Strict threshold against casual declaration of sham deeds

Courts must not lightly or casually declare registered instruments as sham documents, and challenges can only be sustained if the challenger provides material particulars and cogent evidence demonstrating that the deed was never intended to operate as a bona fide transfer. (Hemalatha (D) by Lrs. v. Tukaram (D) by Lrs. | 2026 INSC 179)