Jai Singh v. Shakuntala AIR 2002 SC 1428 (Case Summary)
In this significant ruling, the Supreme Court of India examined the scope of the statutory presumption under Section 16 of the Hindu Adoption and Maintenance Act, 1956. The case revolved around the validity of an adoption deed and whether the presumption of validity could be rebutted based on contrary evidence. The judgment delves into the nature of adoption and inheritance rights in the context of registered documents.
Facts of Jai Singh v. Shakuntala
- The dispute arose over the estate of SundaRam between his daughter, Shakuntala, and Jai Singh, who claimed to be Sunda Ram’s adopted son.
- Shakuntala sought a declaration of ownership of the suit land, challenging the validity of the adoption deed (dated June 1, 1973) and a will (dated February 14, 1974) as fraudulent and the result of misrepresentation.
- Jai Singh presented the registered adoption deed as proof of being Sunda Ram’s adopted son.
Issues framed
- Whether the statutory presumption under Section 16 of the Hindu Adoption and Maintenance Act, 1956, regarding the validity of a registered adoption deed, was applicable?
- Whether the evidence presented rebutted the presumption of validity of the adoption?
Subordinate Court Judgment
The trial court had ruled in favor of Shakuntala, declaring the adoption deed invalid.
Jai Singh’s appeals were dismissed by the first appellate court and the High Court, both upholding the trial court’s decision.
Judgment of Jai Singh v. Shakuntala
Section 16 of the Hindu Adoption and Maintenance Act, 1956 was central to the judgment. This section provides a statutory presumption that an adoption deed, if registered, is valid unless disproved.
The Supreme Court confirmed that while the presumption of adoption is valid under Section 16, it is rebuttable. The court held that evidence such as the voter list, chulha tax receipts, and other documents indicated that Jai Singh was still recognized as the natural son of Jage Ram after the alleged adoption.
Key Judgment (Para 16): “The presumption under Section 16 being a rebuttable presumption as the statute prescribes… the evidence available on record questions the validity of the adoption deed.”
The Supreme Court upheld the lower court decisions, dismissing the appeal filed by Jai Singh. The court held that the presumption of validity of the adoption deed had been rebutted based on the evidence presented. The appeal was dismissed without any order as to costs.
