Property is granted "to A for life, remainder to B." A renounces his life interest. What happens to B's remainder?

B's Interest: Vested from the Beginning

When property is granted "to A for life, remainder to B," B acquires a vested interest the very moment the transfer is made. Section 19 of the Transfer of Property Act, 1882 makes this clear — where an interest is created without specifying the time when it is to take effect, or on the happening of an event which must happen, it is vested. Death is not an uncertain event; it is a certainty. B's remainder, therefore, vests immediately in title, even though the actual possession and enjoyment must await the natural determination of A's life interest. Importantly, as Section 19 itself declares, a vested interest is not defeated by the death of the transferee before he obtains possession. B carries a present right for future enjoyment from day one.

What Renunciation by A Does

When A voluntarily renounces or surrenders his life interest before his natural death, he causes the prior interest to fail — not by death, but by his own deliberate act. This is where the doctrine of acceleration under Section 27 becomes directly relevant. The section provides that where an ulterior disposition is made in favour of one person by the same transaction, if the prior disposition shall fail, the ulterior disposition shall take effect upon that failure, although the failure may not have occurred in the manner contemplated by the transferor.

The transferor who crafted the arrangement — "to A for life, remainder to B" — almost certainly contemplated that B would take upon A's death. A's voluntary renunciation is plainly not that. Yet Section 27 specifically liberates B's remainder from the precise manner of failure, and the courts have consistently construed ulterior interests as intended to take effect upon the determination of the prior interest in any manner.

The Acceleration of B's Remainder

The legal consequence, therefore, is unambiguous: B's remainder accelerates. The prior life estate having failed — through renunciation rather than death — B's vested interest in remainder is no longer kept waiting. B becomes entitled to immediate possession of the property. This is the doctrine of acceleration in its purest operation: the prior interest no longer stands in B's way, and there is no reason to keep the property suspended in any form of abeyance. The law abhors a vacuum of ownership, and where a valid vested interest already exists in favour of a person, it steps in without delay.

A Qualification Worth Noting

There is one circumstance that could complicate this otherwise clean result. If the transferor, in the instrument itself, had expressed a clear and specific intention that B's interest should take effect only upon A's natural death — and not upon any other determination of the life estate — then B's remainder would not accelerate on a mere renunciation by A. The second paragraph of Section 27 protects such specifically conditioned ulterior interests. But where, as in the simple grant before us, no such restrictive intention is expressed, the broad rule applies: the failure of A's life interest, in whatever manner it occurs, brings B's remainder immediately into possession. The law, in favouring early vesting, does not compel B to wait for an event — A's death — when the obstruction has already been removed by A's own hand.