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  • provisions of the Indian Evidence Act,
  • 49 I. Section 54, s.c. 24
  • 44 I. Section 98, s.c. 19
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Citation Codes
Equivalent Citations
citation codes
Case Number
Judges
Acts
  • provisions of the Indian Evidence Act,
  • 49 I. Section 54, s.c. 24
  • 44 I. Section 98, s.c. 19
Smart Summary

Summary of the Opinion

Factual and Procedural Background

The appellant (originally the plaintiff in the suit) is the hereditary mutwalli of an ancient wakf of large extent. He sued the defendants for possession of extensive lands, claiming they were wakf property which he was entitled to resume.

The defendants contended that the lands were held under an ancient istimrari (mukarari) tenure: a permanent, heritable tenure held for a long though indefinite time at a fixed rent. They relied on documentary and circumstantial proof of long continued possession and recognition of the tenure, including descriptions of the tenure as istimrari mukarari in 1859 and 1902, long series of rent receipts described similarly, sale in Court auctions for rent arrears, and the fact that in 1869 the then mutwalli unsuccessfully sued for enhancement of rent.

The plaintiff replied that the defendants could produce no grant or lease establishing a permanent tenure and that a mutwalli cannot alienate wakf lands or grant a permanent tenure at a fixed rent; thus the alleged permanent tenure could not be valid.

In the trial court the Subordinate Judge declined to presume any lawful origin (such as leave of a Kazi) for the tenure; on appeal the High Court (Greaves J., Mukerji J. concurring) assumed that, given the long unchallenged existence of the lease and related circumstances, the grant was originally lawful and reversed the decree for possession. The present appeal was brought against that High Court conclusion to their Lordships' Board.

Legal Issues Presented

  1. Whether, in the absence of direct proof of origin, a court may presume a lawful origin (specifically an unrecorded leave or permission of a Kazi under Mahomedan law) for a long, uninterrupted istimrari/mukarari tenure over wakf lands, thereby completing the defendants' title against the mutwalli's claim.
  2. Whether the existence of an Imperial sanad (1772) expressly reserving to the mutwalli no competence to grant istimrari/mukarari or low-jama leases precludes the presumption of a subsequent unrecorded lawful permission (e.g., Kazi's leave) validating the tenure.
  3. Whether the decision in Bawa Magniram Sitaram v. Kasturbhai Manibhai (the Board's earlier decision) applies to this case, or whether it can properly be distinguished (for example on the ground that that case concerned a Hindu mutt rather than a Mahomedan wakf).

Arguments of the Parties

Appellant's Arguments (Plaintiff / Hereditary Mutwalli)

  • The defendants have no grant or lease to support a claim of permanent tenure; their payments of rent at an unchanging rate do not establish a permanent grant.
  • As mutwalli of a wakf the appellant (and predecessors) could not alienate wakf lands or grant a permanent tenure at a fixed rent; therefore any purported permanent tenure is invalid.
  • Where an express imperial sanad (dated 1772) declares that the mutwalli is "not competent to give istimrari or mukarari or lease at a low jama to any person" that documentary restriction is the real legal origin and precludes presuming a lawful permission to alienate.

Respondents' Arguments (Defendants / Tenants)

  • The long-continued, unchallenged possession, descriptions of the tenure as istimrari mukarari in records (1859, 1902), series of rent receipts, sales in court auctions for arrears, and failed rent-enhancement litigation (1869) amount to ordinary and prima facie sufficient proof of a permanent tenure.
  • To complete their title where the tenure has been enjoyed for many years the law should presume some lawful origin — in Mahomedan law this may be an exception allowing, with the leave of the Kazi, an otherwise unlawful alienation by a mutwalli.
  • The presumption of a lost or unrecorded lawful permission (for example, Kazi's leave) is appropriate to explain the existence of such a long-continued tenure where documentary proof of origin is absent.

Table of Precedents Cited

Precedent Rule or Principle Cited For Application by the Court
Bawa Magniram Sitaram v. Kasturbhai Manibhai (1921) L.R. 49 I. Section 54; s.c. 24 Bom. L.R. 584 The Board relied on the principle that, when a permanent lease has existed unchallenged for a very long time and it is impossible to trace the original circumstances, the court may presume the existence of a lawful origin (including necessity or permission) to secure quiet possession. The Board treated this decision as directly relevant and applied the same presumption in the present case; it observed that in Bawa the presumption was applied without debating circumstances because of the long lapse of time, and used that as authority for presuming a lawful origin here.
Choclcalingam Pillai v. Mayandi Chettiar (1896) I.L.R. 19 Mad. 485 Established the exception permitting permanent alienation of temple property where necessity is proved, and supported the proposition that, failing actual proof of necessity, such necessity may be presumed in appropriate cases. The Board relied on Choclcalingam Pillai as a precedent for presuming necessity (or lawful origin) when direct proof is lacking; the opinion notes that in Choclcalingam much was known about the original circumstances and that the presumption there was supported by evidence of the context of the original grant.
Murugesam Pillai v. Maniokavasaka Pandara (1917) L.R. 44 I. Section 98; s.c. 19 Bom. L.R. 456 The doctrine of presuming a lawful origin to support long possession was invoked, though in that case the interval between the impugned grant and the suit was shorter (about 25 years) than in other cited cases. The Board noted this case as another instance where the presumption doctrine was invoked but also pointed out that the shorter interval there limited how readily the presumption could be applied; the present Board contrasted that with the much longer period here.

Court's Reasoning and Analysis

The Board undertook a layered analysis:

  1. It identified and examined earlier authorities (principally Bawa Magniram Sitaram and Choclcalingam Pillai) where courts had, to secure quiet possession and on policy grounds, presumed a lawful origin (such as necessity or official permission) for very long uninterrupted tenures when direct evidence of origin was lost by lapse of time.
  2. The Board explained the legal nature of the presumption: it is not merely a rule of evidence but a substantive presumption based on the failure of actual evidence and on the policy of securing quiet possession. Consequently, Section 114 of the Indian Evidence Act (as relied on by the appellant) does not prevent the court from drawing such a presumption where circumstances warrant it.
  3. The Board cautioned that the presumption must be reasonable and practicable: it is not to be made capriciously nor invoked as an automatic entitlement of a particular class of possessor. The court must be satisfied that the particular lawful title presumed is one that was practicable and consistent with the probabilities and applicable law.
  4. The Board then examined the specific documentary obstacle raised by the appellant: a sanad of 1772 of Emperor Shah Alam granting the trusteeship to an ancestor of the appellant, with an express declaration that the mutwalli "is not competent to give istimrari or mukarari or lease at a low jama." The Board assessed whether that sanad precluded presuming a lost and unrecorded permission (such as Kazi's leave) as the origin of the defendants' tenure.
  5. Considering the terms of the sanad and the broader historical context, the Board concluded that the sanad did not abrogate the general rules of Mahomedan law (which included the possibility of relaxation by a Kazi) and that it was reasonably clear the wakf pre-dated the sanad and was subject to long-established Mahomedan rules. They noted tangible evidence of antiquity (inscriptions on buildings) and the remoteness of the relevant period, which reduced the force of the appellant's objection to presumption.
  6. The Board rejected the appellant's argument that it was unreasonable to presume an unrecorded Kazi permission within comparatively modern times. Instead, they observed that while Kazi permissions may be rare in modern times, historically they could have been common, and it would be speculative to assume the opposite when the law records such a rule and the facts point to long-established practice.
  7. Finally, the Board considered whether Bawa (a case concerning a Hindu mutt) could be distinguished on communal grounds and concluded there was no principled basis for introducing distinctions between communities in applying the presumption. Accordingly, the Board accepted the High Court's presumption as proper and sufficient to complete the defendants' title.

Holding and Implications

Holding: The appeal is dismissed with costs.

Implications (direct consequences as discussed in the opinion):

  • The Board upheld the High Court's presumption of a lawful origin (specifically, the plausibility of an unrecorded permission of the Kazi under Mahomedan law) to complete the defendants' title to the long-continued istimrari/mukarari tenure, thereby defeating the appellant's claim to possession.
  • The Board indicated that the doctrine applied in earlier authorities (including Bawa Magniram Sitaram and Choclcalingam Pillai) is applicable in principle across communities, and that purposeless distinctions between communities in this area of law would be undesirable.
  • The decision affirms that where long, peaceful, and uncontested possession exists and direct evidence of origin is lacking, a court may (subject to reasonableness and consistency with probabilities and law) presume an appropriate lawful origin rather than automatically invalidate the tenure; the presumption must, however, be practicable and not contravene the probabilities of the case.

This summary strictly follows the reasoning, findings, and consequences as stated in the provided opinion and does not add information beyond that text.

    Mahammad Mazaffar Al Musavi v. Jabeda Khatun

    1. The appellant in this case was plaintiff in the suit. He is the hereditary mutwalli of an ancient wakf of large extent, and he claimed from the defendants possession of extensive lands, as property of the wakf, which he was entitled to resume. The defendants' answer was that the lands were an ancient istimrari tenure, held for a long though indefinite time at a fixed rent and as heritable property, of the appellant's predecessors, who had not only never contested the title, but had frequently acknowledged it by various overt acts. Other defences of limitation and estoppel were raised, but they need not now be considered. In substance, the facts necessary to support this defence were proved, though the actual date and circumstances of the origin of the tenure were not. The tenure had been sold in Court auctions for arrears of rent, and had been described as an istimrari mukarari tenure in 1859 and in 1902 ; rent receipts were produced for a long series of years, in which the tenure was also thus described; and it was proved that, in 1869, the mutwalli of the day had sued unsuccessfully for enhancement of rent. Circumstances such as these are an ordinary and, prima facie, a sufficient proof of the right asserted by the defendants.

    2. Against this, the plaintiff's reply was as follows:-

    "Admittedly the defendants have always owed and have often paid rent at an unchanging rate to the mutwalli of the wakf, to which the lands in question with others appertained, but they can produce no grant or lease in support of their claim to a permanent tenure, and, if they could, a mutwalli cannot alienate the lands of the wakf or grant a permanent tenure at a fixed rent, which has the same effect."

    3. To meet this, otherwise irrefragable, argument, the defendants contended that, by way of completing their title to a tenure actually enjoyed over so long a period of years, there ought to be presumed some lawful origin, and the existence of such facts, though unrecorded and forgotten, as would establish a lawful origin. Mahomedan law affords such an origin in the exception to the rub (whether still acted on in the practice in modern times or not), that with the leave of the Kazi such an alienation, otherwise unlawful, is permissible to a mutwalli (Ameer Ali, Mahomedan Law, 4th ed., i. 428). The Subordinate Judge declined to make this presumption, but on appeal, the High Court made it and reversed his decree for possession. Greaves J., with whom Mukerji J. concurred, observed:

    I think that the Court, under the circumstances of the present case, should make the assumption that the grant was in its origin lawful, having regard to the fact that the lease has existed unchallenged since at any rate 1843, that the rent has remained unchanged, that applications for enhancement have been made and failed, and that no mutwalli has challenged it for a period of over seventy years.

    4. It is against this conclusion that the present appeal is brought.

    5. This question was dealt with by their Lordships' Board in Bawa Magniram Sitaram v. Kasturbhai Manibhai (1921) L.R. 49 I. Section 54, s.c. 24 Bom. L.R. 584. In that case a lease of five and a half acres of land, which had been previously settled as part of a mutt, was granted to a tenant, upon terms which, on the true construction of the document, were hold to amount to a permanent lease, terminable only on non-payment of the rent reserved. The land had been held for the greater part of a century at the original low rent continuously without any disturbance of the tenants or anything to show that either party to it regarded the right of the tenants as other than permanent, while circumstances were proved, which appeared to establish the contrary. The decision proceeded upon the assumption that the grantor of the lease had been the She bait. If so, the property having' been devoted to religious purposes, the power of leasing would not extend beyond a grant for the life of the Shebait for the time being.

    6. The Board, relying on the established exception to this limitation of his powers, namely, that, a permanent alienation of temple property is valid, when there is proved necessity for the alienation, and following the case of Choclcalvngam Pillai v. Mayandi Chettiar (1896) I.L.R. 19 Mad. 485 came to the conclusion that, failing actual proof of such necessity, its existence ought under the circumstances to be presumed (p. 59):-

    At the lapse of 100 years," says Lord Buckmaster, " when every party to the original transaction has passed away, and it becomes completely impossible to ascertain What were the circumstances which caused the original grant to be made, it is only following the policy which the Courts always adopt, of securing as far as possible quiet possession to people who are in apparent lawful holding of an estate, to assume that the grant was lawfully and not unlawfully made.

    7. It is to be remarked that in the case of Choclcalingam Pillai the date and terms of the original grant of the land to the mutt were on record, the date being 1756, and that in the earlier case of Murugesam Pillai v. Maniokavasaka Pandara (1917) L.R. 44 I. Section 98, s.c. 19 Bom. L.R. 456 in which the above quoted doctrine was also invoked, the interval between the impugned grant and the suit, which challenged it, was only twenty-five years. Further in Choclcalingam's case, as appears at page 496 of the report, a good deal was known and proved in evidence of the circumstances existing when the grant in question was made, and this was considered by the Court as part of the material, justifying the presumption of some necessity. In the case of Bawa Magniram Sitaram v. Kasturbhai Manibhai, their Lordships, however, applied the presumption without debating [ the circumstances or the probabilities of the case, no doubt in view of the fact that so long a time had elapsed since the event that any such consideration would have been speculative.

    8. The question then is whether this decision applies in the present case, or whether any ground exists on which it can, be properly distinguished.

    9. The presumption of an origin in some lawful title, which the Courts have so often readily made in order to support possessory rights, long and quietly enjoyed, where no actual proof of title is forthcoming, is one which is not a mere branch of the law of evidence. It is resorted to because of the failure of actual evidence. Hence their Lordships cannot accept the appellant's contention that the provisions of the Indian Evidence Act, e. 114, prevent the inference of a consent by the Kazi in the absence of any evidence of an application to the Kazi for leave, or some other proved fact of that kind. The matter is one of a presumption, based on the policy of the law, but even considered as an inference from proved facts, the leave presumed is a thing, which may well be regarded as likely to have happened. At the same time it is not a presumption to be capriciously made, nor is it one which a certain class of possessor is entitled to de jure. In a case such as this, where it is necessary to indicate what particular kind of lawful title is being presumed, the Court must be satisfied that such a title was in its nature practicable and reasonably capable of being presumed, without doing violence to the probabilities of the case. The presumption is not an " open sesame," with which to unlock in favour of a particular kind of claimant a closed door, to which neither the law nor the proved facts would in themselves have afforded any key. It is the completion of a right, to which circumstances clearly point> where time has obliterated any record of the original commencement.

    10. There was, however, in evidence in the present case a sanad of the Emperor Shah Alam, in 1772, which granted the trusteeship of the wakf mahals, within which the villages in suit are situated, to an ancestor of the appellant as mutwalli, with an express declaration that he is not competent to give istimrari or mukarari or lease at a low jama to any person anything appertaining to to said pergana." This sanad was confirmed by the Nawab Nazim and the East India Company, and here, it was said, was the real legal origin of this mutwalliship, created with a specific restriction on its powers, long anterior to the earliest date to which the respondents' proof could be carried. If so, the sanad is in terms absolute, and reserves no right to alienate with the consent of the Kazi, and, even if this were otherwise, it is unreasonable to presume some leave, given by a Kazi, of which no record exists, the material period being comparatively modern; the intervention of a Kazi being, at any rate, recently little heard of, if not obsolete; and the matter not being one in which it is probable that a grant might have been lost, but rather that the existence of any such grant would have been an extraordinary and doubtful thing. For the suggestion that, although his par mission validates the transaction, it would necessarily be irregular and wrong in the Kazi to give it, no authority was produced, and the contention itself seems to reduce the power of legal permission to an absurdity, while the argument that, in effect, the origin of this tenure was prima facie a usurpation on the part of some mutwalli, and that the supposed permission would be an impiety on the part of some complaisant Kazi, and that accordingly nothing should be presumed that would validate one wrong by the supposition of another, begs the question.

    11. Their Lordships answer this as follows. Without saying that, eve-n in regard to a period beginning not later than 1772, and ending not later than 1843, it would have been improper to make the presumption of an unrecorded grant of leave by the Kazi at some unknown time within those limits, it is plain in this case that no such narrow limits apply. From the terms of the sanad itself it is reasonably clear that the wakf was one already established and subject to the general rules of Mahomedan law, and these, at least without express words, th e Imperial Sanad could not abrogate. It was admitted that the prohibition expressly stated in the sanad was actually identical with the prohibition, which the Mahomedan law would impose, subject always to the power of relaxation possessed by the Kazi. As a matter of fact, this wakf was of very considerable antiquity, of which the proof did not consist solely in venerable traditions or the doubtful accounts of annalists, but also in inscriptions of ancient date and tenor, still existing upon the walls of the buildings belonging to it. The longer the period within which and the remoter the time when arst a grant might be reasonably supposed to have occurred, the ess force is there in such an objection as the appellant has developed in argument. Even if the leave of a Kazi is now a rarity and perhaps obsolescent still, in more ancient times and in different social circumstances, resort to it may well have been common; otherwise, indeed, how came the rule to be recorded as existing and long established in learned and formal treatises ? What is now, as is only too well known, commonly achieved only by usurpations and breaches of trust on the part of delinquent mutwallis, may in earlier and purer times have been regularly done in conformity with the prescriptions of the law. In their Lordships' opinion the presumption of a lost and unrecorded permission of the Kazi for the creation of the tenure of wakf lands, under which the respondents claim to hold, is in itself reasonable and proper as the natural form, which a legal origin would take. The alternative suggestion, that the creation of the tenure should be presumed to have been older than the creation of the wakf, so that the subject of the settlement was the permanent rent and not the lands themselves, is one which their Lordships do not think fit to adopt.

    12. There remains the question whether the decision of the Board in Bawa Magnwam Sitaram v. Kasturbhai Manibhai can and ought to be distinguished on any ground. The only possible distinction is that it was a Hindu mutt with which the case was concerned. In principle the cases are in themselves analogous. In the language of the judgment there is nothing to suggest that the subject then under discussion was regarded as being in any sense peculiar or special. As a matter of public right their Lordships think it would be very undesirable to introduce purposeless distinctions between the law applicable in the case of one community and that applicable to another. They are therefore of opinion that the presumption rightly made by the High Court completed the defendants' answer to the plaintiff's claim to possession and they will humbly advise His Majesty that this appeal should be dismissed with costs.

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    Mahammad Mazaffar Al Musavi v. Jabeda Khatun
    (Jan 21, 1930)