Tuesday, 30 December 2014

SUPREME COURT DECISION ON ‘WILL’

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Execution of a can is needed to be evidenced in terms of the provisions of Section 63(c) of the Indian Succession Act and Section 68 of the Indian evidence Act. In Janki Narayan Bhoir v. Narayan Namdeo Kadam, [(2003) two SCC 91], whereas addressing the question in an elaborate way, the Hon'ble Supreme Court has command as under: 

“To say can has been punctually executed, the necessity mentioned in Clauses (a), (b) and (c) of Section 63 of the  Succession Act are to be complied with i.e., The individual has got to sign or affix his mark to the desire, or itought to be signed by another person in his presence and by his direction; 

The signature or mark of the individual, or the signature of the person linguistic communication at his direction, has got to seem at an area kind that it may seem that by that mark or signature the document is meant to own result as a will

The most necessary purpose with that we have a tendency to are presently involved during this attractiveness, is that the desire has got to be documented by 2 or additional witnesses and every of those witnesses should have seen the individual sign or affix his mark to the desire, or should have seen another person sign the desire within the presence and by the direction of the individual, or should have received from the individual a private acknowledgement of signature or mark, or of the signature of such different person, and every of the eleven witnesses has got to sign the desire within the presence of the individual." 

As regards compliance of the availability of Section 68 of the evidence Act, it absolutely was opined:
"In a way, Section 68 offers a concession to those that need to prove and establish a can in an exceedingly Court of law by examining a minimum of one attesting witness despite the fact that can has got to be documented a minimum of by 2 witnesses obligatorily underneath Section63 of the Succession Act. However what's vital and to be noted is that one attesting witness examined ought to be in an exceedingly position to prove the execution of a can. to place in different words, if one attesting witness will prove execution of the desire in terms of Clause (c) of Section 63, viz., attestation by 2 attesting witnesses within the manner contemplated in this, the examination of different attesting witness are often distributed with. The one attesting witness examined, in his proof has got to satisfy the attestation of a can by him and therefore the different attesting witness so as to prove there was due execution of the desire. 


If the attesting witness examined besides his attestation doesn't, in his proof, satisfy the wants of attention of the need by different witness conjointly it falls wanting attestation of will a minimum of by 2 witnesses for the easy reason that the execution of the desire doesn't simply mean the signing of it by the individual however it suggests that fulfilling and proof of all the formalities needed underneath Section63 of the Succession Act. wherever one attesting witness examined to prove the desire underneath Section sixty eight of the proof Act fails to prove the due execution of the desire then the opposite obtainable attesting witness has got to be referred to as to supplement his proof to form it complete altogether respects. Wherever one attesting witness is examined and he fails to prove the attestation of the desire by the opposite witness there'll be deficiency in meeting the necessary needs of Section sixty eight of the evidence Act."


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