Bhagwati Saran v Parmeshwari Nandar

Facts

• Transfer created a life interest in A and remainder to B "on A's death"
• B died before A; B's heirs claimed the remainder
• Question: was B's interest vested (passes to heirs) or contingent (fails on B's death)?

Issue

1. Whether an interest to take effect on death of the life tenant is vested or contingent.

Held

• The interest is vested from the date of transfer. Death is certain; only enjoyment is postponed. B's heirs inherit the vested remainder.

Ratio Decidendi

S.19 applies: the interest takes effect "on the happening of an event which must happen" (death). This creates vesting immediately. The remainderman's death before the life tenant does not destroy the interest: it passes to heirs.