ASOKAN versus LAKSHMIKUTTY & ORS.

ASOKAN versus LAKSHMIKUTTY & ORS.

A recital of handing over possession in a registered gift deed raises a presumption of acceptance, and overt proof or express acceptance is not necessary. Onus to show non-acceptance or non-possession lies on the donor; once gift is complete, it cannot be rescinded based on subsequent conduct of donee.

Parties
Appellant: Asokan; Respondents: Lakshmikuty and Ors.
Jurisdiction
India
Judgment Date
14 December 2007
Procedural Posture
Civil Appeal / Appeal From High Court Judgment
Outcome
Appeal allowed
Legal Topics
Gift, Proof of Acceptance, Registered Deed, Recitals in Deed, Presumption of Acceptance, Sections 122 and 123 Transfer of Property Act, Sections 91 and 92 Evidence Act

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Parties

Asokan

Appellant

Lakshmikuty and Ors.

Respondents

Procedural Posture

Civil Appeal / Appeal From High Court Judgment

  1. 1 Whether recital of handing over possession in a gift deed is sufficient proof of acceptance by the donee to constitute a valid gift
  2. 2 Whether plea against recitals in deed of gift is permissible under Sections 91 and 92 of Evidence Act
  3. 3 Whether subsequent conduct of donee allows rescinding a completed gift

Ratio Decidendi

A recital of handing over possession in a registered gift deed raises a presumption of acceptance, and overt proof or express acceptance is not necessary. Onus to show non-acceptance or non-possession lies on the donor; once gift is complete, it cannot be rescinded based on subsequent conduct of donee.

Court Disposition

Appeal allowed

Orders

  • Judgment of High Court and First Appellate Court set aside
  • Judgment of Trial Court restored