In Brief
Hardei, an elderly illiterate woman, allegedly gifted land to her relatives Gian Chand and Dhanbir via a registered deed in 1985. After her death in 1991, they sued for declaration of ownership. The lower courts rejected their claim, finding the deed was false because Hardei had denied executing it during her lifetime, was dependent on Keshav (who eventually possessed the land), and the plaintiffs took no possession steps for years. The High Court reversed this, focusing on the formal execution and registration. The Supreme Court upheld the trial court's judgment, holding that concurrent findings on a gift deed's invalidity—based on holistic examination of all circumstances, the executant's age, illiteracy, dependence, and lifetime denial—cannot be reversed merely on formal presumptions. The burden lay on the plaintiffs to prove voluntariness."
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