Can a Person Claim Property After Being Accused of Killing the Owner?
Property inheritance disputes often become complicated when legal heirs, Wills, family claims, and criminal allegations overlap. But one principle remains very clear in law: no person should be allowed to benefit from their own wrongdoing.
The Supreme Court of India recently explained this principle in Manjula and Others v. D.A. Srinivas, 2026 INSC 465, where it held that a person accused of murdering the person from whom inheritance is claimed cannot assert rights over that person’s estate. The Court clarified that this bar applies not only to inheritance without a Will but also to claims made through a Will.
Case Details: Manjula and Others v. D.A. Srinivas
The case involved a property dispute connected to K. Raghunath, who died on 4 May 2019. The respondent/plaintiff, D.A. Srinivas, claimed ownership over the disputed properties based on a Will allegedly executed by K. Raghunath in his favour.
The appellants, Manjula and others, opposed the claim. Their main argument was that Srinivas was shown as an accused in the murder case of K. Raghunath. Therefore, they argued that he could not claim inheritance from the very person he was accused of murdering.
The plaintiff tried to defend his claim by saying that he was not claiming the property as a normal legal heir. He argued that his claim was based on a Will, and therefore Section 25 of the Hindu Succession Act should not apply to him.
What Was the Main Legal Issue?
The main issue before the Supreme Court was simple but serious:
Can a person accused of murdering the property owner still claim that owner’s property through a Will?
The plaintiff’s argument was that Section 25 applies only to normal inheritance when a person dies without a Will. But the defendants argued that the law cannot allow a murder accused to benefit from the estate of the murdered person, whether the claim is made as a legal heir or through a Will.
What Section 25 of the Hindu Succession Act Says
Section 25 of the Hindu Succession Act, 1956 states that a person who commits murder, or helps in committing murder, is disqualified from inheriting the property of the person murdered. It also disqualifies the person from inheriting any other property in furtherance of the succession connected to that murder.
In simple words:
A person cannot kill someone and then claim that person’s property.
This is not just a technical rule. It is based on a deeper legal and moral principle: no one should profit from their own wrong.
Why Section 27 Also Matters
The Supreme Court also referred to Section 27 of the Hindu Succession Act. This section says that when a person is disqualified from inheritance, the property will pass as if that disqualified person had died before the deceased.
This means the law removes the disqualified person from the line of succession. The property then moves to the next eligible legal heirs, as though the disqualified person was never available to inherit.
How Section 30 Became Important
The plaintiff’s claim was based on a Will. So the Court also examined Section 30 of the Hindu Succession Act, which allows a Hindu to dispose of property through a Will or other testamentary document.
The Court said that the Hindu Succession Act recognises both:
Intestate succession — where a person dies without a Will and property passes to legal heirs.
Testamentary succession — where property is transferred through a Will.
Because the Act recognises both types of succession, the Court held that the bar under Section 25 applies to both. A person cannot avoid disqualification simply by saying, “I am claiming through a Will, not as a legal heir.”
The Supreme Court’s Judgment
The Supreme Court held that a person accused of murdering the person from whom inheritance is claimed is disentitled from asserting rights over that estate. The Court made it clear that the disqualification applies not only under Section 25 but also under the broader principles of justice, equity, fair play, and public policy.
The Bench, comprising Justice J.B. Pardiwala and Justice R. Mahadevan, held that the bar under Section 25 applies to both intestate and testamentary succession. The Court also said that strict criminal proof is not always necessary in a civil property dispute if the facts, on a balance of probabilities, point towards the commission of the offence.
This is a very important point. In a criminal case, the standard of proof is beyond reasonable doubt. But in a civil property case, the standard is 1preponderance of probabilities, meaning the court examines what appears more probable from the available facts.
Is Criminal Conviction Necessary Before Disqualification?
The Supreme Court made it clear that a person does not always need to be convicted in a criminal case before being stopped from inheriting property under Section 25. However, a simple accusation is not enough.
The court must look at the facts carefully. If strong evidence or circumstances show that the person claiming the property was likely involved in the murder, the civil court can disqualify that person from inheriting the property.
Why the Court Rejected the Claim
The Supreme Court found that the respondent’s suit was legally 2untenable because it was based on a claim to the properties of a person he was accused of murdering. The Court held that such a claim is barred not only by the wording of Section 25 but also by the larger principles of equity and justice.
The Court also noted that legal rights cannot be used as instruments of injustice. In other words, a person cannot use succession law, a Will, or clever legal drafting to claim property if the claim itself is connected to a serious wrongful act.
Why This Judgment Matters in Property Disputes
This judgment is important for families, legal heirs, property buyers, and real estate due diligence professionals.
Many property disputes arise after the death of an owner. Sometimes, people rely on Wills, legal heir certificates, possession, family arrangements, or oral claims. But this case shows that inheritance is not only about documents. The conduct of the claimant also matters.
Before accepting any inheritance-based property claim, it is important to check:
- Whether the claimant is a genuine legal heir
- Whether there is a valid Will
- Whether there are pending criminal disputes connected to the deceased
- Whether the Will was created under suspicious circumstances
- Whether other legal heirs have challenged the claim
- Whether any disqualification applies under succession law.
For property buyers, this is especially important. Buying a property from a person claiming through inheritance or Will without verifying legal risks can later lead to litigation, title disputes, and registration complications.
Verified.RealEstate Angle: Why Title Due Diligence Matters
This case is a strong reminder that property verification should not stop with checking the sale deed alone. In inherited properties, the buyer must also verify the chain of title, legal heirs, Will validity, death certificate, family disputes, pending litigation, and any criminal or civil proceedings affecting ownership.
Platforms like Verified.RealEstate and tools such as LandLens can help buyers identify title risks, inheritance gaps, suspicious ownership claims, and property dispute red flags before completing a transaction.
Conclusion
The Supreme Court’s ruling in Manjula and Others v. D.A. Srinivas makes one principle very clear:
A person accused of murdering the property owner cannot claim that owner’s property either as a legal heir or through a Will.
Section 25 of the Hindu Succession Act blocks such inheritance, and the broader principle of justice also supports the same result. The law will not allow a person to benefit from their own wrong.
For property buyers and families dealing with inherited assets, the lesson is simple: inheritance claims must be verified carefully, especially when there are criminal allegations, suspicious Wills, or disputed family claims.
Abbreviations Used
HSA — Hindu Succession Act, 1956, the law governing inheritance and succession among Hindus in India.
CPC — Code of Civil Procedure, 1908, the procedural law that governs civil court cases in India.
Will — A legal document through which a person states how their property should be distributed after death.
Intestate Succession — Inheritance that happens when a person dies without leaving a valid Will.
Testamentary Succession — Inheritance that happens through a Will or testamentary document.