The Supreme Court of India has reaffirmed the legal sanctity of a registered will, holding that such a document carries a presumption of genuineness. The burden to prove otherwise lies squarely on the party disputing its validity.
The bench of Justice Vikram Nath and Justice Sandeep Mehta restored the ownership of a widow over a substantial portion of family land, which had earlier been reduced by the High Court.
The case revolved around ownership of approximately 18 acres of land situated across the villages of Dasnapur, Mavala, and Savaragaon in Andhra Pradesh. The dispute arose among legal heirs of Metpalli Rajanna, who had two children from his first marriage — Muthaiah and Rajamma — and no children from his second marriage with Lasum Bai.
In 1974, Rajanna executed a registered will, distributing the family property among his second wife (Lasum Bai), son (Muthaiah), and widowed daughter (Rajamma). The will specifically granted Lasum Bai 6 acres and 16 guntas of land, among other properties.
After Rajanna’s death in 1983, disputes emerged when Lasum Bai sold a portion of her share. Muthaiah challenged her right to alienate the property, claiming the land was ancestral and unpartitioned.
Initially, a suit filed by Muthaiah for injunction was decreed in his favour, but the court clarified that title issues remained open. Lasum Bai then filed a title declaration suit in 1991. The District Judge decreed the suit in her favour in 1994, recognizing the validity of the will and her exclusive ownership.
However, the Andhra Pradesh High Court partially overturned this decision in 2014. It held that the properties were joint family properties and granted 3/4th share to Muthaiah and only 1/4th to Lasum Bai, despite the existence of the will.
This led to two cross-appeals before the Supreme Court: one by Lasum Bai (through legal representatives after her death) and another by Muthaiah’s heirs seeking a complete nullification of her rights.
Supreme Court: Will Valid, Presumption in Favour of Genuineness
The Court emphasized the following key points:
Presumption of Genuineness: A registered will inherently carries a presumption of its authenticity unless proven otherwise. In this case, the will was registered in 1974 and acknowledged even by Muthaiah in his deposition.
Admissions Strengthen Case: Muthaiah not only identified his father’s signature on the will but also admitted to family arrangements under which Lasum Bai cultivated a separate portion of land. He acknowledged her possession and even the sale of 2 acres of the disputed land, which he never challenged.
Oral Family Settlement Valid: While technically unregistered, the oral family settlement was supported by consistent possession patterns and testimonies, making it legally enforceable under the facts.
Equitable Distribution: The will had not entirely deprived Muthaiah — he had in fact received the lion’s share of the property, disproving any malicious intent in its execution.
The Supreme Court ruled, “The High Court manifestly erred in interfering with the well-reasoned judgment of the trial court. The registered will, backed by possession and admission, is genuine and enforceable. The trial court’s decree in favour of Lasum Bai is restored.”
Case Details
Case Title: Metpalli Lasum Bai Versus Metapalli Muthaih(D)
Case No.: C.A. No(s). 5921 of 2015 with C.A. No(s). 5922 of 2015
Date: 21/07/2025
