Landmark Supreme Court Judgements Related To Wills

Wills, often perceived as simple documents, hold immense legal and emotional weight. They are the final wishes of an individual regarding the distribution of their earthly possessions after their demise. In India, the law governing wills is primarily encapsulated in the Indian Succession Act, 1925 (ISA), with specific provisions for Hindus, Sikhs, Jains, and Buddhists under Section 30 of the Hindu Succession Act, 1956 (HSA). While the fundamental principles are clear, the complexities of human relationships, property disputes, and evolving societal norms often lead to intricate legal battles. The Supreme Court of India, as the apex judicial authority, has played a pivotal role in interpreting these laws, laying down crucial precedents that guide the lower courts and ensure justice.

In this blog, you will get to read about different Supreme Court Judgements Related to Wills in various situations, such as:

• Testamentary Capacity and Due Execution.
• Suspicious Circumstances.
• Interpretation of Wills.
• Revocation and Alteration of Wills.
• Probate and Letters of Administration.

Testamentary Capacity And Due Execution

The validity of a will hinges on two primary pillars: the testator's capacity to make a will and the proper execution of the will as per legal mandates.

Testamentary Capacity: Sound Mind and Free Will

Section 59 of the Indian Succession Act, 1925 clearly states that "Every person of sound mind not being a minor may dispose of his property by Will." The concept of "sound mind" is crucial. It doesn't mean perfect mental health, but the ability to understand the nature of the act of making a will, the extent of the property being disposed of, and the persons who are the natural objects of the testator's bounty.

The Supreme Court has repeatedly emphasized that the testator must be of sound disposing mind and capable of understanding the nature and effect of the dispositions at the time of execution.

H. Venkatachala Iyengar v. B.N. Thimmajamma

In the case of H. Venkatachala Iyengar v. B.N. Thimmajamma, the Court observed that if there are "suspicious circumstances" surrounding the execution of the will, the propounder must remove those suspicions to the satisfaction of the court.

Parties:

• Appellant: H. Venkatachala Iyengar (the sole executor of the alleged will of Lakshmamma)
• Respondents: B.N. Thimmajamma and others (relatives of the testatrix, challenging the will's validity)

Facts: The appellant, as the executor, filed a suit seeking a declaration that Lakshmamma was the absolute owner of certain properties and had the right to dispose of them via a will executed on August 22, 1945. The suit also sought consequential reliefs to implement the bequests. The respondent, Lakshmamma's daughter-in-law, contested the will, alleging coercion and questioning Lakshmamma's mental capacity at the time of execution. Evidence showed the appellant played a prominent role in preparing the will, which included substantial bequests to his sons. There was also a lack of clear evidence that the testatrix had approved the draft or fully understood the will's contents.

Issues: The central issue was the validity and due execution of the will. Specifically, the court had to determine:

1. Whether the testatrix, Lakshmamma, had signed the will.
2. Whether she possessed a sound disposing mind at the time of execution.
3. Whether she understood the nature and effect of the dispositions made in the will.
4. Whether she signed the will of her own free will.
5. Whether the suspicious circumstances surrounding the will's execution had been adequately explained by the propounder.

Judgment: The Supreme Court upheld the High Court's decision, dismissing the appellant's appeal. The Court reiterated that while a will generally needs to be proved like any other document, the propounder bears a heavy onus, especially when "suspicious circumstances" exist. Such circumstances include a propounder taking a prominent role in the will's execution and receiving substantial benefits under it, or the testatrix's feeble mental state, or unnatural dispositions. In this case, the appellant's prominent role and the substantial benefits to his sons, coupled with the lack of convincing evidence regarding the testatrix's full understanding and free will, created significant suspicion. The Court found that these suspicious circumstances were not adequately removed by the propounder, leading it to conclude that the will was not genuinely and validly executed. This landmark judgment emphasized the need for courts to be satisfied that the will is the product of the testator's free volition and not influenced by others.

Shashi Kumar Banerjee v. Subodh Kumar Banerjee

In the case of Shashi Kumar Banerjee v. Subodh Kumar Banerjee, it was reiterated that the onus is on the propounder to prove the will, and if there are suspicious circumstances, they must be dispelled.

Parties:

• Appellants: Shashi Kumar Banerjee and others (propounders of the will, seeking its probate).
• Respondents: Subodh Kumar Banerjee and others (sons and descendants of the testator, opposing the will).

Facts:

The dispute revolved around the will of Ramtaran Banerjee, a wealthy 97-year-old lawyer, who died on April 1, 1947. The will was purportedly executed on August 29, 1943, when he was 93 years old. The appellants sought probate of this will. The respondents challenged its validity, claiming improper execution, lack of genuineness, diminished testamentary capacity of the testator, and undue influence/fraud. The District Judge granted probate, finding the testator had a sound mind and the will was duly executed. However, the High Court reversed this, largely relying on expert handwriting evidence suggesting the signature was not from 1943.

Issues:

The primary issues before the Supreme Court were:

1. Whether the will was duly executed and attested as required by law.
2. Whether the testator had the necessary testamentary capacity at the time of execution.
3. Whether there were suspicious circumstances surrounding the will's execution that required explanation by the propounders.
4. The weight to be given to expert handwriting evidence versus the testimony of attesting witnesses.

Judgment:

The Supreme Court reversed the High Court's decision and upheld the probate of the will. The Court reiterated established principles regarding the proof of wills:

• The onus of proving the will lies on the propounder.
• If there are no suspicious circumstances, proof of testamentary capacity and the testator's signature suffices.
• However, if suspicious circumstances exist (e.g., propounder taking a prominent role, unnatural dispositions, testator's mental condition), the propounder must explain them to the court's satisfaction.
• The Court emphasized that expert handwriting evidence is opinion evidence and generally cannot override the clear testimony of attesting witnesses unless there are compelling reasons to do so.

Due Execution and Attestation

Section 63 of the Indian Succession Act, 1925, prescribes the essential formalities for the execution of an unprivileged will:

• The testator shall sign or shall affix his mark to the will, or it shall be signed by some other person in his presence and by his direction.
• The signature or mark of the testator, or the signature of the person signing for him, shall be so placed that it shall appear that it was intended thereby to give effect to the writing as a will.
• The will shall be attested by two or more witnesses, each of whom has seen the testator sign or affix his mark to the will, or has seen some other person sign the will in the presence and by the direction of the testator, or has received from the testator a personal acknowledgment of his signature or mark, or the signature of such other person; and each of the witnesses shall sign the will in the presence of the testator, but it shall not be necessary that more than one witness be present at the same time, and no particular form of attestation shall be necessary.

Section 68 of the Indian Evidence Act, 1872, deals with the proof of execution of documents required by law to be attested. It mandates that if a document is required by law to be attested, it shall not be used as evidence until at least one attesting witness has been called for the purpose of proving its execution, if an attesting witness is alive and subject to the process of the court and capable of giving evidence.

Meena Pradhan v. Kamla Pradhan & Ors.

In the case of Meena Pradhan v. Kamla Pradhan & Ors., the Court reaffirmed that a will, even if executed mere days before death, can be legally valid if it complies with the statutory requirements of Section 63 of the Indian Succession Act and Section 68 of the Indian Evidence Act.

Parties:

• Appellants: Meena Pradhan and others (first wife and her children of the deceased, Bahadur Pradhan)
• Respondents: Kamla Pradhan and others (second wife and her daughter of the deceased, Bahadur Pradhan)

Facts: Bahadur Pradhan, the deceased, had two wives: Meena Pradhan and Kamla Pradhan. He had children from both marriages. Seven days before his death on July 30, 1992, Bahadur Pradhan executed a Will bequeathing all his assets to Kamla Pradhan and their daughter, Ritu, effectively excluding Meena Pradhan and her children. The Will was attested by two witnesses, though only one (Suraj Bahadur Limboo) was examined in court. After Bahadur Pradhan's death, Meena Pradhan challenged the Will's authenticity, alleging forgery, suspicious circumstances, and the testator's unsound mental state.

Issues: The central issue before the Supreme Court was whether the Will executed by Bahadur Pradhan was validly proved in accordance with the statutory requirements of the Indian Succession Act, 1925 (Section 63) and the Indian Evidence Act, 1872 (Section 68), particularly concerning proper attestation and the absence of suspicious circumstances.

Judgment: The Supreme Court, upholding the decisions of the lower courts, dismissed Meena Pradhan's appeal. The Court reaffirmed that for a Will to be proved valid, the propounder must satisfy the "prudent mind" test, demonstrating that the testator signed the Will out of his own free will, with a sound mind, and understanding its nature and effect. The Court emphasized strict compliance with statutory requirements, particularly attestation by at least two witnesses, one of whom must be examined in court if alive and capable. It held that mere exclusion of certain family members or preferential treatment does not automatically create suspicion. The Court found that the attesting witness's testimony adequately proved the Will's execution and that the appellants failed to provide sufficient evidence to establish suspicious circumstances, fraud, or undue influence. The judgment stressed that "suspicious circumstances" must be real and germane, not merely speculative. Consequently, the Will's validity was upheld, and consequential benefits were directed to be disbursed as per its terms.

Shivakumar v. Sharanabasappa

In the case of Shivakumar v. Sharanabasappa, it was reiterated that suspicious circumstances must be "legitimate, real, and germane" to the execution of the will and not based on mere conjectures or surmises.

Parties:

• Appellants/Plaintiffs: Shivakumar and others (claiming as legatees under a Will).
• Respondents/Defendants: Sharanabasappa and others (contesting the Will).

Issues: The central issue was the genuineness and validity of a Will dated May 20, 1991, allegedly executed by Sri Sangappa Shettar, which bequeathed properties to the plaintiffs. The court also considered whether a trust created by the defendants, which included the suit properties, was binding on the plaintiffs.

Facts: The plaintiffs filed a civil suit seeking declaration of ownership and injunction over properties, claiming rights based on a Will executed by Sri Sangappa Shettar. The Trial Court initially ruled in favor of the plaintiffs, upholding the Will's authenticity. However, the High Court reversed this decision, finding numerous "suspicious circumstances" surrounding the Will's execution, leading them to conclude it was not genuine. These circumstances included the use of different colored papers, inconsistent placement of signatures, varying pen types, and the absence of signatures on certain pages. The High Court also noted that the propounders failed to adequately explain these discrepancies. The plaintiffs then appealed to the Supreme Court.

Judgment: The Supreme Court upheld the decision of the High Court, dismissing the appeal. The Court meticulously reviewed the evidence and concurred with the High Court's finding that the Will was not genuine due to the numerous unexplained suspicious circumstances and discrepancies in its execution. The Supreme Court emphasized the principle that while courts do not approach a Will with inherent doubt, they must examine it cautiously and with circumspection, especially when suspicious circumstances are present. The propounder of the Will bears the burden of removing all legitimate suspicions before the document can be accepted as genuine. In this case, the plaintiffs failed to dispel the doubts regarding the Will's authenticity.

Presence Of Suspicious Circumstances

The presence of "suspicious circumstances" often forms the core of challenges to a will. The Supreme Court has consistently held that while a will is a sacred document, courts must exercise "judicial conscience" when dealing with suspicious circumstances.

Jasbir Kaur v. Amrit Kaur

In the case of Jasbir Kaur v. Amrit Kaur, the Court clarified that the registration of a will, while offering a presumption of validity, does not make it immune to challenges.

Parties:

• Plaintiff/Appellant: Smt. Jaswant Kaur (one of the wives of the deceased)
• Defendant/Respondent: Smt. Amrit Kaur & Ors. (including a grandson of the deceased)

Facts: The case concerned the estate of Sardar Gobinder Singh Sibia, who passed away in 1954. He had two wives, Gulab Kaur (mother of Jaswant Kaur) and Dalip Kaur. After Gobinder Singh's death, his widow Gulab Kaur filed a suit claiming maintenance and a share in his properties. The defendant, Surjit Inder Singh (a grandson), presented a will purportedly executed by Gobinder Singh, which bequeathed the entire estate to him, largely excluding Jaswant Kaur. The Trial Court decreed the plaintiff's suit, holding the will invalid. The High Court reversed this, upholding the will.

Issues: The central issues revolved around:

1. The burden of proving the validity of a will, especially when surrounded by suspicious circumstances.
2. The interplay between customary laws and the Hindu Succession Act, 1956, in determining succession rights.
3. The standards courts should apply when assessing suspicious circumstances concerning testamentary documents.

Judgment: The Supreme Court, allowing the appeal, set aside the High Court's judgment and held the will to be invalid. The Court emphasized that in cases where the execution of a will is "shrouded in suspicion," the propounder (the party asserting the will) bears a heavy burden to remove all legitimate suspicions before the document can be accepted as the last will of the testator. The Court found several suspicious circumstances, including the delayed revelation of the will, inconsistencies in the attesting witnesses' testimonies, and the unnatural exclusion of other natural heirs without clear justification. The judgment reiterated the principle that the court must be satisfied that the will reflects the true intentions of the testator.

Indore Development Authority v. Manohar Lal

The case Indore Development Authority v. Manohar Lal reinforces the broader principle that courts must look at the substance and intent behind legal documents. In the context of wills, this means not just a mechanical application of rules, but an assessment of the testator's true wishes, especially when suspicious circumstances are alleged.

Parties:

• Petitioner: Indore Development Authority
• Respondents: Manohar Lal and others (landowners/subsequent purchasers)

Facts: The core of the case revolved around the interpretation of Section 24(2) of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 (2013 Act). This provision deals with the lapse of land acquisition proceedings initiated under the repealed Land Acquisition Act, 1894. A key question was whether the deposit of compensation by the government in the treasury could be considered "paid" under Section 24(2) to prevent the proceedings from lapsing. This issue had led to conflicting judgments by three-judge benches of the Supreme Court, particularly between Pune Municipal Corporation v. Harakchand Misirmal Solanki (2014) and an earlier Indore Development Authority v. Shailendra (2018) judgment. The Pune Municipal Corporation case held that compensation not deposited in the landowner's account or with the court would lead to a lapse, while Indore Development Authority (2018) stated that tendering compensation was sufficient, even if refused by the landowner.

Issues:

1. What is the correct interpretation of Section 24(2) of the 2013 Act, specifically the conjunction "or" in the phrase "physical possession of the land has not been taken or the compensation has not been paid"? Should it be read as disjunctive ("or") or conjunctive ("and"/"nor")?
2. Whether the non-deposit of compensation in court, especially when refused by the landowner, leads to the lapse of land acquisition proceedings.
3. Whether a judge who has expressed an opinion in a smaller bench on a referred matter can hear the case in a larger bench.

Judgment: A five-judge Constitution Bench of the Supreme Court, in its judgment delivered on March 6, 2020, overturned the Pune Municipal Corporation decision. The Court held that for land acquisition proceedings to lapse under Section 24(2) of the 2013 Act, both conditions must be met: physical possession of the land must not have been taken and compensation must not have been paid. The "or" in Section 24(2) should be read as "nor" or "and" in this specific statutory context. The judgment clarified that tendering compensation by the State is sufficient to discharge its obligation, and it is not mandatory to deposit the compensation in court if the landowner refuses to accept it. A deposit in the treasury would not cause the acquisition to lapse. The non-deposit in court would only attract a higher rate of interest as per Section 34 of the 1894 Act, not a lapse of proceedings. The judgment also addressed the issue of a judge's recusal, upholding the judge's right to decide on recusal.

Interpretation Of Wills: Ascertaining The Testator's True Intent

The language used in a will can sometimes be ambiguous, leading to disputes over the testator's actual intentions. The Supreme Court has developed a nuanced approach to interpreting wills, prioritizing the testator's wishes over strict literal interpretations.

Navneet Lal v. Gokul

In the case of Navneet Lal v. Gokul, the Court held that the primary duty of the court is to ascertain the intention of the testator from the words used in the will. The will must be read as a whole, and effect must be given to every part of it, if possible. Where there are conflicting clauses, later clauses generally prevail over earlier ones, but only if an attempt to reconcile them fails.

Facts: The case concerned the interpretation of a will executed by one Bhola Chaubey, who was childless and governed by Mitakshara School of Hindu Law. Bhola Chaubey had a strained relationship with his brother and nephew. His will stipulated that his wife, Smt. Jarian, would be in possession and enjoyment of his property during her lifetime. Crucially, it also stated that after his wife's death, his sister's son, Gokul, would become the "Malik Kamil" (absolute owner) with full proprietary and transfer powers, and would perform his obsequies. After Bhola Chaubey's death, Smt. Jarian and Gokul initially lived cordially, but later their relationship soured. Smt. Jarian subsequently executed a gift deed and a will of some properties in favor of Navneet Lal (the appellant). This led Gokul to file a suit claiming his rights under Bhola Chaubey's will, which Navneet Lal contested, arguing that Smt. Jarian had received an absolute estate and thus had the right to alienate the property.

Issues:

1. Did the will of Bhola Chaubey confer an absolute estate or merely a life estate upon his wife, Smt. Jarian?
2. What is the correct interpretation of the term "malik" (owner) when used in a will, particularly when there are subsequent provisions giving absolute ownership to another person?

Judgment: The Supreme Court of India, in its judgment delivered on December 9, 1975, upheld the decision of the Allahabad High Court, ruling in favor of Gokul. The Court held that the will, when read as a whole and considering the surrounding circumstances (like the testator's strained relations with his brother's family and his desire for Gokul to perform obsequies), clearly indicated an intention to grant only a life estate to Smt. Jarian and an absolute estate to Gokul after her death.

The Court emphasized that while "malik" generally denotes absolute ownership, its meaning can be restricted by the context of the entire document. To interpret the will as granting an absolute estate to the widow would create repugnancy with the subsequent clear bequest of absolute ownership to Gokul, and would also lead to the property eventually passing to the very relatives the testator sought to exclude. The Supreme Court reinforced the principle that the cardinal rule in construing a will is to ascertain the testator's intention from the entire document, avoiding interpretations that render any part inoperative or contradict the overall scheme of the will. Therefore, Smt. Jarian's gift deed and will in favor of Navneet Lal were held invalid.

Revocation And Alteration Of Wills: The Ambulatory Nature

A distinctive feature of a will is its "ambulatory" nature, meaning it can be revoked or altered at any time by the testator during their lifetime. Section 70 of the Indian Succession Act, 1925, outlines the methods of revocation of unprivileged wills:

• By marriage of the maker (subject to exceptions under Section 69, which states that every will shall be revoked by the marriage of the maker, except a will made in exercise of a power of appointment, when the property over which the power of appointment is exercised would not, in default of such appointment, pass to his or her executor or administrator, or to the person entitled in case of intestacy).
• By another will or codicil.
• By some writing declaring an intention to revoke the same and executed in the manner in which an unprivileged will is required to be executed.
• By the burning, tearing, or otherwise destroying the same by the testator or by some person in his presence and by his direction with the intention of revoking it.

Rupinder Singh v. Sita Devi

The case Rupinder Singh v. Sita Devi touched upon the application of Section 70 ISA. While the general rule is that marriage revokes a will, the Court observed that the application of this section might be subject to the religion/faith of the testator and restrictions contained in Section 57 and 58 of the ISA. For Hindus, Buddhists, Sikhs, and Jains, Section 57 makes certain provisions of Part VI (Testamentary Succession) of the ISA applicable, but with the rider that marriage shall not revoke the will or codicil.

Parties:

• Appellant: Rupinder Singh
• Respondents: Sita Devi (since deceased) through her Legal Representatives (LRs) and another (likely the allotting authority).

Facts: Sita Devi, the mother, filed a suit seeking declaration, possession, and mandatory injunction concerning a booth. This booth had been allotted to her son, Varinder Kumar, on a leasehold basis in 1993. Varinder Kumar later experienced mental health issues and passed away in 2009, leaving behind his mother (Sita Devi) and his son, Karan, as legal heirs. Sita Devi sought to have the property transferred to her and Karan's names.

However, Rupinder Singh (the appellant-defendant) claimed ownership and possession of the booth based on several documents allegedly executed by Varinder Kumar in his favor on August 14, 1995. These included an Agreement to Sell, an Irrevocable Registered General Power of Attorney (GPA), a Registered Will, an Affidavit, and an Indemnity Bond. Sita Devi contended that these documents were forged and fabricated.

A crucial point of contention was whether the Will executed by Varinder Kumar in favor of Rupinder Singh stood revoked due to Varinder Kumar's subsequent marriage in 1999.

Issues:

1. Whether the possession of the booth was legally transferred to Rupinder Singh via the documents executed by Varinder Kumar (Agreement to Sell, GPA, Will, Affidavit, Indemnity Bond).
2. Whether the irrevocable GPA was protected under Section 202 of the Indian Contract Act, 1872, even after the death of the donor (Varinder Kumar).
3. Whether the transfer of possession in favor of Rupinder Singh could be protected under Section 53A of the Transfer of Property Act, 1908.
4. Whether the Will executed by Varinder Kumar in favor of Rupinder Singh was revoked by Varinder Kumar's subsequent marriage, in light of Section 57 of the Indian Succession Act, 1925 (which applies to Wills made by Hindus).

Judgment: The High Court of Punjab and Haryana, in a judgment dated December 21, 2023, allowed Rupinder Singh's appeal, setting aside the judgments and decrees of the lower courts (dated September 9, 2016, and March 24, 2023).

The High Court ruled in favor of Rupinder Singh on all key issues:

• It held that possession of the booth was handed over to Rupinder Singh under the executed documents, noting that the Agreement to Sell explicitly stated this.
• The Court affirmed that an irrevocable GPA, protected by Section 202 of the Indian Contract Act, is not terminated by the death of the donor.
• It found that the alleged transfer of possession to Rupinder Singh was indeed protected under Section 53A of the Transfer of Property Act.
• Crucially, the Court held that the Will in favor of Rupinder Singh was not revoked by Varinder Kumar's subsequent marriage. It specifically referred to Section 57 of the Indian Succession Act, 1925, which provides that marriage shall not revoke a Will made by a Hindu.

Probate And Letters Of Administration: Authentication And Authority

Probate is the legal process by which a will is proved in a court of law and accepted as a valid public document. Letters of Administration are granted by the court when a person dies intestate (without a will) or when a will is made but no executor is appointed.

Krishan Kumar Sharma v. Rajesh Kumar Sharma

In the case Krishan Kumar Sharma v. Rajesh Kumar Sharma, the Supreme Court clarified that an application for grant of probate or letters of administration is not a suit where the applicant asserts or claims a right. Rather, the applicant seeks recognition from the court to perform a duty as an executor or administrator.

Parties:

• Appellant: Krishan Kumar Sharma (step-brother of the respondent)
• Respondent: Rajesh Kumar Sharma (propounder of the Will)

Facts: The case concerned a dispute over the Will of Smt. Sneh Prabha Sharma, the deceased mother of Rajesh Sharma and step-mother of Krishan Kumar Sharma. Rajesh Sharma, the propounder, sought a probate for the Will dated July 13, 1989, which was registered on September 11, 1989. Smt. Sneh Prabha Sharma died on July 9, 1990. The probate court initially dismissed the petition as time-barred, holding that Article 137 of the Limitation Act, 1963, which prescribes a three-year limitation period, applied to probate petitions. This decision was challenged in the High Court, which held that the Limitation Act did not apply to probate proceedings and that the right to apply for probate was a recurring one. This led to an appeal to the Supreme Court.

Issues:

1. Whether Article 137 of the Limitation Act, 1963, applies to a petition for the grant of probate or letters of administration under the Indian Succession Act, 1925.
2. If the Limitation Act applies, when does the "right to apply" for probate or letters of administration accrue?

Judgment: The Supreme Court, in its judgment dated March 27, 2009, overturned the High Court's decision and held that Article 137 of the Limitation Act, 1963, indeed applies to applications for the grant of probate or letters of administration. The Court clarified that while a probate petition seeks recognition from the court to perform a duty (as an executor or administrator), and not to assert a right in the traditional sense, it still falls under the ambit of "applications" as per Article 137. Regarding the accrual of the "right to apply," the Supreme Court held that the right would accrue when it becomes necessary to apply. This means that the limitation period does not necessarily begin from the date of the testatrix's death. However, any delay beyond three years after the deceased's death would raise suspicion, and a greater delay would warrant greater suspicion, requiring a proper explanation. The judgment essentially brought probate petitions under the purview of general limitation law, emphasizing that while it's a continuing right, undue delay needs justification.

Conclusion

The Supreme Court of India, through its numerous pronouncements, has meticulously built a robust legal framework around wills. These landmark judgments serve as guiding principles, ensuring that the last wishes of a testator are respected while upholding the sanctity of legal processes and preventing fraud or undue influence. The emphasis on proof of due execution, the removal of suspicious circumstances, and the paramount importance of ascertaining the testator's true intent form the bedrock of testamentary law in India. While each case presents unique facts, the principles established by these judgments provide clarity and consistency, empowering individuals to plan their legacy with confidence and ensuring a fair and equitable distribution of their assets.

Disclaimer: The information provided here is for general informational purposes only and should not be construed as legal advice. For personalized legal guidance, please consult with a qualified civil lawyer.