Marriage of a Son as No Bar to Family Pension under Rule 47(6) of the M.P. Civil Services (Pension) Rules, 1976:
A Detailed Commentary on Neeraj Kewat v. The State of Madhya Pradesh

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I. Introduction

The decision of the Madhya Pradesh High Court in Neeraj Kewat v. The State of Madhya Pradesh & Others (WP No. 10766 of 2024, decided on 24 November 2025 by Hon'ble Justice Ashish Shroti) clarifies a recurring and significant question under the M.P. Civil Services (Pension) Rules, 1976:

• Does the marriage of a son of a deceased government servant terminate his right to family pension?

The Court answers this question in the negative, laying down a clear legal principle: under Rule 47(6) of the M.P. Civil Services (Pension) Rules, 1976, a son’s entitlement to family pension continues until he attains the age of 25 years or starts earning his livelihood or dies, irrespective of his marital status. Any administrative attempt to cut off pension on the ground of the son’s marriage is de hors (outside) the Rules and therefore invalid.

The judgment also touches upon an important ancillary issue: whether a petitioner’s alleged misrepresentation about his marital status can disentitle him from a statutory pension benefit when the statute does not make that fact relevant. The Court holds that a statutory entitlement cannot be defeated by importing an extraneous condition (marriage of the son), even if there is alleged misstatement, so long as the statutory preconditions are otherwise fulfilled.

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II. Factual Background

The core facts are straightforward and undisputed:

1. The petitioner’s father, Late Gangaram Kewat, served as a Line Helper in the office of the Deputy General Manager (O&M), Division Mungaoli. He retired from service and was receiving pension from 1 June 2018 until his death on 15 May 2021. His wife had predeceased him.
2. Upon his father’s death, the petitioner, Neeraj Kewat, applied for family pension. The authorities initially asked for a succession certificate, which he submitted on 29 September 2022.
3. On 9 August 2023, respondent no. 2 sanctioned family pension in favour of the petitioner for the period from 16 May 2021 to 2 February 2026 (Annexure P/1). The order contained a condition that family pension would be payable to him until he attained 25 years of age, or marriage, or death, whichever was earlier.
4. The petitioner challenged specifically the inclusion of the marriage condition, arguing that the Pension Rules do not provide that a son’s marriage bars his entitlement. He also alleged that despite sanction, actual payment was withheld.
5. The respondents, on their part, not only relied on Rule 47(14)(b)(ii) (definition of “family”) to justify the marriage condition but also alleged that:
   • The petitioner was in fact married, as indicated by the Samagra ID / family ID showing one Neetu Kewat (aged 25) and a child, Harshika Kewat (aged 1), in the petitioner’s family unit.
   • The petitioner had given an affidavit on 29 November 2023 declaring himself to be unmarried (Annexure R/2), which they claimed was false.
   • On this basis, they argued he had not approached the authorities or the Court with clean hands and should not be granted any relief.

As a result, although pension had been formally sanctioned, no amount was disbursed, leading the petitioner to invoke the writ jurisdiction of the High Court.

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III. Issues Before the Court

The Court distilled the controversy into two principal issues:

1. Effect of Alleged Misrepresentation:
   Does the alleged furnishing of false information by the petitioner (about being unmarried) in an affidavit disentitle him to family pension, assuming that the statutory rules do not make marriage a disqualification for sons?
2. Interpretation of Rule 47 of the Pension Rules:
   Under Rule 47 of the M.P. Civil Services (Pension) Rules, 1976, is a son’s entitlement to family pension affected by his marriage, or is it confined only to age (25 years) and income criteria? More specifically:
   • How should Rule 47(6) (the main provision on period of payment of family pension) be read vis-à-vis
   • Rule 47(14)(b)(ii) (the definition of “family” for purposes of Rule 47)?

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IV. Statutory Framework: Rule 47 of the M.P. Civil Services (Pension) Rules, 1976

1. Rule 47(6): Period for Which Family Pension is Payable

The key provision relied upon by the petitioner is Rule 47(6):

"The period for which family pension is payable shall be as follows:-

(i) in the case of a widow or widower, up to the date of death or remarriage whichever is earlier;
(ii) in the case of a son, until he attains the age of 25 years; and
(iii) in the case of an unmarried daughter, until she attains the age of 24 years or until she gets married, whichever is earlier."

From this, the Court underscores two vital points:

• For a son, the text is simple and unconditional: family pension is payable “until he attains the age of 25 years”.
• For an unmarried daughter, there is an explicit marriage-based limitation: she is eligible only until age 24 or marriage, whichever is earlier.

To this sub-rule, there is an Explanation, of which two clauses are crucial:

"(b) A daughter shall become ineligible for family pension under this sub-rule from the date she gets married.
(c) The family pension payable to such a son or daughter shall be stopped if he or she starts earning his/her livelihood."

Explanation (b) expressly attaches marriage as a disqualification only for a daughter, and not for a son. Explanation (c) adds an income criterion for both son and daughter: pension stops if they start earning a livelihood.

2. Rule 47(14)(b)(ii): Definition of “Family”

The respondents invoked Rule 47(14)(b)(ii), which reads:

"(14) For the purpose of this rule-
(b) 'family' in relation to the Government servant means-
(ii) son or an unmarried or widowed or divorced daughter till such son or daughter attains the age of twenty five years or upto the date of his/her marriage/remarriage as the case may be, whichever is earlier, subject to the income criteria as prescribed by the State Government from time to time."

This provision is somewhat clumsily drafted, particularly due to the use of the pronoun “his” (in "his/her marriage/remarriage") after the phrase “son or an unmarried or widowed or divorced daughter”. This give rise to an apparent ambiguity:

• Does the phrase “upto the date of his/her marriage/remarriage” apply to both son and daughter?
• Or does the marriage/remarriage condition relate only to daughters (unmarried/widowed/divorced), while the son is governed solely by the age and income criteria as in Rule 47(6)?

The interpretational conflict between Rule 47(6) and Rule 47(14)(b)(ii) lies at the heart of the case.

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V. Arguments of the Parties

1. Petitioner’s Submissions

Through counsel, the petitioner contended:

1. Rule 47(6) is the substantive provision dealing with the period of payment of family pension. It unambiguously states that in the case of a son, family pension is payable until he attains the age of 25 years. There is no mention of marriage as a disqualification for sons.
2. The condition of “marriage” in the sanction order (Annexure P/1) is therefore de hors the Rules, i.e., outside the four corners of the statutory framework, and hence invalid.
3. Despite sanction of pension in his favour, the authorities have not disbursed any payment, which is arbitrary and illegal.
4. He sought:
   • Direction to release family pension;
   • Arrears from the date of his father’s death, with interest at 12% per annum;
   • A declaration that the marriage condition in the sanction order is contrary to the Pension Rules.

2. Respondents’ Submissions

The State and respondent nos. 2 and 3 opposed the petition, arguing:

1. That Rule 47(14)(b)(ii) clearly states that a son “till … the date of his/her marriage” shall be treated as family, indicating that marriage is a disqualification for sons as well.
2. During verification, the petitioner was asked to provide his ration card/family ID. The Samagra ID disclosed the names of Neetu Kewat (25 years) and Harshika Kewat (1 year), suggesting that the petitioner was married with a child.
3. By letter dated 17 January 2024 (Annexure R/3), the petitioner was asked to clarify his relationship with these individuals but failed to do so, which justified withholding payment.
4. The petitioner had earlier submitted an affidavit dated 29 November 2023 claiming he was unmarried (Annexure R/2), which appeared to be false. Therefore:
   • He had not approached the Court with clean hands;
   • He was not entitled to any discretionary relief under Article 226 of the Constitution;
   • He was, in any event, disentitled to family pension upon marriage under Rule 47(14)(b)(ii).

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VI. Summary of the Judgment

The Court’s conclusions can be summarised as follows:

1. Alleged False Affidavit Irrelevant to Statutory Entitlement
   Even if the petitioner mis-stated his marital status, this does not affect his legal right to family pension because the governing rules (Rule 47(6)) do not treat a son’s marriage as a disqualifying factor.
2. Rule 47(6) Is Clear: Son’s Marriage Not a Disqualification
   Rule 47(6)(ii) grants family pension to a son until he reaches 25 years of age. Neither Rule 47(6) nor its Explanation makes marriage a disqualification for sons. Explanation (b) explicitly makes marriage a disqualification only for daughters.
3. Rule 47(14)(b)(ii) Cannot Override or Restrict Rule 47(6)
   Rule 47(14)(b)(ii) is a definitional clause. It must be read harmoniously with Rule 47(6), the substantive provision. It cannot be interpreted in a way that:
   • Contradicts or narrows the clear scope of Rule 47(6); or
   • Introduces a marriage-based disqualification for sons that the main provision does not contemplate.
   The use of the pronoun “his” in Rule 47(14)(b)(ii) is treated as a drafting anomaly that cannot be allowed to defeat the clear intent of Rule 47(6).
4. Marriage of a Son Not a Ground to Stop Family Pension
   The Court expressly holds that the mere marriage of the petitioner, a son of the deceased employee, does not render him ineligible for family pension. His entitlement continues:
   • Until he attains the age of 25 years; or
   • Until he starts earning his livelihood; or
   • Until his death,
   whichever is earlier.
5. Sanction Order’s Marriage Condition Invalid
   The condition in the sanction order dated 9 August 2023, that pension is subject to the petitioner remaining unmarried, is held to be invalid and de hors Rule 47(6).
6. Relief Granted
   The Court:
   • Declares the petitioner entitled to family pension from 16 May 2021 (the day after his father’s death)
   • Directs respondents to:
     • Disburse all arrears of family pension from 16 May 2021 till date;
     • Continue to pay pension till he attains 25 years of age or starts earning or dies, whichever earlier;
     • Pay interest at 6% per annum on the arrears;
     • Make the entire payment within 90 days from the date of submission of a certified copy of the order.
   The petition is accordingly allowed and disposed of.

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VII. Detailed Analysis

1. Treatment of Alleged Misrepresentation and the "Clean Hands" Argument

The first point dealt with by the Court (para 7) is the respondents’ objection that the petitioner furnished incorrect information in his affidavit (claiming to be unmarried). The Court’s approach is significant:

• It accepts, for purposes of argument, that the petitioner may indeed be married (as indicated by the Samagra ID).
• It then emphasises that entitlement to family pension is governed by statutory rules. If, on a correct reading of those rules, a married son is still eligible for family pension, the authorities cannot deny that right by reference to his marital status.
• Therefore, whether the affidavit was wrong or right becomes **irrelevant** to the determination of the legal right. An alleged false statement cannot create a disqualification that the statute itself does not recognise.

This reasoning implicitly recognises that while a writ court ordinarily insists that litigants come with “clean hands”, this equitable consideration cannot override a clear statutory entitlement. At most, alleged misrepresentation may have separate consequences (e.g., departmental or criminal proceedings) but does not erase a benefit that the law itself mandates.

The Court therefore refuses to treat the affidavit issue as a bar to relief, and proceeds to decide the core legal question on the interpretation of Rule 47.

2. Rule 47(6): Son’s Entitlement Independent of Marriage

The Court correctly begins with Rule 47(6), the substantive provision that specifies the period of payment of family pension to different categories of family members.

The Court notes (paras 9–11):

• The provision distinguishes **three categories**:
  1. Widow or widower – pension till death or remarriage;
  2. Son – pension until he attains age 25;
  3. Unmarried daughter – pension until she turns 24 or marries, whichever earlier.
• Marriage as a terminating event is expressly stated only for daughters (in sub-clause (iii)) and reiterated in Explanation (b), which states that a daughter becomes ineligible from the date she gets married.
• For sons, the only express limitations within Rule 47(6) are:
  • Age – pension is payable until age 25; and
  • Income – Explanation (c) states that family pension stops if the son starts earning his livelihood.
  Marriage is nowhere mentioned as a ground for cessation of pension for sons.

The Court thus finds that the textual and structural design of Rule 47(6) is clear and unambiguous with respect to sons: marriage does not affect their entitlement.

3. Reconciling Rule 47(6) and Rule 47(14)(b)(ii): Harmonious Construction

The respondents’ entire case on the merits rested on Rule 47(14)(b)(ii), a part of the definition of “family.” The Court’s interpretive exercise (paras 12–18) is crucial, because it addresses:

• How to handle apparent inconsistency between a definitional clause and a substantive provision;
• How to resolve ambiguity created by poor drafting (the pronoun “his”).

Key aspects of the Court’s reasoning:

1. Nature of Rule 47(14)(b)(ii):
   Rule 47(14) opens with “For the purpose of this rule – … ‘family’ means…”. This is clearly a definitional or ancillary provision, not the main provision granting the benefit.
2. Opening Words of Clause (b)(ii):
   The clause begins: “son or an unmarried or widowed or divorced daughter till such son or daughter attains the age of twenty five years…”. This confirms that:
   • Both sons and daughters (including widowed/divorced) are eligible up to age 25,
   • subject to income criteria.
   This is broadly consistent with Rule 47(6), except for the age difference for unmarried daughters mentioned elsewhere.
3. Problematic Phrase – “upto the date of his/her marriage/remarriage”:
   The Court recognises that the later part of the clause – “or upto the date of his/her marriage/remarriage, as the case may be, whichever is earlier” – seems, on a superficial reading, to make marriage/remarriage a disqualification both for sons and daughters. However, this directly conflicts with:
   • The clear language of Rule 47(6)(ii) (no marriage limitation for sons); and
   • Explanation (b) which singles out daughters only.
4. Principle of Harmonious Construction:
   Invoking Supreme Court jurisprudence, the Court reiterates that a subordinate provision (such as a proviso or definition clause) must be:
   • Read in relation to the main provision to which it relates; and
   • Interpreted so as not to render the main provision nugatory, otiose, or inconsistent.
   The definitional clause cannot be used to:
   • Introduce a disqualification that the main rule does not contain; or
   • Whittle down rights clearly conferred by the main rule.
5. Resolution of the Ambiguity:
   On this basis, the Court construes Rule 47(14)(b)(ii) as follows:
   • The phrase “upto the date of his/her marriage/remarriage” is operative only in relation to daughters (including widowed and divorced daughters), not sons.
   • The apparent inclusion of the word “his” (suggesting applicability to sons) is treated as a drafting error which cannot be allowed to override the clear legislative intent reflected in Rule 47(6) and its Explanation.

Thus, the Court firmly concludes that Rule 47(14)(b)(ii) does not and cannot restrict a son’s entitlement to family pension upon his marriage.

4. Precedents Cited and Their Influence

To buttress its interpretive approach, the Court relies on two Supreme Court decisions:

(a) CIT v. Ajax Products Ltd., 1964 SCC OnLine SC 59 (AIR 1965 SC 1358)

In this case, the Supreme Court explained the function and limits of a proviso in a statute. Quoting from CIT, Mysore, Travancore-Cochin and Coorg v. Indo-Mercantile Bank Ltd., the Court reiterated:

"The proper function of a proviso is that it qualifies the generality of the main enactment by providing an exception and taking out as it were, from the main enactment a portion which, but for the proviso, would fall within the main enactment. Ordinarily, it is foreign to the proper function of a proviso to read it as providing something by way of an addendum or dealing with a subject which is foreign to the main enactment… It is a fundamental rule of construction that a proviso must be considered with relation to the principal matter to which it stands as a proviso."

Although Rule 47(14)(b)(ii) is a definition clause and not literally a “proviso”, the Court uses the underlying principle: a subordinate clause cannot:

• Be interpreted as an independent substantive provision that contradicts the main provision; or
• Be “divorced” from the main enactment to which it relates.

Applied here, this means that Rule 47(14)(b)(ii) must be read in light of Rule 47(6), not in isolation. It cannot be read as introducing a new disqualification (marriage of a son) absent in the primary provision.

(b) Delhi Metro Rail Corporation Ltd. v. Tarun Pal Singh, (2018) 14 SCC 161

This case concerned Section 24 of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, and the interplay between its main sub-sections and a proviso. The Supreme Court held that reading the proviso in a way that virtually nullifies or makes another express provision otiose is impermissible. The Court observed:

"A proviso appended to a provision has to be specifically interpreted in the manner so as to enable the field which is covered by the main provision. The proviso is only an exception to the main provision to which it has been enacted and no other. The proviso deals with a situation which takes something out of the main enactment…"

Justice Shroti draws a parallel here: just as a proviso cannot be interpreted to obliterate the main provision, so too a definition clause (Rule 47(14)(b)(ii)) cannot be read so as to virtually rewrite Rule 47(6) by adding a marriage-based disqualification for sons.

In both precedents, the core interpretative doctrine is: subordinate provisions are constrained by the structure and purpose of the main provision and must be read harmoniously with it.

5. Beneficial Nature of Pension Laws – Contextual Understanding

Although the judgment does not expressly invoke it, the Court’s approach is consistent with the established principle that: pension laws and social security provisions are beneficial, welfare-oriented legislation. Therefore, they should be:

• Interpreted liberally and purposively in favour of beneficiaries, and
• Not subject to restrictive or technical constructions that defeat legitimate entitlements.

Here, the Court:

• Refuses to superimpose an extra-statutory disqualification (son’s marriage) based on administrative understanding or literal reading of a loosely worded definition clause, and
• Opts for a construction that preserves and furthers the benefit conferred by Rule 47(6).

This aligns with the broader judicial approach to pensionary benefits, which treats them as a right rather than a bounty, and favours interpretations that safeguard that right.

6. Directions on Arrears and Interest

Finally, the Court grants consequential relief:

• Arrears from 16 May 2021 – the day after the death of the pensioner. This affirms the settled principle that family pension accrues immediately upon the death of the pensioner (subject to eligibility).
• Prospective payment – pension is to continue as sanctioned (without the invalid marriage condition) until:
  • The petitioner turns 25; or
  • He starts earning his livelihood; or
  • He dies,
  whichever is earlier.
• Interest at 6% per annum on arrears, to be paid within 90 days of submission of certified order. This award of interest:
  • Compensates the petitioner for the delay in release of a statutory entitlement; and
  • Sends a signal to authorities that undue delay in pension matters will have financial consequences.

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VIII. Complex Concepts Simplified

Some key legal concepts and terms used in the judgment can be briefly explained as follows:

1. Family Pension

Family pension is a pensionary benefit payable to the family members of a deceased government servant or pensioner, intended to provide financial support after the breadwinner’s death. It is regulated by statutory rules (here, the M.P. Civil Services (Pension) Rules, 1976) and is a statutory right once the conditions in the rules are satisfied.

2. "De hors" the Rules

The Latin expression “de hors” means “outside” or “beyond.” When the Court says a condition is “de hors the Rules”, it means:

• The condition is not authorised by, and indeed is inconsistent with, the governing statutory rules.
• Such a condition cannot lawfully be imposed by administrative authorities.

3. Harmonious Construction

Harmonious construction is a method of interpreting different provisions of a statute so that:

• All provisions are given effect, as far as possible;
• Apparent conflicts are resolved by an interpretation that allows them to coexist;
• No provision is treated as redundant, meaningless, or in direct conflict unless absolutely unavoidable.

In this case, the Court harmonised Rule 47(6) and Rule 47(14)(b)(ii) by:

• Giving primacy to the clear language of Rule 47(6); and
• Reading Rule 47(14)(b)(ii) in a way that does not introduce a new disqualification for sons.

4. Proviso

A proviso is a clause that follows a main provision and typically:

• Creates an exception or qualification; or
• Carves out certain cases from the general rule in the main provision.

While Rule 47(14) is a definition clause rather than a proviso, the Court borrowed principles about how provisos must be read (from Ajax Products and DMRC) to inform how a subordinate clause must relate to a main provision.

5. Definition Clause

A definition clause defines key terms used in a statute. Its function is:

• To clarify the scope of words or expressions used in the substantive provisions, not to override them.

In Rule 47(14), “family” is defined for the purposes of Rule 47, but the Court emphasises that such a definition must:

• Be consistent with; and
• Not expand or contradict

the substantive entitlements laid down in Rule 47(6).

6. "Clean Hands" Doctrine

The clean hands doctrine is an equitable principle that a person seeking discretionary relief (like a writ) must not have acted dishonestly or concealed material facts. However:

• It is a matter of judicial discretion; and
• It cannot be used to nullify a clear statutory right where the alleged misconduct relates to a fact (here, marital status of the son) that the statute itself treats as irrelevant.

7. Writ Petition

A writ petition under Article 226 of the Constitution is a legal proceeding in the High Court seeking:

• Judicial review of governmental/administrative action; or
• Enforcement of legal or fundamental rights.

Here, the petitioner invoked the writ jurisdiction to enforce his statutory right to family pension under the Pension Rules.

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IX. Impact and Future Implications

1. Clarification of Law: Marriage of Son Not a Disqualification

The primary legal principle established by this judgment is:

Under Rule 47(6) of the M.P. Civil Services (Pension) Rules, 1976, a son’s entitlement to family pension is not affected by his marriage. He remains entitled until he turns 25 or starts earning his livelihood or dies, whichever is earlier.

This has immediate and practical consequences:

• Authorities in Madhya Pradesh can no longer:
  • Insert “unmarried son” conditions in sanction orders; or
  • Stop or refuse family pension to sons on the ground that they have married.
• Any departmental circulars or practices premised on treating a married son as ineligible would be contrary to this ruling and susceptible to legal challenge.

2. Administrative Practice and Drafting of Orders

The judgment has a direct impact on the drafting and structure of pension sanction orders:

• Standard formats that mechanically add “unmarried” before “son” or include marriage as a terminating condition for sons must be revised to reflect the correct legal position.
• Authorities must pay closer attention to the exact wording of the statutory rules rather than relying on generalised templates or assumptions that conditions applicable to daughters (e.g., marriage) also apply to sons.

3. Approach to Ambiguous Drafting in Subordinate Legislation

The judgment sets a useful precedent on how courts (and administrators) should approach:

• Ambiguities arising from poor drafting (e.g., the misplaced “his” in Rule 47(14)(b)(ii));
• Conflicts between substantive provisions and definition clauses.

The Court’s approach suggests:

• Where the main rule is clear (Rule 47(6)), a definitional or ancillary clause that introduces confusion must be read down or harmonised to avoid contradiction.
• Courts will not allow ancillary drafting errors to erode substantive entitlements under welfare legislation.

4. Protection of Statutory Pension Rights Against Equitable Objections

The Court’s rejection of the “clean hands” objection on the question of entitlement also carries wider implications:

• It underscores that statutory rights to pension cannot be extinguished by equitable or discretionary arguments where the alleged misconduct relates to a non-essential factor for eligibility.
• This approach will likely protect pension claimants from being denied benefits on extraneous grounds that are not grounded in the pension rules themselves.

5. Gender-Differentiated Rules and Their Persistence

Interestingly, the judgment does not question the gender-differentiated nature of Rule 47(6) itself:

• For sons – entitlement till age 25 (no marriage condition);
• For unmarried daughters – entitlement till age 24 or marriage, whichever earlier.

The Court’s task was not to assess constitutional validity but to interpret the existing rules. However, the decision:

• Ensures that the statutory scheme is applied as it stands, without administrative expansion; and
• Prevents the creation of an even more restrictive regime for sons than the text actually provides.

Questions about the constitutionality or fairness of gender-based distinctions in pension rules would require separate, direct challenge, which was not in issue here.

6. Implications for Other Welfare Statutes and Rules

The interpretive approach adopted here has resonance beyond pension rules:

• In any welfare scheme (e.g., scholarships, social security benefits), definition clauses and provisos must be read in a manner that:
  • Does not negate main entitlement provisions;
  • Does not introduce new disqualifications absent from the principal clause.
• Practitioners and administrators should be cautious about reading subordinate or explanatory provisions as if they were self-standing eligibility criteria.

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X. Conclusion

The decision in Neeraj Kewat v. State of Madhya Pradesh is a significant clarification of the law on family pension under the M.P. Civil Services (Pension) Rules, 1976. The Court articulates and applies two core principles:

1. Primacy of the Substantive Provision:
   Rule 47(6) clearly grants family pension to a son until age 25 without reference to his marital status. A definitional clause like Rule 47(14)(b)(ii) cannot be interpreted to add a marriage-based disqualification for sons. The marriage condition in the sanction order was, therefore, ultra vires and invalid.
2. Irrelevance of Alleged Misrepresentation When Statutory Criteria Are Met:
   Even assuming the petitioner was married and had initially mis-stated this, it does not affect his statutory entitlement to family pension under the Rules, which do not treat a son’s marriage as a disqualification. Equitable objections cannot override a clear legal right arising under welfare legislation.

By ordering payment of arrears with interest and clarifying that a son’s marriage cannot be a ground to deny family pension, the judgment strengthens beneficiary protections under pension law and provides valuable guidance on:

• The proper relationship between substantive provisions and definition clauses;
• The method of resolving ambiguities and inconsistencies in subordinate legislation; and
• The need for administrative authorities to scrupulously adhere to statutory language when granting or withholding benefits.

Going forward, this precedent should prevent improper denial of family pension to sons in Madhya Pradesh on the ground of their marriage and will likely influence similar interpretive disputes in other welfare contexts where definitional or subsidiary provisions appear to conflict with the main grant of a statutory benefit.