The Supreme Court of India, in a judgment delivered on July 21, 2025, has upheld the validity of a registered Will and an oral family settlement in a long-standing property dispute among the legal heirs of Metpalli Rajanna. A bench of Justices Vikram Nath and Sandeep Mehta reversed a judgment by the High Court of Judicature of Andhra Pradesh, restoring a trial court decree that had granted a declaration of title and permanent injunction in favour of the testator’s second wife. The Court held that the defendant’s admission of the testator’s signature on the registered Will, coupled with evidence of an oral family arrangement, was sufficient to establish the plaintiff’s claim.
Background of the Case
The dispute arose over the properties of Metpalli Rajanna, who died in 1983. The properties were originally owned by his father, Metpalli Ramanna, who died intestate before 1949. Rajanna had two children, Muthaiah and Rajamma, from his first marriage to Narsamma, who predeceased him. He later married Lasum Bai, the original plaintiff, with whom he had no children.
Following Rajanna’s death, a dispute over property rights emerged between his second wife, Lasum Bai (plaintiff), and his son, Muthaiah (defendant). The plaintiff, Lasum Bai, contended that to avoid future conflicts, M. Rajanna had made an oral family arrangement and also executed a registered Will on July 24, 1974, distributing his properties among her, his son Muthaiah, and his widowed daughter Rajamma.
Under this arrangement, Lasum Bai was granted rights over 6 acres and 16 guntas of land in Survey No. 28 of Dasnapur Village. She subsequently sold 2 acres from her share to one Sanjeeva Reddy via a registered sale deed on August 27, 1987, which was never challenged by the defendant. Later, she entered into an agreement to sell the remaining 4 acres and 16 guntas (the “disputed property”) to Janardhan Reddy.
This led defendant-Muthaiah to file an injunction suit (Original Suit No. 101 of 1987), which was decreed in his favour on July 6, 1990, restraining Lasum Bai from selling the property. However, the court in that suit noted that Lasum Bai was free to file a separate suit for declaration of title. Consequently, she filed Original Suit No. 2 of 1991, seeking a declaration of her title over the properties bequeathed to her in the Will.
Arguments of the Parties
Plaintiff’s Submissions (Lasum Bai, represented by legal heirs of purchaser Janardhan Reddy): The plaintiff’s case rested on the registered Will (Ext.-A1) and the oral family settlement. It was argued that the defendant, Muthaiah, had admitted the signature of his father, M. Rajanna, on the Will. Furthermore, his failure to challenge the earlier sale of 2 acres to Sanjeeva Reddy amounted to acquiescence, estopping him from questioning Lasum Bai’s right to sell the property.
Defendant’s Submissions (Muthaiah, represented by his legal heirs): The defendant contended that the properties were joint ancestral properties and that his father had died intestate, making him the sole co-parcener of the Hindu Undivided Family (HUF). He claimed the Will was a “got up document.” He argued that M. Rajanna could not have executed the Will for the entire property as it was not his self-acquired property. He further submitted that the judgment in the earlier injunction suit had attained finality, rendering the subsequent sale deed in favour of Janardhan Reddy invalid.
Trial Court and High Court Decisions
The District Judge, Adilabad (trial Court), decreed the suit in favour of plaintiff-Lasum Bai on November 15, 1994. The trial court found that the plaintiff had established that M. Rajanna had executed the Will in a sound disposing state of mind. It relied on the defendant’s admission in his deposition where he not only identified his father’s signatures on the Will but also confirmed the separate cultivation and possession of lands as per the family arrangement.
However, on appeal, the High Court of Judicature of Andhra Pradesh, in its judgment dated January 23, 2014, set aside the trial court’s decree. The High Court held that the properties were joint family properties and determined that defendant-Muthaiah was entitled to a 3/4th share, while plaintiff-Lasum Bai was entitled to only a 1/4th share.
Supreme Court’s Analysis and Final Decision
The Supreme Court, after hearing both appeals, sided with the reasoning of the trial court. The bench, in its judgment authored by Justice Sandeep Mehta, made several key observations.
The Court noted that the Will was a registered document, which carries a “presumption regarding genuineness thereof.” The burden to prove it was not genuine fell on the defendant, Muthaiah. The Court found he failed to do so, particularly in light of his own testimony. The judgment states:
“The defendant-Muthaiah in his evidence, admitted the signatures as appearing on the said Will (Ext.-A1) to be that of his father, i.e., M. Rajanna… He also admitted the fact that the plaintiff-Lasum Bai was in possession of 6 acres and 16 guntas of land, which fell into her share as per the Will.”
The Court further held that the evidence on record fortified the existence of an oral family settlement, which was supported by the “factum of the possession of the suit schedule properties.”
The genuineness of the Will was also supported by its contents, as it granted a “lion’s share of the property to the defendant-Muthaiah.” The Court reasoned that if the Will had been manipulated, the defendant could have been excluded entirely.
Concluding its analysis, the Supreme Court held that the trial court was justified in its findings. The bench stated:
“The High Court, manifestly erred while interfering with the well-reasoned judgment of the trial Court and substituting its own findings by reducing the share of plaintiff-Lasum Bai in the suit schedule properties.”
The Supreme Court allowed the appeal filed on behalf of the late plaintiff-Lasum Bai and the purchasers, and dismissed the appeal filed by the legal representatives of the late defendant-Muthaiah. The High Court’s judgment was reversed and set aside, and the trial court’s decree from November 15, 1994, granting absolute rights to Lasum Bai over the suit properties, was restored.
