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Metpalli Lasum Bai Since Dead and Ors. v. Metpalli Muthaiah(D) by LRs

Civil Appeal · 2025 INSC 879Decided 21 Jul 2025
Civil Appeal No(s). 5921 of 2015 (with Civil Appeal No(s). 5922 of 2015)
Justice Vikram Nath · Justice Sandeep Mehta

Background

After the family patriarch Metpalli Ramanna died intestate before 1949, his son Metpalli Rajanna became owner of the family lands. Rajanna, anticipating disputes between his son from his first marriage (Muthaiah) and his second wife (Lasum Bai), executed a registered Will in 1974 dividing the property between Lasum Bai, Muthaiah, and his widowed daughter Rajamma, and this division was also reflected in an oral family settlement. After Rajanna's death in 1983, Lasum Bai sold part of her share, prompting Muthaiah to challenge her right to do so, ultimately leading to competing suits: Lasum Bai sought a declaration of title based on the Will, which the trial court granted in full but the High Court cut down to a mere 1/4th share, treating the property as undivided joint family property.

Decision Breakdown

The Supreme Court restored the trial court's decree in Lasum Bai's favour and reversed the High Court. It held that the registered Will carried a presumption of genuineness, and crucially, Muthaiah himself had admitted in his deposition that the signatures on the Will were his father's, shifting the burden onto him to prove it was invalid, which he failed to do. The Court found the Will's fairly balanced distribution (giving Muthaiah the larger share) supported its genuineness, since a fabricated Will manipulated in Lasum Bai's favour would more likely have excluded Muthaiah entirely. The evidence of long-standing separate possession by each party over their respective portions further corroborated the family settlement.

Lesson Learnt

In inheritance disputes, a registered Will carries a presumption of validity, and once the person challenging it admits key facts (like the testator's signature), the burden shifts to them to prove fraud or invalidity. Courts will also look at whether a Will's overall fairness supports or undermines a claim that it was forged.

Official source (sci.gov.in)View Judgment (PDF)

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