As per case facts, Kapil Puri sued claiming exclusive ownership of a plot registered in his mother Phoola Rani's name, asserting he funded the purchase due to a fiduciary relationship. ... Phoola Rani denied this, claiming personal funds and arguing the suit was barred by the Benami Act. The trial court dismissed the suit under the 1988 Benami Act. The First Appellate Court remitted the case, deeming it maintainable under Section 4(3). The High Court heard appeals against this remittal order. The question arose whether Benami law prohibits property purchase in the mother's name. Finally, the High Court held that Kapil Puri's suit is not maintainable under the 1988 Benami Act, clarifying that Section 4(3) does not apply unless the child lacks legal capacity for a fiduciary relationship. SAO No.29 was allowed, and SAO No.39 was dismissed.