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Manjula & Others v. D.A. Srinivas

Civil Appeal · 2026 INSC 465Decided 8 May 2026
Civil Appeal No. 7370 of 2026 (arising out of SLP (C) No. 7924 of 2024)
Justice J.B. Pardiwala · Justice R. Mahadevan

Background

D.A. Srinivas (the respondent/plaintiff) sued the wife and children of the late K. Raghunath, claiming ownership of certain properties on the strength of a Will allegedly executed by Raghunath in his favour. The appellants (Raghunath's widow and children) sought to have the plaint thrown out at the threshold, arguing it disclosed no valid cause of action and was barred by the Prohibition of Benami Property Transactions Act, 1988, since the plaintiff's own case was that he had funded the purchase of the properties in Raghunath's name. The trial court rejected the plaint on this basis, but the Karnataka High Court reversed that order and restored the suit for trial. The appellants then appealed to the Supreme Court.

Decision Breakdown

The Supreme Court held that a plaint can indeed be rejected at the threshold where a meaningful reading of its own averments shows the claim is founded on a prohibited benami arrangement, even if it is dressed up as a claim under a Will. It found that the plaintiff's own pleadings admitted he financed the purchase while title was taken in Raghunath's name: squarely a benami transaction not protected by any statutory exception, and that the 2016 amendment to the Benami Act operates retrospectively. The Court also held that a person implicated in the murder of the person from whom inheritance is claimed cannot assert inheritance rights, applying Section 25 of the Hindu Succession Act and principles of justice and equity. Consequently, it set aside the High Court's judgment, declared the transaction benami, and directed the Central Government to appoint an Administrator to take over the properties (confiscation) within eight weeks.

Lesson Learnt

Courts will look past the form of a lawsuit to its real substance, dressing up a claim as one under a Will does not shield it from the legal bar on benami transactions; funding a property purchase in someone else's name and later trying to claim ownership through litigation can result in the property being confiscated by the government.

Official source (sci.gov.in)View Judgment (PDF)

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