A Trial Must Seek the Truth, Not Exclude Those Who Have a Right to Be Heard: Supreme Court Allows Daughter to Challenge Alleged Will

No Justification to Shut the Door on a Legal Heir Contesting the Estate – Supreme Court, In a significant ruling upheld the right of a legal heir to challenge an alleged will, dismissing an appeal that sought to exclude a daughter from contesting her mother’s estate. The case, Pappammal (Died) Through LR R. Krsna Murtii v. Jothi & Anr., centered around a dispute where a son, claiming exclusive inheritance through a registered will, attempted to block his sister from participating in the legal proceedings.

The Supreme Court, in a bench comprising Justices Sudhanshu Dhulia and Prashant Kumar Mishra, firmly rejected this attempt, stating:

“The entire purpose of a trial is to reach the truth of the matter, and it is absolutely important that all necessary parties must be heard before a decision is taken by the Court.”

The dispute arose over the estate of Pappammal, who passed away on January 10, 2020, at the age of 97 years. Before her death, she had initiated a civil suit for declaration and recovery of possession, which was being pursued on her behalf by her son, R. Krsna Murtii, as her power of attorney holder.

Following her demise, Murtii sought to be substituted as the sole legal representative, claiming that his mother had executed a registered will on June 13, 2016, bequeathing her entire estate exclusively to him. However, his sister Jothi, challenged the will, alleging that it was fabricated and fraudulent, and sought to be impleaded in the case to assert her rights as a legal heir.

The Trial Court initially rejected Murtii’s substitution application, citing the absence of a legal heir certificate and the fact that other heirs were not impleaded. The Madras High Court upheld this decision, but granted Murtii the opportunity to bring all heirs on record.

When Murtii appealed to the Supreme Court in 2022, the Court ruled that his substitution as plaintiff should not have been denied outright, but did not bar other heirs from contesting the estate.

Jothi, subsequently, filed an application to be impleaded as a defendant in the suit, which was allowed by the Trial Court and later affirmed by the Madras High Court. Murtii then moved the Supreme Court once again, arguing that his sister had no right to be part of the proceedings.

 “A Legal Heir Cannot Be Shut Out from Seeking Justice”
The Supreme Court firmly rejected Murtii’s contention, holding that a legal heir cannot be excluded from asserting their rights in a dispute over inheritance.

“It is not correct to contend that the presence of other legal heirs is unnecessary. If a will is disputed, those with a potential interest in the estate must be allowed to participate in the proceedings.”

Murtii had relied on the Supreme Court’s 2022 ruling, claiming that since he was allowed to be substituted as plaintiff, his sister could not challenge his claim. The Bench dismissed this argument, clarifying:

“Our previous ruling merely restored the appellant’s substitution application for reconsideration. It did not say that no other person has the right to challenge the will or assert a claim in the estate.”

The Court further observed that Pappammal was 94 years old when the alleged will was executed, raising serious concerns about its authenticity. The justices remarked:

“The validity of a will, particularly one executed by a person in advanced age, cannot be determined without hearing all interested parties. Justice demands that all voices be considered before arriving at a conclusion.”

“A Will Can Be Contested in a Pending Suit, Probate is Not a Precondition”
Murtii had also contended that Jothi should have initiated separate probate proceedings instead of seeking impleadment in the civil suit. The Supreme Court rejected this argument outright, stating that a will’s validity can be contested within the suit itself.

“Where the authenticity of a will is questioned, the correct course is to allow the challenge within the existing legal proceedings rather than forcing parties into multiple rounds of litigation.”

The Court emphasized that a probate application is not mandatory for contesting inheritance rights, particularly when the will is already under dispute in an ongoing civil case.

“A Trial Cannot Ignore Parties Who Have a Stake in the Dispute”
Reaffirming the principle that a trial must be a quest for truth, the Court held that denying Jothi’s impleadment would amount to blocking a rightful claimant from being heard. The judgment noted:

“The insistence that Respondent No.1 (Jothi) should not be impleaded is wholly erroneous. A court cannot render justice while ignoring an interested party’s claim. A will is not sacrosanct merely because it is registered—its authenticity must be examined in the presence of all heirs.”

The Supreme Court concluded that the Madras High Court and the Trial Court were correct in allowing Jothi to participate in the proceedings, as she had a direct and legitimate interest in the estate.

 “A Dispute Over Inheritance Cannot Be Resolved in a One-Sided Manner”
Dismissing Murtii’s appeal, the Supreme Court upheld the Madras High Court’s decision, ruling that:

Jothi’s impleadment was legally justified, as she had a direct interest in the estate.
Murtii had no exclusive right over the suit proceedings based solely on the alleged will.
The Trial Court must proceed with the case after hearing both parties and determining the validity of the will.
The Supreme Court reaffirmed that inheritance disputes must be adjudicated fairly and inclusively, ensuring that no party is unjustly denied the opportunity to contest their rights.

 “Inheritance Claims Must Be Decided on Their Merits, Not Through Exclusion”
This judgment serves as a clear precedent that a legal heir cannot be arbitrarily excluded from an inheritance dispute. It reinforces the principle that justice requires all affected parties to be heard, particularly when the validity of a will is in question.

By upholding the daughter’s right to contest the will, the Supreme Court has ensured that estate disputes are resolved through an open and fair judicial process, rather than through selective exclusion of interested parties.

Date of Decision : 07/03/2025