Registered sale deeds cannot be contradicted by oral evidence unless fraud, misrepresentation, or other vitiating facts are specifically pleaded and proved.

A registered sale deed carries a presumption of regularity and cannot be treated as void merely because consideration or debt repayment was not separately pleaded where the deed itself supports the transaction. A party seeking to invalidate such an instrument must specifically plead and prove fraud, misrepresentation, or want of due execution; bare assertions of ignorance of the contents are insufficient. Once a written and registered document is proved, oral evidence cannot be used to vary or contradict its terms unless a recognised vitiating circumstance is properly alleged and established. On these principles, the challenge to the sale deed failed and the trial decree was restored.

---

---

Issues: (i) Whether the registered sale deed was void for want of consideration or because the consideration and debt repayment were not pleaded in the plaint; (ii) Whether the respondents had established fraud, misrepresentation, or want of due execution so as to invalidate the sale deed; (iii) Whether oral evidence could be admitted to contradict the terms of the registered sale deed.

Issue (i): Whether the registered sale deed was void for want of consideration or because the consideration and debt repayment were not pleaded in the plaint.

Analysis: A registered sale deed carried a presumption of regularity and correctness. The recital of sale consideration in the deed could not be treated as ineffective merely because the pleadings did not separately set out the manner in which the transaction was supported by the discharge of the vendor's debts. In a suit founded on the written instrument, the material facts were sufficiently disclosed by relying on the deed itself, and evidence supporting the transaction was not required to be pleaded as if it were a substantive fact forming the cause of action.

Conclusion: The sale deed was not void for want of consideration, and the absence of a separate pleading of debt repayment did not invalidate the transaction.

Issue (ii): Whether the respondents had established fraud, misrepresentation, or want of due execution so as to invalidate the sale deed.

Analysis: A party seeking to avoid a registered instrument on the ground of fraud or misrepresentation must specifically plead and prove the particulars of that plea. Mere assertion of ignorance about the contents of the document, without a pleaded case of fraud and without proof of deception, was insufficient. The admissions regarding the repayment of debts, the execution of signatures before officials, and participation of the vendor and his wife in the registration process negatived the allegation that the document was procured by fraud or misrepresentation.

Conclusion: The respondents failed to prove fraud, misrepresentation, or want of due execution, and the registered sale deed could not be invalidated on that basis.

Issue (iii): Whether oral evidence could be admitted to contradict the terms of the registered sale deed.

Analysis: Once the terms of a document required by law to be in writing and registered had been proved, oral evidence could not be admitted to vary or contradict its terms. Oral evidence was permissible only to show a vitiating circumstance such as fraud, intimidation, illegality, want of due execution, or want or failure of consideration. As no such foundational plea or proof existed, the respondents could not invoke the exception to displace the written instrument.

Conclusion: Oral evidence was inadmissible to contradict the registered sale deed, and the findings based on such evidence were unsustainable.

Final Conclusion: The appellate findings setting aside the trial court's decree were erroneous in law and on facts. The trial decree was restored, the challenge to the sale deed failed, and the respondents were directed to deliver vacant possession.

Ratio Decidendi: A registered instrument cannot be displaced by oral evidence unless fraud, misrepresentation, or another legally recognised vitiating circumstance is specifically pleaded and proved, and a mere assertion of ignorance of the document's contents is insufficient to invalidate it.

---