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H. Venkatachala Iyengar vs B. N. Thimmajamma & Others on 13 November, 1958

25.1. The objection on behalf of the appellant does not stand in conformity with the law declared in H. Venkatachala Iyengar and Rani Purnima Debi (supra) and scores of other decisions where this Court has consistently held that the probate proceeding is ultimately a matter of conscience of the Court; and irrespective of whether any plea in opposition is taken or not, a propounder of Will is required to satisfy the conscience of the Court with removal of all the suspicious circumstances. By the very nature and consequence of this proceeding, filing or non-filing of written statement or objections by any party pales into insignificance and is of no effect. The 67 probate proceeding is not merely inter-partes proceeding but leads to judgment in rem and, therefore, even when no one contests, it does not ipso facto lead to grant of probate. The probate is granted only on proof of Will as also on removal of suspicious circumstances, if there be any, to the final satisfaction of the conscience of the Court.

Ppk Gopalan Nambiar vs Ppk Balakrishnan Nambiar And Ors on 7 March, 1995

16. A Will is executed to alter the ordinary mode of succession and by the very nature of things it is bound to result in earlier reducing or depriving the share of natural heirs. If a person intends his property to pass to his natural heirs, there is no necessity at all of executing a Will. It is true that a propounder of the Will has to remove all suspicious circumstances. Suspicion means doubt, conjecture or mistrust. But the fact that natural heirs have either been excluded or a lesser share has been given to them, by itself without anything more, cannot be held to be a suspicious circumstance specially in a case where the bequest has been made in favour of an offspring. As held in P.P.K. Gopalan Nambiar v. P.P.K. Balakrishnan Nambiar and Ors.: [1995] 2 SCR 585, it is the duty of the propunder of the Will to remove all the suspected features, but there must be real, germane and valid suspicious features and not fantasy of the doubting mind. It has been held that if the propounder succeeds in removing the suspicious circumstances, the court has to give effect to the Will, even if the Will might be unnatural in the sense that it has cut off wholly or in part near relations. ….. In Rabindra Nath Mukherjee and Anr. v . Panchanan Banerjee (dead) by LRs. and Ors.: AIR 1995 SC 1684, it was observed that the circumstance of deprivation of natural heirs should not raise any suspicion because the whole idea behind execution of the Will is to interfere with the normal line of 62 succession and so, natural heirs would be debarred in every case of Will. Of course, it may be that in some cases they are fully debarred and in some cases partly.” 24.6.
Supreme Court of India Cites 1 - Cited by 194 - K Ramaswamy - Full Document

Surendra Pal & Ors vs Saraswati Arora & Anr on 9 August, 1974

It has also been held by Supreme Court in Surinder Pal vs. Saraswati Arora: (1974) 2 SCC 600 that where propounder takes prominent part in the execution of Will which confers on him a substantial benefit that is itself one of the suspicious circumstance which he must remove by clear evidence. In the present case no evidence is led by appellant to satisfy the conscience of the court to clear the aforesaid suspicious circumstance existing at the time of making of Will Ex.PW1/H. The propounder was required to remove the doubts by clear and satisfactory evidence.” 30 17.5. Turning on to the respondent No. 2 (son of the testatrix), the High Court found that absolutely no reason was provided in the Will for excluding him from the said immovable property and for limiting his benefit under the Will to the balance amount in the savings bank account of the testatrix. The High Court observed that though the appellant had deposed that there were strained relations between the testatrix and respondent No. 2 but, on the contrary, the witness PW-3 Major General Manjit Ahluwalia, son of sister of the testatrix, as also respondent No. 1 had deposed that their relations, in fact, were satisfactory. The High Court again referred to the documentary evidence as regards regular maintaining of good relations between the testatrix and her son, like those of birthday card and the family photographs, and observed that if at all there were strained relations, the testatrix would not have even bequeathed any amount to her son. Again, after a thorough analysis of the evidence on record, the High Court found that there was no sufficient evidence of strained relations between the testatrix and her son to such an extent that she would have excluded him from her immovable property. Hence, the exclusion of respondent No. 2 from bequeath was also taken to be that of a grave suspicious circumstance casting doubt on the genuineness of the Will in question. The High Court, inter alia, observed,-
Supreme Court of India Cites 11 - Cited by 175 - P J Reddy - Full Document

B. Venkatamuni vs C.J. Ayodhya Ram Singh & Ors on 19 October, 2006

20.4. The learned counsel has relied on the decisions of this Court in B. Venkatamuni v. C.J. Ayodhya Ram Singh & Ors. : (2006) 13 SCC 449; H. Ventakachala Iyengar; and Rani Purnima Debi (supra) amongst 49 others, to submit that the Probate Court can investigate into the matter of a Will despite the fact that the signature found thereon has been proved or ingredients of Section 68 of the Evidence Act has been complied with.
Supreme Court of India Cites 17 - Cited by 150 - S B Sinha - Full Document
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