Parol evidence cannot vary a registered settlement deed; any rescission or modification needs a subsequent registered instrument.

Parol evidence is excluded under Section 92 of the Indian Evidence Act, 1872 to vary the terms of a written grant or disposition once its contents are proved. Proviso (4) allows proof of a later oral agreement to rescind or modify an earlier arrangement only when the underlying contract, grant or disposition is not required by law to be in writing and is not registered. Where the instrument is a registered settlement deed conferring rights, its terms cannot be altered, rescinded, or varied by oral evidence; any change must be made by a subsequent registered document. On that basis, the alleged later oral arrangement could not be proved and the challenge to the plaintiff's share failed.

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Issues: Whether parol evidence is admissible to prove a subsequent oral arrangement that rescinds or modifies the terms of a registered settlement deed.

Analysis: Section 92 of the Indian Evidence Act, 1872 excludes oral evidence to vary the terms of a written grant or disposition once its terms are proved. Proviso (4) permits proof of a distinct subsequent oral agreement to rescind or modify an earlier arrangement only where the underlying contract, grant or disposition is not required by law to be in writing and is not registered. A registered instrument cannot be altered, rescinded, or varied by parol evidence; such change can be effected only by a subsequent registered document. Since the settlement deed in question was a registered document by which rights had already been conferred, the alleged later oral arrangement could not be proved by oral evidence.

Conclusion: Parol evidence was not admissible to support the alleged subsequent oral arrangement, and the challenge to the plaintiff's share failed.

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