The court emphasizes the importance of clear and satisfactory evidence in proving the validity of a will. It also highlights that a later will can revoke earlier wills, even without a specific clause of revocation, if the testator unambiguously deals with the entire property in the later will.

Kuldip Chand Sood, J.—The defendant-appellants having lost before the trial Court and the First Appellate Court, are in second appeal against the judgment and decree of learned Additional District Judge, Kullu dated November 2, 1994.

2. Facts necessary for the disposal of this appeal are:

3. One Prem Kaur alias Chhabilu was the owner in possession of the properties subject matter of dispute. The properties are situate in the District of Kullu and Mandi.

4. Prem Kaur was married to one Sardar Kuldip Singh in the year 1947. No issue was born out of this wedlock. Kudlip Singh died in the year 1981. On the death of Kuldip Singh, Prem Kaur inherited his properties. She also purchased some other properties in her own name. She had adopted defendant-appellant Lata Swaran. Lata Swaran contracted love marriage with defendant-appellant Nand Singh Jhalla, then resident of Rajasthan. Defendants-appellants Jeetender Singh Jhalla, Shakunt Jhalla and Kumari Chand Jhalla are children of Nand Singh Jhalla and Lata Swaran.

5. Plaintiff-respondent Budh Ram was real brother of Prem Kaur. Respondents Dhani Ram, Chandu Lal, Rewat Ram and Dayalu Ram are sons of Budh Ram. Respondents Kala Devi and Leela Devi are daughters of Budh Ram, respondent Asha alias Thakri is daughter of Dayalu and grand-daughter of Budh Ram.

6. The case of the plaintiff-respondent: After the death of Kuldip Singh, Lata Swaran and her husband Nand Singh Jhalla started harassing Prem Kaur with a view to grab her property. Nand Singh Jhalla wanted to dispose of the property of Prem Kaur. Relations between them became so strained that he set on fire the workshop of Prem Kaur styled as "Kerala Tyres" at Kullu. Nand Singh Jhalla was prosecuted under Section 436 of the Indian Penal Code. He was convicted and sentenced to rigorous imprisonment for one year and also to pay fine. However, he was later acquitted in appeal. Prem Kaur fed with the harassment, executed a will on March 25, 1987 in favour of plaintiff-respondents and defendant Nos. 1 to 3, namely, Jeetinder Singh Jhalla, Shakunt Jhalla and Kumari Chand Jhalla. Nand Singh Jhalla had some inkling that Prem Kaur is going to execute a will disinheriting him and Lata Swaran. Unmindful of the fact that the will had already been executed, Nand Singh Jhalla and Lata Swaran shot Prem Kaur dead on April 17, 1987 to frustrate any effort on the part of Prem Kaur to disinherit them. A case under Section 302 read with Section 114 of the Indian Penal Code and Section 27 of the Indian Arms Act was registered against them. Both of them were prosecuted and convicted by the learned Sessions Judge. They, however, were acquitted in appeal by the High Court.

7. It is the case of the plaintiff-respondents that pursuant to the last will of Prem Kaur dated March 25, 1987, the plaintiffs have inherited the properties of deceased Prem Kaur situated in District Kullu fully described in para 2(i) to (iv) of the plaint in accordance with the shares stipulated in the will. Similarly, defendants No. 1 to 3 inherited the property situated in District of Mandi fully described in para 2(v) to (viii) of the plaint. The plaintiffs, consequently are the owners in possession of the properties described in para 2(i) to (iv) of the plaint, hereinafter referred to as "suit property". It is the further case of the plaintiffs that defendants, after the death of Prem Kaur, set up a forged and fictitious will alleged to have been executed by Prem Kaur on August 23,1967 in favour of defendant No. 1 Jeetinder Jhalla. It is pleaded that this will is forged and fictitious and was never executed by Prem Kaur and even if such will was executed, then the same stands revoked in view of the last and final will of Prem Kaur dated March 25, 1987.

8. The defendants, on the basis of forged will, got a mutation of the disputed properties sanctioned in favour of defendant Jeetender Jhalla. These mutations were attested without notice to the plaintiffs. The plaintiffs when came to kn