Fraudulent Will Cannot Override Legal Heirs' Rights: Allahabad High Court Rejects Appeal, Declares Will Invalid

A Will Must Stand the Highest Standard of Scrutiny, Especially When Surrounded by Suspicious Circumstances - In a crucial ruling Allahabad High Court, Lucknow Bench, dismissed the second appeal filed by Juggi Lal, challenging the cancellation of a Will allegedly executed in his favor. The Court held that the lower courts had rightly concluded that the execution of the Will was surrounded by suspicious circumstances, casting serious doubts on its authenticity.

Rejecting the appellant’s plea, the Court ruled that "when a Will is marred by serious doubts, it is the duty of the propounder to dispel all suspicions with convincing evidence. A Will that unfairly excludes legal heirs, particularly without justification, cannot be upheld by law."

"Judicial Scrutiny Confirms Guru Prasad as the Legal Heir, Will Found Fraudulent"
The appellant had argued that Guru Prasad was not the biological son of Lodhe, the testator, and therefore had no claim over his estate. He submitted documents, including a Pariwar Register entry and other records, suggesting that Guru Prasad was the son of Chhedi and Mata Dei. The Court, however, found that these claims were baseless, ruling that "the evidence overwhelmingly establishes Guru Prasad as Lodhe’s legitimate son, and the appellant’s attempt to challenge his parentage is unfounded."

The Court took note of the High School Certificate, caste certificate, and money order receipts proving that Guru Prasad was consistently recognized as Lodhe’s son. It observed that "when official records and past financial transactions indicate a clear parental relationship, mere contradictions in the Pariwar Register do not carry sufficient weight to overturn this fact."

"Undue Influence and Fraudulent Intent Render the Will Invalid"
Scrutinizing the execution of the disputed Will, the Court found multiple red flags that raised serious doubts about its legitimacy. It observed that Lodhe, an illiterate and physically weak man, was suffering from serious illness for over a year before his death. The Will excluded his legally wedded wives and biological children without any justification, granting absolute ownership of all assets to the appellant.

Holding that such an unnatural disposition of property is a major ground for suspicion, the Court ruled that "when a Will makes an unjustified departure from the natural line of succession, the burden on the propounder increases manifold. The failure to provide any reason for completely disinheriting the rightful heirs points towards coercion or fraud."

Examining the credibility of the attesting witnesses, the Court found that they were habitual witnesses in land disputes and had a history of appearing in multiple property transactions. Finding their testimonies unreliable, the Court ruled that "when attesting witnesses lack credibility, the authenticity of the Will itself is called into question."

"Failure to Provide for Family Strengthens Doubts About the Will’s Legitimacy"
Observing that the testator had made no provisions for his wives or son, the Court held that "it is inconceivable that a man would disinherit his family without reason. The complete exclusion of dependents, without explanation, strongly suggests manipulation or undue influence in the execution of the Will."

Referring to Supreme Court precedents in Dhannulal v. Ganeshram and Meena Pradhan v. Kamla Pradhan, the Court reiterated that "proof of a Will demands a higher degree of scrutiny than ordinary documents. When suspicious circumstances exist, the burden lies on the propounder to establish that the testator executed the Will with full understanding and free will."

"Lower Court’s Findings Were Legally Sound, No Justification for Interference"
The appellant contended that the lower appellate court had failed to frame specific points for determination under Order 41 Rule 31 of the CPC, making its judgment defective. Rejecting this claim, the High Court ruled that "while the appellate court did not separately frame issues, it meticulously analyzed the trial court’s findings and recorded detailed observations. The judgment substantially complied with procedural requirements and does not warrant interference."

The Court cited the Supreme Court’s ruling in Mrugendra Indravadan Mehta v. Ahmedabad Municipal Corporation, which held that "even if points for determination are not explicitly framed, an appellate judgment is valid as long as all relevant issues are considered and reasoned conclusions are drawn."

"Fraudulent Will Declared Null and Void, Appeal Dismissed"
Dismissing the appeal, the Court ruled that "the findings recorded by the lower courts regarding the fraudulent execution of the Will and the rightful claim of Guru Prasad as the legal heir are legally sound. The appellant has failed to establish the validity of the Will, and the appeal stands dismissed."
The Allahabad High Court has reaffirmed that "a Will must be free from all suspicion to be legally enforceable. When serious doubts arise regarding its execution, the burden to establish its legitimacy falls entirely on the propounder."

By rejecting an untrustworthy Will that unjustly excluded legal heirs, the Court has ensured that "fraudulent claims do not override the rightful inheritance of legitimate heirs. The law must protect against manipulation and coercion in property succession matters."
 

Date of Decision: 28 February 2025