds of trust are
\nvoid ab\t initio since they violate Sections 13 and 14 of the
\nTransfer of  Property Act,  particularly  the  Rule  against
\nPerpetuity  incorporated   there.  The\tappellant,  however,
\nreview upon  Section 2 of the Transfer of Property Act under
\nwhich it is provided, inter alia, that nothing in the second
\nchapter of  this Act  shall be\tdeemed to affect any rule of
\nMahomedan  law.\t Section  13  and  14  relied  upon  by\t the
\ndepartment, form  a  part  of  the  second  chapter  of\t the
\nTransfer of  Property Act.  The appellant submits that under
\nMahomedan Law  it is permissible to create a Wakf-alal-aulad
\nunder which  a trust  in perpetuity  can be  created for the
\nmaintenance and\t support wholly\t or partially, of the family
\nof the\tsettlor, his children or descendants from generation
\nto  generation and thereafter for the benefit of poor or for
\nany  other  purpose  recongnised  by  Mohammedan  Law  as  a
\nreligious,  pious  or  charitable  purpose  of\ta  permanent
\ncharacter. The\tprovisions of  Chapter 2  of the Transfer of
\nProperty Act  which  inter  alia  embody  the  Rule  against
\nPerpetuity applicable to transfers inter vivos, do not apply
\nto such trusts.\n<\/p>\n
     Syed Ameer\t Ali in\t his book  on Mahommedan Law, Fourth
\nEdition, Volume 1, page 284 stated as follows:\n<\/p>\n
     “When  a  man,’  says  the\t Fatawai
\n     Alamgiri quoting  the Zakhira,  has
\n     made a  wakf of  land or  something
\n     else with\ta  condition,  that  the
\n     whole or  part of\tit shall  be for
\n     himself while  he lives  and  after
\n     him for the poor, the wakf is valid
\n     according to  Abu\tYusuf,\tand  the
\n     jurists of\t Balkh have  adopted his
\n     opinion and  ruled accordingly, and
\n     the Fatwa\tis  in\tconformity  with
\n     that opinion  as an  inducement  to
\n     the making of wakfs.”<\/p><\/blockquote>\n
     Dealing with  wakf in  favour of descendants, Ameer Ali
\nsays (p.284):\n<\/p>\n
     “So also  if he  should,  ‘This  my
\n     land  is\ta  sadakah-mowkoofa,  he
\n     (meaning the  mutwalli)  will  pass
\n     the produce  to me\t while\tI  live,
\n     then after\t me to\tmy child  and my
\n     child’s child  and their  nasl  for
\n     ever, while  there are any and when
\n     they cease,  to the indigent,’ This
\n     is lawful.”<\/p><\/blockquote>\n
     (N.B. nasl = descendants)
\n     There is  general consensus on this proposition amongst
\nthe various authorities on Islam.\n<\/p>\n
     The Privy Council, however, had an occasion to consider
\na wakf-alal-aulad  created by  a Muslim\t in the case of Abul
\nFata Mohammad  Ishak v.\t Rasamaya Dhur\tChowdhary  (1894  22
\nIndian Appeals\t76) in which two Muslim brothers made a wakf
\nwhereby they  were the\tfirst mutwallis\t of  the  wakf.\t The
\nentire benefit of the wakf was to go to the children in\t the
\nfirst instance\tand their  descendants\tfrom  generation  to
\ngeneration  until   the\t total\textinction  of\tthe  family.
\nThereafter the\tincome was  to be applied for the benefit of
\nwidows, orphans, beggar and the poor. The Privy Council held
\nthat since  the bequest\t to charity  was  illusory  and\t too
\nremote, the  wakfs were\t not valid as they offended the rule
\nagainst perpetuity.\n<\/p>\n
     Criticising the  decision of the Calcutta High Court in
\nthe case  of Rasamaya  Dhur Chowdhary v. Abdul Fata Mohammad
\nIshak ([891])  I.L.R. 18  Cal. 399)  which was\tsubsequently
\nupheld by  the Privy Council in Abdul Fata Mohammad Ishak v.
\nRasamaya Dhur  Chowdhary (supra),  Ameer  Ali  explains\t the
\nposition in  Mahommadan Law by saying that the provision for
\none’s children\tand descendants\t is regarded as a pious duty
\nby which  nearness (kurbat)  to God is attained. The mention
\nof the\tpoor is\t required by Mohammad (not by Abu Yusuf with
\nwhom is\t the Fatwa) not to give validity to the wakf, but to
\nensure perpetuity;  and as human beings are liable to become
\nextinct and  as a  wakf\t must  be  a  permanent\t dedication,
\nMohammad required that the poor should be expressly named or
\nimplied by  the use of the word “sadakah”. Abu Yusuf, on the
\nother hand, held that whether the poor were named or not, or
\nwhether the  word “sadakah” was used or not, the word “wakf”
\nimplied perpetuity, and, therefore, unless some other object
\nwas named,  on failure\tof the wakif’s posterity, the income
\nwould be  applied for  the poor.  There is no question about
\nthe validity  of the  wakf; the mention of the poor does not
\nmake the  wakf per  se more  or less  valid; it only ensures
\nperpetuity insisted upon in the law (pages 296-297).\n<\/p>\n
     Asaf A.A.\tFyzee in  his book  “Outlines of  Muhammadan
\nLaw”, Fourth  Edition at  pages 303 states that according to
\nthe  ancient  texts,  wakfs  for  the  support\tof  a  man’s
\ndescendants and\t family were  considered to  be\t proper\t and
\nlawful. He says, ” The Prophet is reported to have said that
\n‘When a Muslim bestows on his family and kindred, hoping for
\nreward in  the next  world, it becomes alms, although he was
\nnot given to the poor, but to his family and children.’ What
\nin  the\t estimation  of\t the  English  lawyers\twould  be  a
\npernicious perpetuity,\tcalculated to  aggrandize the family
\nof the\tfounder, is,  according to  the shariat, the best of
\ncharities.” The\t position in  Islamic Law  is summed  up  by
\nFyzee at page 303 by quoting the words of Ameer Ali:\n<\/p>\n
     From the  promulgation of\tIslam up
\n     to the  present day  there has been
\n     an absolute  consensus  of\t opinion
\n     regarding the  validity of wakfs on
\n     one’s   children,\t  kindred    and
\n     neighbours.   Practical\tlawyers,
\n     experienced judges,  high\tofficers
\n     of\t every\tsect  and  school  under
\n     Mussulman\tsovereigns  are\t all  in
\n     unison on\tthis  point.  There  are
\n     minor differences,\t viz. Whether  a
\n     wakf can be created for one’s self,
\n     whether the unfailing object should
\n     be designated, whether the property
\n     should  be\t  partitioned  or   not,
\n     whether consignment is necessary or
\n     not; but  so far as the validity of
\n     a wakf constituting one’s family or
\n     children the\tbenefaction,  in
\n     whole or  in  part,  is  concerned,
\n     there is  absolutely no difference.
\n     A wakf  is a  permanent benefaction
\n     for the  good of  God’s  creatures:
\n     the wakif\tmay bestow the usufruct,
\n     but   not\t  the\tproperty,   upon
\n     whomsoever\t he   chooses\tand   in
\n     whatsoever manner he likes, only it
\n     must endure for ever. If he bestows
\n     the usufruct  in the first instance
\n     upon  those  whose\t maintenance  is
\n     obligatory on  him, or  if he gives
\n     it to  his descendants  so long  as
\n     they exist to prevent their falling
\n     into indigence,  it is a pious act,\n<\/p><\/blockquote>\n
     –\tmore  pious,  according\t to  the
\n     Prophet than  giving to the general
\n     body of the poor. he laid down that
\n     one’s family  and\tdescendants  are
\n     fitting  objects  of  charity,  and
\n     that  to  bestow  on  them\t and  to
\n     provide for  their future substance
\n     is more  pious and\t obtain\t greater
\n     ‘reward’  than  to\t bestow\t on  the
\n     indigent  stranger.   And\tthis  is
\n     insisted upon so strongly that when
\n     a wakf  is made for the indigent or
\n     poor generally, the proceeds of the
\n     endowment is applied to the relieve
\n     the wants of the endower’s children
\n     and descendants  and kindred in the
\n     first place  (see\tBaillie’s  Dig.,
\n     2nd ed.,  p.593). When  a\twakf  is
\n     created constituting  the family or
\n     descendants of  the wakf  [sic, for
\n     wakif]  the   recipients\tof   the
\n     charity so\t long as they exist, the
\n     poor  are\texpressly  or  impliedly
\n     brought in\t not for  the purpose of
\n     making the wakf charitable (for the
\n     support   of    the   family    and
\n     descendants is a part and parcel of
\n     the charitable  purpose  for  which
\n     dedication is  made), but simply to
\n     impart permanency to the endowment.
\n     When the  wakif’s descendants fail,
\n     it must  come to the poor. So it is
\n     an enduring benefaction – an act of
\n     ibadat  or\t  worship,  to\tuse  the
\n     language of  the Jawahir-ul-Kalam,-
\n     an\t  act\tby   which   kurbat   or
\n     ‘nearness’ is  gained to the Deity,
\n     according to the bahr-ur-Raik.”<\/p><\/blockquote>\n
     Despite this  clear Islamic pronouncement regarding the
\nvalidity of  wakfs-alal-aulad, the  Privy Council pronounced
\nin the case of Abdul Fata Mohammad Ishak (supra) that such a
\nwakf would  be invalid, even if there is an express ultimate
\ndedication to  the poor, because the bequest to “charity” is
\ntoo  remote.   The  decision   can,  at\t best,\tbe  held  as
\ninterpreting Mohammedan\t Law as interpreted in British India
\nof the\ttime, as  the  case  arose  in\tBritish\t India.\t Not
\nsurprisingly, it led to large scale protests.\n<\/p>\n
     On account\t of large  scale protests  in British  India
\nagainst the  decision, the  Mussalman Wakf Validating Act of
\n1913 was  enacted to validate such wakfs. This Act cannot be
\nlooked upon  as laying\tdown any new principle of Mohammedan
\nLaw. As\t Fyzee has  put it,  (page 304) the Act purported to
\nrestore the  law of the Shariat in India and to overrule the
\nlaw as\tlaid down  by the  Privy Council. This Act was given
\nretrospective effect by the Mussalman Wakf Validation Act of
\n1930. Both  the Acts  applied to  British India.  After\t the
\nConstitution  came   into  force,   the\t operation   of\t the
\nValidation  Act\t  of  1913  was,  therefore,  by  amendment,
\nexcluded from  Part-B States  i.e.  territories\t which\twere
\noriginally native States or outside British India. After the
\nConstitution (Seventh Amendment) Act, 1956 abolishing Part-B
\nStates (inter alia), all the territories which were included
\nin Part-B  States prior\t to  1956  were\t excluded  from\t the
\nValidation Act,\t 1913. It  is, therefore,  contended by\t the
\ndepartment that\t the Validation\t Act did  not apply  to\t the
\nState of  Hyderabad which  was a Part-B State upto 1956. And
\nhence the  wakfs in  the present  case are  hit by the Privy
\nCouncil decision in Abdul Fata Mohammad Ishak (Supra).\n<\/p>\n
     However, the  Privy  Council  decision  in\t Abdul\tFata
\nMohammad Ishak\t(supra) can  be taken  to  have\t interpreted
\nMohammedan  Law\t  as  applicable   in  British\t India.\t The
\nValidation Act,\t 1913 merely restored the law of the Shariat
\nwhich had  been disturbed  by the  Privy  Council  judgment.
\nHyderabad,  which   was\t outside   British  India,  must  be
\nconsidered as continuing to be governed by the principles of
\nMohammedan Law\tas understood by the accepted authorities on
\nthe  subject.\tNon-applicability  of\tthe  Mussalman\tWakf
\nValidation Act,\t 1913 to  the State  of Hyderabad  will\t not
\naffect wakfs-alal-aulad\t created in  the State\tof Hyderabad
\nwhich are  valid under the accepted principles of Mohammedan
\nLaw.\n<\/p>\n
     In fact,  the Hyderabad High Court in 1955, referred to
\nand applied  the general  principles of\t Mohammedan  Law  to
\ndeclare a  wakf invalid.  In the case of Salah v. Husain and
\nOrs. (AIR 1955 Hyderabad 229), one Salah Bin Ahmed purported
\nto create a wakf-alal-aulad with himself as mutawalli.\n<\/p>\n
     After his\tdeath his  sons were  to  be  mutwallis\t and
\nthereafter his\tgrandsons. There  was no  dedication to\t the
\npoor. Dealing  with the\t position under\t the Mohammedan Law,
\nthe High  Court of  Hyderabad referred\tto the difference of
\nopinion\t between  the  disciples  of  Abu  Hanif  viz.\tImam
\nMohammad and  Abu Yusuf. While Imam Mohammed was of the view
\nthat without  dedication to  the poor, the wakf was invalid,
\nAbu Yusuf  was said to be of the view that such a dedication
\nwas implicit  in the  wakf. The Court held that there was no
\nclear authority\t that the  view of  Abu Yusuf  differed from
\nthat of\t Imam Mohammad\ton this\t point. On the principles of
\nMohammedan Law the wakf, in the absence of dedication to the
\npoor, was invalid.\n<\/p>\n
     Although the  High Court  referred, inter\talia, to the
\nPrivy Council decision in Abdul Fata Mohammad Ishak (supra),
\nand the\t Mussalman Wakf\t Validation Acts 1913 and 1930 which
\napplied only  to British  India, it appears to have accepted
\nthe submission\tthat the  Court was  obliged  to  apply\t the
\noriginal principles  of Mohammedan  Law in as much as H.E.H.
\nthe Nizam  in the Charter granted to the High Court directed
\nthat in\t cases where the parties were Muslims the case would
\nbe governed  by Sharai-Shariff. The High Court held the wakf
\nto be invalid under Mohammedan Law.\n<\/p>\n
     Of course, in the case before it, both under the law as
\ndeclared by  the Privy\tCouncil as  also the  dictum of Imam
\nMohammad (said\tto be no different from that of Abu Yusuf on
\nthis issue) the wakf was invalid. But the High Court, in the
\nlight of  its Charter also took the assistance of Mohammedan
\nLaw as\tlaid down  by Islamic  authorities in  deciding\t the
\nissue.\n<\/p>\n
     In the light of the principles of Mohammedan Law as set
\nout earlier,  the two  trusts created in 1953 in the present
\ncase are valid wakfs. The wakif-settlor made a dedication in
\nperpetuity  of\tthe  subject  matter  of  these\t trusts\t for
\npurposes which\tare considered\tpious under Islamic Law. The
\nproperties, therefore,\tceased to  be the  properties of the
\nsettlor on  the creation  of the  wakfs in  1953.  When\t the
\nsettlor died  in 1967,\tthey could  not form  a part  of his
\nestate –  the  settlor\thaving\tdivested  himself  of  these
\nproperties fourteen years prior to his death.\n<\/p>\n
     The appellant has also pointed out that during the life
\ntime of the settlor, the income-tax authorities had accepted
\nthe validity  of the wakfs and had not treated the income of
\nthe wakfs as the income of the settlor.\n<\/p>\n
     In the present case, therefore, the beneficial interest
\ncreated in favour of Oalia Kulsum and Anwar Begum is a valid
\ncreation of  trust which  is not affected by Sections 13 and
\n14 of  the Transfer of Property Act. As a result the settlor
\nhad divested himself of these properties during his lifetime
\nfor the\t benefit of  his grand daughter Oolia Kulsum and his
\ndaughter-in-law\t Anwar\t Begum\tand   thereafter  for  their
\ndescendants and\t then for  the holy  shrine at\tKhum. On the
\ndate of\t his death  the Settlor did not have any interest in
\nthe properties\tnor had\t he reserved any interest to himself
\nunder these  trusts. Hence, for the purposes of Estate Duty,
\nthe deceased  cannot be considered as having any interest in
\nthe trust property which passed on his death. The properties
\nwhich constituted  the subject\tmatter of  the\ttwo  trusts,
\ntherefore, cannot  be included in the estate of the deceased
\nSir Mir\t Osman Ali  Khan, the  Nizam of\t Hyderabad  for\t the
\npurposes of estate duty.\n<\/p>\n
     In the  premises, the  judgment and  order of  the High
\nCourt are  set aside  and the  two questions are answered in
\nthe negative and in favour of the appellant. The appeals are
\naccordingly allowed with costs.<\/p>\n","protected":false},"excerpt":{"rendered":"
Supreme Court of India Trustees Of Sahebzadi Oalia … vs The Controller Of Estate Duty, A.P on 3 August, 1998 Author: M S Manohar. Bench: Sujata V. Manohar, M. Srinivasan PETITIONER: TRUSTEES OF SAHEBZADI OALIA KULSUM TRUST Vs. RESPONDENT: THE CONTROLLER OF ESTATE DUTY, A.P. DATE OF JUDGMENT: 03\/08\/1998 BENCH: SUJATA V. MANOHAR, M. SRINIVASAN […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_lmt_disableupdate":"","_lmt_disable":"","_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[30],"tags":[],"class_list":["post-6236","post","type-post","status-publish","format-standard","hentry","category-supreme-court-of-india"],"yoast_head":"\nTrustees Of Sahebzadi Oalia ... vs The Controller Of Estate Duty, A.P on 3 August, 1998 - Free Judgements of Supreme Court & High Court | Legal India<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/www.legalindia.com\/judgments\/trustees-of-sahebzadi-oalia-vs-the-controller-of-estate-duty-a-p-on-3-august-1998\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Trustees Of Sahebzadi Oalia ... vs The Controller Of Estate Duty, A.P on 3 August, 1998 - 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