
On November 22, 2023, the First Civil Chamber of the Court of Cassation upheld the validity of a holographic will lacking a handwritten date, provided that intrinsic elements, supported by extrinsic evidence, establish the approximate period of its drafting.
This case reflects a flexible interpretation of Article 970 of the Civil Code, emphasizing that the absence of a date does not necessarily render the will invalid, as long as the rights of the parties are respected and the testator was not incapacitated during the relevant period.