In Brief
Sultana Begum sought review of a Supreme Court order dismissing her writ petitions against the rejection of applications under Section 65 of the Indian Evidence Act. The core dispute was whether two property agreements (dated 1981 and 1982) were family settlements requiring no registration or stamp duty, or conveyance deeds requiring both. The Court held that substance prevails over nomenclature: since the documents transferred co-owner rights for valuable consideration (₹40,000), they operated as conveyances regardless of being labelled as family settlements. The Court relied on established precedent that a document's true legal character is determined by its recitals and operative effect, not its stated name. The review petitions were dismissed.
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