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

In the case of H. Venkatachala Iyengar v. B.N. Thimmajamma & Ors.2, a celebrated judgment with respect to the proof of Wills, the Supreme Court held that if the propounder significantly benefits from the will, this too is considered a suspicious circumstance requiring clear evidence for resolution. The relevant part of the judgment reads as under:

State Of Karnataka And Ors. vs M. Muniraju on 25 February, 2002

45.2 Section 60(c) of BSA, governs the admissibility of secondary evidence. It stipulates that secondary evidence may only be admitted when the party seeking to introduce it demonstrates that the original document is unavailable due to specific circumstances, such as loss or destruction. The Petitioner has failed to provide adequate proof of the unavailability of the original Will or to show that any such circumstances exist. Consequently, she has not met the burden of proof necessary to invoke the provisions of this section. The High Court of Karnataka in State of Karnataka v. M Muniraju4 held that the xerox copy of a document is inadmissible as it is not a substantive piece of evidence.
Karnataka High Court Cites 93 - Cited by 6 - V G Gowda - Full Document

Ashok Kothari vs Dipti Bavishi on 17 August, 2020

(ii) In Ashok Kothari v. Dipti Bavishi7 the probate was granted for a photocopy because the Court found that the Will was validly executed by the evidence presented, including the authenticated photocopy of the Will and testimony from attesting witnesses, established its 6 196 (2013) DLT 217 Signature Not Verified TEST.CAS. 69/2024 Signed By:MAHIMA Page 21 of 26 SHARMA Signing Date:27.08.2025 19:16:07 authenticity and compliance with legal requirements, including the contents of the Will which did not completely oust the daughter (Dipti) from the Will, making the intentions of the Testatrix clear. Most significantly, the Court therein observed that there was no real challenge to the signature of the testator on the authenticated photocopy of the Will. The challenge in the said matter was with respect to the mental capacity of the testator. The said facts are completely distinguishable and inapplicable to the case in hand.
Calcutta High Court Cites 37 - Cited by 0 - A Banerjee - Full Document
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