By Shantam Sharma and Ritvik Kashyap
Introduction
In India, matters of inheritance and property often lead to serious family disputes. A Will, which is meant to clearly show a person’s last wishes, can sometimes become the centre of conflict especially when emotions, family ties, and property are involved. In such cases, the legal system plays an important role in protecting the true intention of the person who made the Will, while also being fair to the family members who may have a claim. Over the years, Indian courts have developed careful ways to decide whether a Will is valid particularly when the Will is registered but someone still questions it or finds it suspicious. The Supreme Court, in the case of Metpalli Lasum Bai Since Dead And Ors vs Metpalli Muthaiah(D) By Lrs[1], has added another significant chapter to the evolving jurisprudence on succession law, reaffirming key principles regarding the evidentiary value of registered Wills and clarifying that the burden of proof lies on the party challenging its validity.
Facts
Metpalli Rajanna, the original owner of 18 acres and 6 guntas of land, had two children Muthaiah and Rajamma from his first wife, Narsamma. After her death, he married Lasum Bai, who remained childless. Rajanna passed away in 1983, followed by the intestate death of his daughter Rajamma, leading to a property dispute between his son Muthaiah and second wife Lasum Bai.
To avoid future conflicts, Rajanna had orally divided the property between Muthaiah and Lasum Bai and later executed a registered Will on 24th July, 1974; reaffirming this arrangement. As per the Will, both parties received 6 acres and 16 guntas each in the northern and southern parts of the Dasnapur village land.
Lasum Bai sold 2 acres from her share to Sanjeeva Reddy through a registered sale deed, which went unchallenged. She later entered into an agreement to sell her remaining 4 acres and 16 guntas to Janardhan Reddy. Objecting to this, Muthaiah filed a suit for injunction, claiming sole rights over the property as the surviving coparcener of the Hindu Undivided Family (HUF), arguing that it was ancestral property. In response, Lasum Bai filed a suit asserting ownership under the registered Will.
The Trial Court ruled in Lasum Bai’s favour, declaring her the rightful owner. However, on appeal, the Hon’ble Andhra Pradesh High Court reversed this decision, distributing the property under the Hindu Succession Act – 3/4th to Muthaiah and 1/4th to Lasum Bai. Following this, Lasum Bai appealed to the Hon’ble Supreme Court. After her death, the legal representatives of Janardhan Reddy continued the proceedings.
Judgement
The Hon’ble Supreme Court observed that since the will in question was a registered document, it carries with it a presumption of authenticity. Consequently, the responsibility to prove otherwise by showing improper execution or suspicious circumstances rests with the party contesting its validity.
In the present matter, the division of property aligned with a prior oral family settlement, and the registered will reflected the same terms. The defendant acknowledged both the signature of the testator, M. Rajanna, on the will and the fact that the plaintiff had possession of the portion allotted to her. Given these admissions and the lack of any credible challenge to the will’s legitimacy, its authenticity remained unquestioned.
The Trial Court, after correctly evaluating the evidence and applying established legal principles, rightly concluded in favour of Lasum Bai by granting her full ownership and permanent injunction.
Conclusion
The judgment in Metpalli Lasum Bai & Others vs. Metpalli Muthaiah (D) by LRs serves as a significant reaffirmation of the legal sanctity attached to registered Wills in India (for more information on benefits of registered will, kindly refer to: Secure Your Legacy: Why Registering Your Will Matters). By placing the burden of proof on the party challenging such a will, the Hon’ble Supreme Court has once again highlighted the importance of respecting a testator’s final wishes especially when those wishes are backed by formal documentation and consistent conduct. As inheritance disputes continue to surface in Indian families, this judgment strengthens the foundation for testamentary certainty and reinforces the principle that registered wills must be treated with the presumption of genuineness unless proven otherwise.
Srishti Kaushik, Legal Intern at S.S.Rana & Co. has assisted in the research of this article.
[1] 2025 INSC 879