Saroj Agarwalla (Dead) Thr. LR Abhishek Agrawalla v. Yasheel Jain
Background
The appellant sought probate of a will allegedly executed by her deceased brother. Two separate people filed "caveats" (formal objections) to block the probate: a man claiming to be the testator's nephew who also produced a photocopy of what he said was an earlier, different will naming him a beneficiary, and a woman claiming to be the testator's second wife. The appellant asked the court to reject (discharge) both caveats as filed by people with no real interest in the estate; the Calcutta High Court refused, allowing both caveats to stand, and the appellant challenged that ruling before the Supreme Court.
Decision Breakdown
The Supreme Court explained that a "caveatable interest" exists if granting probate of the will in question would prejudice the caveator's own claim to the estate through some other line of succession. Applying this test, it agreed that the nephew's claim, based on a prior, different will under which he says he was a beneficiary, and the alleged widow's claim both met this threshold, even though neither claim had yet been conclusively proven; a probate court only needs a prima facie, tentative basis at this stage, not final proof. The Court also clarified that a probate court's job is limited to verifying a will was validly executed and signed with a sound mind, not deciding who the rightful heirs ultimately are. Both appeals were dismissed, upholding the High Court's decision that the caveats could stand and go to trial.
Lesson Learnt
To object to someone's will being granted probate, you don't need to conclusively prove your rival claim to the estate upfront: a reasonable, prima facie basis (such as a photocopy of an earlier will, or a disputed marriage claim) is enough to earn the right to contest the matter at trial.