Introduction
On 21 July 2025, the Supreme Court of India delivered a significant judgment in Metpalli Lasum Bai (since dead) & Ors. v. Metapalli Muthaih (D) by LRs., reported as 2025 INSC 879. The case concerned rival claims of legal representatives over ancestral agricultural land in Andhra Pradesh. The Court’s ruling reaffirmed that a registered Will carries a presumption of proper execution and authenticity, thereby shifting the burden of proof to the party disputing its validity. The decision has broad implications for probate law, family settlements, and the evidentiary value of registered documents. This article examines the background of the dispute, the issues before the Court, the reasoning of the bench, and the legal principles underlying the presumption attached to a registered Will.
Factual Background
The dispute centred on 4 acres 16 guntas of agricultural land originally owned by Metpalli Ramanna, who died intestate before 1949 . His son Metpalli Rajanna inherited the property and married twice—first to Narsamma, with whom he had two children: Muthaiah (defendant) and Rajamma . After Narsamma’s death, Rajanna married Lasum Bai (plaintiff), who remained childless . Rajanna passed away in 1983; his daughter Rajamma also died intestate .
Anticipating possible disputes among his heirs, Rajanna allegedly orally partitioned his properties, giving specific parcels to each family member. He also executed a registered Will on 24 July 1974, bequeathing certain lands to Lasum Bai while recognising Muthaiah’s share . Lasum Bai sold part of her share via a registered sale deed in 1987, which remained unchallenged . However, when she attempted to sell the remaining 4 acres 16 guntas, Muthaiah filed an injunction suit, claiming the land was joint family property and that he was the sole coparcener after Rajanna’s death . The trial court decreed in Lasum Bai’s favour, but the Andhra Pradesh High Court reversed this judgment, reducing her share to one‑quarter and granting Muthaiah three‑quarters . Dissatisfied, Lasum Bai appealed to the Supreme Court.
Issues Before the Supreme Court
1. Validity and Genuineness of the Registered Will – Whether the registered Will executed by Metpalli Rajanna in 1974 was genuine and duly executed.
2. Burden of Proof – Whether the presumption of genuineness attached to a registered Will shifts the burden of proof to the party challenging it.
3. Effect of Oral Family Settlement – Whether the oral family arrangement, supported by the Will, validly partitioned the ancestral property among the heirs.
4. Interference by the High Court – Whether the High Court erred in overturning the trial court’s findings on factual appreciation and law.
Reasoning and Legal Principles
Presumption of Genuineness of Registered Wills
The bench of Justice Vikram Nath and Justice Sandeep Mehta held that a registered Will carries a strong presumption of genuineness. Citing the established principle that registration raises a presumption that official acts are regularly performed, the Court observed that “the Will, is a registered document and thus there is a presumption regarding genuineness thereof” . Consequently, the burden of proof lies on the person disputing the Will to show that it was not executed properly or that there were suspicious circumstances . This presumption is grounded in Section 114 of the Indian Evidence Act, which allows courts to presume the regularity of official acts and the authenticity of registered documents.
Evidence of the Contesting Party
The Court noted that Muthaiah (the defendant) admitted in his testimony that the signatures on the registered Will were those of his father, Rajanna . He also acknowledged that Lasum Bai was in possession of 6 acres 16 guntas—the share allotted to her under the Will . These admissions undermined his challenge to the Will and supported the presumption of genuineness. As the Will benefitted both the plaintiff and the defendant, the Court found it implausible that Rajanna intended to deprive his son and thus dismissed allegations of manipulation .
Oral Family Settlement and Consistent Partition
In addition to the Will, the Court considered oral evidence regarding the family settlement. The distribution under the oral arrangement closely matched the terms of the registered Will . The Court reasoned that possession patterns, with each party cultivating their respective portions, fortified the existence and credibility of the oral settlement . Together, the Will and the family arrangement evidenced a fair and voluntary partition of the ancestral property .
Restoration of Trial Court’s Findings
The Supreme Court criticised the High Court for interfering with the trial court’s well‑reasoned judgment. It emphasised that appellate courts should exercise restraint in disturbing concurrent findings of fact unless there is perversity or misapplication of law. Given the clear evidence supporting the Will and the family settlement, the trial court’s decree granting Lasum Bai absolute rights over the disputed land was restored . The High Court’s judgement was set aside, and the appeal filed by Muthaiah was dismissed .
Legal Significance
Presumption under the Evidence Act
The ruling reinforces the rebuttable presumption that accompanies registered Wills. Illustration (e) to Section 114 of the Evidence Act allows courts to presume that official acts have been properly performed. Registration of a Will is an official act carried out by the registrar; hence a registered Will is presumed to be duly executed unless evidence proves otherwise. The Court clarified that although registration alone does not cure all defects, it shifts the evidentiary burden to the challenger. This presumption encourages parties to register testamentary documents, thereby adding credibility and minimising litigation.
Balancing Testamentary Freedom and Family Claims
The judgment strikes a balance between a testator’s freedom to distribute property and the rights of family members in Hindu undivided families. By upholding the oral family settlement corroborated by a registered Will, the Court recognised informal arrangements made to prevent future disputes. It also highlighted that succession disputes cannot override voluntary partitions undertaken by the patriarch, especially when the distribution is equitable and acknowledged by the beneficiaries.
Guidance for Future Litigation
This case provides important guidance for litigants and practitioners:
1. Importance of Registration – Parties intending to execute Wills or family settlements should ensure registration to avail the presumption of genuineness and shift the burden of proof.
2. Consistency of Evidence – Possession and conduct consistent with the terms of a Will strengthen its validity. Admissions by contesting parties can be decisive.
3. Limited Appellate Interference – Appellate courts should be cautious in reversing concurrent findings of trial courts, particularly in fact‑intensive cases like succession disputes.
Conclusion
The Supreme Court’s decision in Metpalli Lasum Bai v. Metapalli Muthaih underscores the evidentiary strength of registered Wills and the judicial preference for respecting family settlements. By restoring the trial court’s decree and emphasising the presumption of genuineness attached to the registered Will, the Court reaffirmed that the burden of proof lies on the challenger to demonstrate fraud, undue influence, or suspicious circumstances . This ruling not only resolves a decades‑old family dispute but also provides clarity on the procedural safeguards available under Indian law to ensure the authenticity of testamentary documents.