Jai Singh vs Shakuntala

The Supreme Court analyzed Section 16 of the Hindu Adoption and Maintenance Act, 1956, which establishes a statutory presumption of lawful adoption when a registered adoption document is presented, stating that this presumption is rebuttable. The Court held that the presumption cannot be considered irrebuttable due to the inclusion of 'unless and until it is disproved', thereby affirming the lower court's decision that the adoption deed in question was not binding on the plaintiff, Shakuntala, who claimed ownership of the estate of Sunda Ram.