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Raja Ram v. Jai Prakash Singh and Others

Civil Appeal · 2019 INSC 1015Decided 11 Sept 2019
Civil Appeal No. 2896 of 2009
Justice Navin Sinha · Justice Indira Banerjee

Background

An elderly man sold his land to his daughter-in-law in 1970 and died about ten months later. His sons later sued, claiming the sale deed had been obtained through fraud and undue influence by exploiting their father's old age and infirmity. The trial court dismissed the suit, but the first appellate court sided with the sons; the High Court then reversed that and restored the dismissal. One of the sons (the appellant) approached the Supreme Court.

Decision Breakdown

The Supreme Court held that old age alone does not create a presumption of undue influence or loss of mental capacity: there must be specific pleadings and evidence showing how the alleged dominant party controlled the deceased's will to obtain an unfair advantage. The Court noted the deceased had personally appeared before the sub-registrar, acknowledged receiving full payment, and had validly executed a similar sale two years earlier without challenge, undermining claims he was bedridden or incapacitated. Since the burden to show a prima facie case of undue influence lay on the plaintiffs and they produced only vague, unparticularized allegations, the shift of burden to the defendants never arose. The Court restored and upheld the High Court's view, dismissing the appeal.

Lesson Learnt

Simply being old, sick, or dependent on a relative is not, by itself, legal proof of undue influence over a property transaction: a person alleging undue influence must plead and prove specific facts showing how their free will was actually overborne, not just assert their relative's age or infirmity.

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

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