Siyambalapiti Mudalige Ariyalatha Athukorala v. Upul Kumara Jayaratne and others – SC APPEAL 59/2011-2025

The court addressed the issue of whether an action for the annulment of deeds, based on allegations of forgery, could be maintained without an explicit prayer for a declaration of title. The Supreme Court held that where title is averred in the plaint and a corresponding issue is raised, a full trial would determine title, rendering an explicit prayer for declaration unnecessary. This decision reaffirmed the principle that the substance of the pleadings and issues raised should guide the maintainability of an action, rather than a strict adherence to formal prayers.

YASANTHA KODAGODA, PC., J. – The matter originated from a District Court action where the Plaintiff-Appellant sought the annulment of two deeds, alleging forgery, claiming sole ownership through intestate succession and gift