Supreme Court: GPF to be shared by wife and mother despite nominee status

New Delhi: The Supreme Court has ruled that the general provident fund (GPF) savings of a deceased government employee must be shared equally between his wife and mother, even though the mother was the sole nominee on record. The court held that once the employee acquired a family through marriage, the earlier nomination in favour of the mother became invalid, and the GPF amount was liable to be distributed among all eligible family members in equal shares.

A bench of Justices Sanjay Karol and N Kotiswar Singh observed that the GPF nomination form itself specifies that a nomination made before the subscriber acquires a family becomes void upon marriage. The judges clarified that the nomination clause does not give the mother a superior claim over the wife and that the relevant rules clearly state that, once invalid, the funds must be shared among eligible survivors.

The employee married the petitioner in 2003 and subsequently nominated her for other service benefits, but did not update the GPF nomination, which continued in favour of his mother until his death in 2021. The court noted that he had ample opportunity between 2003 and 2021 to alter the GPF nomination but failed to do so, and stressed that it is the subscriber’s responsibility, not the authorities’, to update or cancel nominations.

The bench said rules are designed precisely for situations where a subscriber neglects to change nominations, prescribing how money should be distributed among survivors when a nomination becomes invalid. The court recorded that the wife had already received her half share of the GPF as directed earlier by the Central Administrative Tribunal (CAT), and ordered that the remaining half be released to the mother.

In the background of the dispute, the wife had received about Rs 60 lakh in other service-related benefits after her husband died in July 2021, but was denied the GPF amount on the ground that the mother was the nominee. The CAT had ordered equal sharing between wife and mother, but the Bombay High Court set this aside. Challenging that decision, the wife argued before the Supreme Court that the original nomination form itself made the pre-marriage nomination invalid once the employee acquired a family and that, under the rules, the GPF was payable in equal shares to all eligible family members.