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BURDEN OF PROVING VALID EXECUTION OF WILL LIES ON PROPOUNDER

Dictum

Rimmer J summed up the matter as follows in Goode, Carapeto v Goode (2002) WTLR 801 at 841: “The burden of proving that a testator knew and approved of the contents of his will lies on the party propounding the will. In the ordinary course, the burden will be discharged by proving the due execution of the will and that the testator had testamentary capacity. Where, however, the will was prepared in circumstances exciting suspicion something more may be required from those propounding the will by way of proof of knowledge and approval of its contents. A relevant standard of proof is, however, simply by reference to that balance of probability.”

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TESTATOR MUST BE OF SOUND DISPOSING MIND – CRITERIA

Cockburn CJ in Banks v Goodfellow LR 5 QB 549 at 565: “It is essential to the exercise of such a power that a testator shall understand the nature of the act and its effects; shall understand the extent of the property of which he is disposing; shall be able to comprehend and appreciate the claims to which he ought to give effect; and with a view to the latter object, that no disorder of the mind shall poison his affections, pervert his sense of right or prevent the exercise of his natural faculties that no insane delusion shall influence his will in disposing of his property and bring about a disposal of which, if the mind had been sound, would not have been made.”

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BURDEN OF PROOF TO ESTABLISH GENUINENESS OF WILL IS ON THE PROPOUNDER

It is settled, that the burden of proof of the genuiness and authenticity of a WILL lies on the party propounding it. Where there is a dispute as to a WILL, as in this case, the person who propounds it must clearly show by evidence that prima facie everything is in order that is to...

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WHERE WILL IS CHALLENGED, PROPOUNDER IS SHOW REGULARITY

It is incumbent on the propounder of a Will once the Will is being challenged to establish its regularity. But once the court is satisfied prima facie of the regularity of the will, the burden of proof shifts to the party challenging the will. See: Eyo v. Inyang (2001) 8 NWLR (pt 715) 304, Okelola...

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WHERE DISPUTE AS TO WILL, ONUS IS ON PROPOUNDER OF WILL

Amu v Amu (2007) 7 NWLR (Pt.663) 164. At page 164, 170-171, and 174 of the report Aderemi J.C.A (as he then was) said as follows:- “Where there is a dispute as to a will, those who propounded it must clearly show by evidence that, prima facie, all is in order, that is to say that there has been due execution and that the testator had the necessary mental capacity, and was a free agent. Once they have satisfied the court, prima facie, as to these matters, it seems to me that the burden is then cast upon those who attack the will and that they are required to substantiate by evidence the allegation they have made as to lack of capacity, undue influence, and so forth. That it is clear to me, must be their responsibility and nothing can relieve them of it; it is not only a rule of common sense but a rule of law, as appears from numerous authorities.”

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ISSUES RAISED ON PROBATE PROCEEDING NOT TOUCHING ON PROBATE SHOULD – BURDEN

With the plaintiff having introduced new issues over and above the initial challenge on the will Exhibit B, her claim was no longer within the ambit of the general rule as laid down in the case of Adebajo v Adebajo supra, wherein the onus of proof in a probate action lies on the proponents of...

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IF A WILL IS CHALLENGED, IT IS THE PROPOUNDER TO PROVE REGULARITY

It is incumbent on the propounder of a will once the will is being challenged to establish its regularity. But once the court is satisfied prima facie of the regularity of the will, the burden of proof shifts to the party challenging the will – see Eyo v. Inyang (2001) 8 N.W.L.R. (pt. 715) 304,...

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