Kiran Raj

The Supreme Court of India Division Bench of Justice Vikram Nath and Justice Sandeep Mehta allowed a civil appeal arising from a title dispute involving agricultural land, affirming the validity of a registered Will and oral family arrangement. The Court declared that the trial court was "fully justified in decreeing the suit for declaration and permanent injunction" and restoring absolute ownership over the suit property. The Court reversed the judgment of the High Court of Andhra Pradesh, which had limited the plaintiff’s share to one-fourth. Accordingly, the apex court upheld the rights of the purchaser who acquired property from the legatee through a registered sale deed.

The litigation stemmed from a dispute over 18 acres and 6 guntas of agricultural land located in the villages of Dasnapur, Mavala, and Savaragaon. The property was initially held by Metpalli Ramanna, who died intestate before 1949. His son, Metpalli Rajanna, succeeded to the property and had two children—Muthaiah and Rajamma—from his first marriage with Narsamma. After Narsamma's death, Rajanna remarried Lasum Bai, who had no children.

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Rajanna passed away in 1983. Subsequently, a conflict arose between Lasum Bai (second wife) and Muthaiah (son from the first marriage) regarding the ownership and possession of a specific portion of land admeasuring 4 acres and 16 guntas located in Survey No. 28 of Dasnapur village ("disputed property").

Lasum Bai claimed rights over the property based on a registered Will dated 24 July 1974 and an oral family arrangement made by Rajanna before his death. As per this arrangement, specific shares of land in different villages were distributed among Lasum Bai, Muthaiah, and Rajamma.

Muthaiah disputed the existence and validity of the Will and claimed that the entire property was joint ancestral property. He filed Original Suit No. 101 of 1987 seeking an injunction against Lasum Bai from alienating the land. Though the suit was decreed in Muthaiah’s favour, the court explicitly stated that the title of Lasum Bai was not adjudicated and that she was free to file a suit for declaration.

Lasum Bai subsequently instituted Original Suit No. 2 of 1991, seeking declaration of ownership and permanent injunction. She based her claim on the registered Will and oral family arrangement. The Will was produced as Ex.-A1.

During trial, Lasum Bai examined witnesses to prove the Will and her possession of the suit property. Muthaiah appeared as DW-1 and made several material admissions. In his cross-examination, he admitted: "My father allowed me to cultivate half of the land on the Southern side... my father asked her to cultivate 4 guntas of land in Mavala and asked me to cultivate 6 guntas... my father did this arrangement in the presence of elders." He also acknowledged the registered sale of 2 acres by Lasum Bai to Sanjeeva Reddy and confirmed that she was in possession of 4 acres and 16 guntas of land in Dasnapur.

The trial court decreed the suit on 15 November 1994. It held that the Will was proved and that Lasum Bai had exclusive title over the suit properties. The court also found that the oral family arrangement was credible and that the parties had acted upon it.

Muthaiah and Rajamma appealed to the High Court of Andhra Pradesh in Appeal Suit No. 178 of 1995. The High Court, vide judgment dated 23 January 2014, set aside the trial court’s findings. It held that the properties were joint family assets and that upon the deaths of Rajanna and Rajamma, Muthaiah was entitled to a 3/4th share, and Lasum Bai to only 1/4th. The High Court granted a preliminary decree for partition accordingly.

Lasum Bai passed away in 2015, after which Janardhan Reddy’s legal representatives—appellants in the present case—sought to represent her estate, claiming ownership through a registered sale deed dated 22 November 1994. A separate appeal was also filed by Muthaiah’s legal representatives challenging the 1/4th share awarded to Lasum Bai.

The Supreme Court examined the case in detail, focusing on the validity of the Will and oral family settlement. It recorded: "The Will is a registered document... the defendant-Muthaiah in his evidence, admitted the signatures as appearing on the said Will (Ext.-A1) to be that of his father."

The Court observed that the distribution of property under the Will was equitable and matched the oral family arrangement. "There is ample material on record to establish that M. Rajanna anticipated that the relations between plaintiff-Lasum Bai and defendant-Muthaiah were not congenial and that is why, in order to avoid future conflicts, he divided his properties."

The Bench recorded that "the Will not only confers the right and title over a part of the land owned by the Testator... but it also grants a lion’s share of the property to the defendant-Muthaiah." It reasoned that if the Will had been fabricated, it would not have favoured Muthaiah to such an extent.

Further, the Court underscored that the trial court had rightly accepted the Will based on credible evidence, and that "as the Will is a registered document, the burden would lie on the party who disputed its existence... to establish that it was not executed... or that there were suspicious circumstances."

The Court also relied on possession as corroborative evidence: "The evidence available on record fortifies the existence and persuasive nature of the oral family settlement which is countenanced by the factum of the possession of the suit schedule properties including the disputed property, which was admittedly with the plaintiff-Lasum Bai."

In conclusion, the Court stated: "We are of the firm view that the trial Court was fully justified in decreeing the suit... and granting her absolute rights over the suit schedule properties including the disputed property admeasuring 4 acres and 16 guntas."

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The Supreme Court reversed the High Court judgment dated 23 January 2014 in Appeal Suit No. 178 of 1995. It restored the decree passed by the District Judge, Adilabad in Original Suit No. 2 of 1991. The Court stated: "The judgment and decree dated 15th November, 1994 rendered by the trial Court is, consequently, restored."

It also noted: "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... Resultantly, the impugned judgment... does not stand to scrutiny and the same is hereby reversed and set aside."

Accordingly, Civil Appeal No. 5921 of 2015 was allowed, and Civil Appeal No. 5922 of 2015, filed by Muthaiah’s legal representatives, was dismissed. The Court passed no order on costs. All pending applications were disposed of.

Advocates Representing the Parties:

For Appellant(s): Mr. Guntur Prabhakar, AOR; Mr. Alakh Alok Srivastava, AOR; Mr. Rishabh Bafna, Adv.

For Respondent(s): Mrs. Anjani Aiyagari, AOR; Mr. Guntur Prabhakar, AOR; Mr. Alakh Alok Srivastava, AOR; Mr. Rishabh Bafna, Adv.

Case Title: Metpalli Lasum Bai (Since Dead) and Others vs. Metapalli Muthaiah (Dead) by LRs.

Neutral Citation: 2025 INSC 879

Case Number: Civil Appeal Nos. 5921–5922 of 2015

Bench: Justice Vikram Nath and Justice Sandeep Mehta