Lakshmi Amma vs T. Narayana Bhatta Case Summary (1970 SC)


Lakshmi Amma vs T. Narayana Bhatta case is of the Indian Contract Act, 1872 which explains the concept of Undue Influence. In the case of Undue influence, the contract is voidable, as consent given by the party is not free and the party has the power to avoid the contract. To prove that the contract is induced by undue influence than certain condition needs to be fulfilled which are given under the same section.


Hon’ble Justice A.G. Shah, Hon’ble Justice K.Hegde, Hon’ble Justice A.N. Grover


Indian Contract Act: Section 16 which states the definition of Undue Influence.


  1. Plaintiff sued via his daughter and friend for the will which was executed by Respondent No. 1.
  2. Plaintiff has gifted his entire property to one of his grandsons who is respondent no. 1.
  3. Plaintiff has exclusive life interest over the property and has also made some provision for his wife i.e. Lakshmi Amma who is also an appellant in this case.
  4. Respondent claimed he has not executed the will under undue influence or when the plaintiff was in a weak state of find.


  • Whether the settlement of deed was executed in circumstances that deemed it invalid and void?


  • Where a person was suffering from a number of ailments which confined him in a nursing home and from there, he made a deed gifting all his properties to one of his sons to the exclusion of others, it was held that the presumption of undue influence was proper.


  • Supreme Court upheld the judgment of the trial court and quash the judgment given by the High Court which given in the favor of the judgment. It was held that the facts provided proof that the deed which was executed was genuine. The respondent failed to satisfy the court regarding the deed. The appeal was allowed with cost.

BEST BOOK FOR CONTRACT LAW: Contract Law by RK Bangia (Latest Edition)

INDIAN CONTRACT ACT, 1872 (Bare Act) (Latest Edition)

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