Legal Validity of School Leaving Certificates in Property Disputes: Supreme Court’s Detailed Analysis

The Supreme Court of India recently adjudicated a crucial case concerning the admissibility of school leaving certificates as evidence in property disputes. The case, C. Doddanarayana Reddy (Dead) by LRs. & Ors. v. C. Jayarama Reddy (Dead) by LRs. & Ors., was an appeal against a Karnataka High Court ruling that had overturned the concurrent findings of the trial and first appellate courts. The primary legal question involved whether the school leaving certificate (Ex.P/1) submitted by the plaintiff could serve as reliable proof of age.

This case is significant because it establishes a precedent on the evidentiary value of school leaving certificates, especially in disputes involving claims of minority at the time of executing property documents. The Supreme Court thoroughly analyzed the legal provisions under the Indian Evidence Act, 1872, and relevant precedents to determine the validity of the plaintiff’s claims.

Background of the Case

The plaintiff, C. Jayarama Reddy, filed a suit for partition and separate possession, claiming a one-fourth share in the suit property. He argued that he was a minor when his father passed away in 1963, and thus, remained a member of the joint Hindu family entitled to a share in the ancestral property. The defendants, including his brothers and subsequent purchasers of the property, contested this claim.

The pivotal issue arose from a release deed dated 15th June 1963, allegedly executed by the plaintiff, wherein he relinquished his rights in exchange for Rs.5,000. The defendants maintained that the plaintiff was an adult at the time of execution and had voluntarily separated from the joint family.

Legal Issues Considered

The case presented two critical legal questions:

• Was the plaintiff a minor in 1963 when the release deed was executed?
• Did the release deed hold legal validity, or was it void due to the plaintiff’s alleged minority?

Trial Court’s Findings

The trial court examined the evidence presented by both parties and framed multiple issues, including the authenticity of the school leaving certificate and the legitimacy of the release deed. The key observations were:

• The plaintiff relied on Ex.P/1 (School Leaving Certificate) but failed to present any official from the issuing school.
• The certificate did not bear any authentication from the school headmaster or relevant authorities.
• The release deed, a registered document, clearly stated that the plaintiff was 22 years old at the time of execution.
• The plaintiff got married in June 1964, and the registered marriage certificate corroborated that he was an adult.

Based on these findings, the trial court dismissed the plaintiff’s suit, ruling that he was not a minor at the time of executing the release deed.

First Appellate Court’s Confirmation

The plaintiff appealed, challenging the trial court’s decision. The first appellate court re-evaluated the evidence but reached the same conclusion:

• The plaintiff had not challenged the release deed on grounds of fraud, coercion, or undue influence.
• The school leaving certificate alone could not serve as conclusive proof of age.
• The plaintiff’s claim was inconsistent with his subsequent actions, including receiving consideration for the release deed.

Thus, the first appellate court upheld the trial court’s decision, dismissing the plaintiff’s claims.

High Court’s Reversal

On a second appeal, the Karnataka High Court took a different view. It framed the question of law as:

“Whether the judgment and decree passed by the courts below suffer from illegality on account of improper consideration of Ex.P/1, i.e., school leaving certificate?”

The High Court ruled in favor of the plaintiff, reasoning that:

• The school leaving certificate was admissible under Section 35 of the Indian Evidence Act, 1872.
• The plaintiff’s minority status invalidated the release deed, making it unenforceable.
• The plaintiff could not be estopped from claiming his share in the property.

Supreme Court’s Verdict

Upon review, the Supreme Court overturned the High Court’s decision, reinstating the trial and appellate court’s findings. The court analyzed the admissibility and probative value of school leaving certificates under the Indian Evidence Act and referenced past judgments, including:

• Birad Mal Singhvi v. Anand Purohit – Entries in school registers require corroborative evidence.
• Madan Mohan Singh v. Rajni Kant – School records alone are insufficient to establish birth date.
• Ram Suresh Singh v. Prabhat Singh – Public documents must be proved in accordance with law.

The court concluded:

• The school leaving certificate was not a certified public document.
• The plaintiff failed to prove his date of birth as 8th April 1946.
• Concurrent findings of fact could not be interfered with in a second appeal.
• The release deed, a registered document, carried greater evidentiary value than the school certificate.

Accordingly, the Supreme Court allowed the appeal and dismissed the plaintiff’s suit.

Key Takeaways from the Judgment

This case underscores important legal principles:

1. School leaving certificates are not absolute proof of age: Courts require corroborative evidence.
2. Registered documents hold stronger evidentiary value: A duly executed and registered release deed is presumed valid.
3. Concurrent factual findings are binding: Second appeals should not interfere with factual conclusions unless there is clear illegality.
4. Section 35 of the Indian Evidence Act has limitations: Mere inclusion in official records does not ensure automatic admissibility.

Conclusion

The Supreme Court’s decision in this case establishes a vital precedent on the evidentiary value of school leaving certificates in property disputes. It reiterates the importance of proving such documents with corroborative evidence and upholding the legal sanctity of registered documents. This judgment will serve as a reference for future cases involving similar disputes over property rights and age verification.

Petitioner Name: C. Doddanarayana Reddy (Dead) by LRs. & Ors..
Respondent Name: C. Jayarama Reddy (Dead) by LRs. & Ors..
Judgment By: Justice Hemant Gupta, Justice S. Abdul Nazeer.
Place Of Incident: Karnataka.
Judgment Date: 14-02-2020.

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Download Judgment: C. Doddanarayana Red vs C. Jayarama Reddy (D Supreme Court of India Judgment Dated 14-02-2020.pdf

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