Kali Bakhsh Singh vs Ram Gopal Singh on 27 November, 1913
"In the case of a deed executed by a purdanashin lady the law protects her by demanding that the burden of proof shall in such cases rest not with those who attack, but with those who rely on the deed; and it must be proved affirmatively and conclusively that the deed was not only executed by, but was explained to and really understood by, the grantor. Ordinarily the Courts insist on proof that the lady had independent legal advice, and though this is not an absolute and invariable rule--although there may be exceptions where the lady was shown to have business capacity and strength of will and where the deed is shown to be in the circumstances not an unnatural disposition of her property as in Kali Bakhsh Singh v. Ram Gopal Singh, 41 Ind App 23 (PC) (B), the general rule is that save in such exceptional cases the Courts will demand affirmative proof on the subject of the lady's intelligent understanding and execution of a deed and will not readily hold this onus to have been discharged where it is not shown that the lady had any independent advice."