C. Doddanarayana Reddy (D) By LRs. & Ors. v. C. Jayarama Reddy (Dead) By LRs. & Ors.
Background
A man sued his brothers for a 1/4th share in family property, claiming the 1963 release deed by which he had relinquished his rights was void because he was a minor at the time he signed it. The trial court and the first appellate court both held, based on his subsequent marriage date and the release deed's own recitals, that he was actually an adult when he signed, and dismissed his suit. In a second appeal, the Karnataka High Court reversed this, relying on a school transfer certificate to hold he was a minor and that the release deed was therefore void.
Decision Breakdown
The Supreme Court held the High Court had exceeded its narrow jurisdiction under Section 100 of the Code of Civil Procedure, which permits interference only on a genuine "substantial question of law," not by re-appreciating facts already concurrently found by two lower courts. On the evidence itself, the Court held the school certificate had no real evidentiary value for proving date of birth because no one with actual knowledge, such as the headmaster who issued it or the father who allegedly signed it, was ever examined to prove how the entry was made. Since the plaintiff had admitted executing the release deed and had retained the Rs 5,000 consideration paid under it, without ever pleading fraud or coercion, the Supreme Court restored the trial court's dismissal of the suit.
Lesson Learnt
A school leaving or transfer certificate is not automatic proof of someone's date of birth, its value depends on a witness with real, first-hand knowledge testifying to how the entry was recorded, and a High Court cannot overturn the concurrent factual findings of two lower courts in a second appeal without a genuine question of law.