Lakshmi Amma vs. T. Narayana Bhatta||Case Summary||AIR 1970 SC 1367||Undue Influence

Undue Influence

FACTS

In Lakshmi Amma v. T. Narayana Bhatta, the issue was with regard to the validity of a deed of settlement signed by Narasimha Bhatta, a diabetic old man afflicted with other illnesses also. Incarcerated in a nursing home during 1955, he bequeathed almost all his properties to his elder grandson, T. Narayana Bhatta, thereby precluding his daughters and other grandchildren. The deed, though, retained a life interest in himself and provided for his wife, Lakshmi Amma. She had challenged the deed on the grounds that it was obtained by undue influence since Narasimha Bhatta was weak in body and mind. The trial court held in her favour and declared the deed to be invalid. The Kerala High Court overruled the same, holding that the deed was willingly executed. An appeal was made to the apex court.

ISSUES

Whether the settlement of the deed was executed in circumstances that deemed it invalid and void and whether this was a case of undue influence.

RELEVANT LAWS

Section 16(3) of the Indian Contract Act: A contract is held to be induced by 'undue influence' where the relationship between the parties stands such that one of the parties is in a position to control the will of the other and does so in order to secure an unfair benefit over the other. Whether the relationship is such that the dominating party holds authority over the other or if the contract is made with a person of affected mental capacity due to various reasons.

JUDGEMENT

The Supreme Court in Lakshmi Amma vs. T. Narayana Bhatta declared null and void a deed of settlement by an old and sick Narasimha Bhatta in favor of his eldest grandson. The Court ruled that the deed was acquired under undue influence since Bhatta was sick and weak, having no mental and physical faculties to make a free decision. As the deed unfairly favored one grandson at the expense of other heirs, it cast suspicion on its fairness. The Supreme Court overruled the Kerala High Court's judgment and restored the trial court's order, holding the deed to be void.

RATIO DECIDENDI

When an individual suffers from some sickness that leads him to a nursing home and then the individual makes documents to bequeath all his assets to one of his sons to the detriment of others, presuming about undue influence is considered appropriate.

Vinita Pathak