Legal Analysis: Manjula and Others vs. D.A. Srinivas

Citation: 2026 INSC 465  
Court: Supreme Court of India
Bench: Justice R. Mahadevan and Justice J.B. Pardiwala (Division Bench)
Date of Decision: May 8, 2026
Nature of Judgment: Civil Appeal under Article 136 against High Court order reversing rejection of plaint under Order VII Rule 11 CPC.

Synopsis of the Judgment

The respondent/plaintiff filed a suit for declaration of title based on a Will allegedly executed by K. Raghunath (since deceased), claiming that the suit properties were purchased with his funds in the name of the deceased, who held them as a benamidar. The appellants/defendants (legal heirs of the deceased) filed an application under Order VII Rule 11 CPC seeking rejection of the plaint on the ground that the suit was barred under the Prohibition of Benami Property Transactions Act, 1988. The trial Court rejected the plaint. The High Court reversed, restoring the suit. The Supreme Court set aside the High Court’s judgment, holding that a meaningful reading of the plaint disclosed a benami transaction squarely hit by Sections 3 and 4 of the Benami Act. The Court held that the 2016 amendments to the Benami Act are retrospective insofar as they are declaratory, procedural, and curative. It also held that there was no fiduciary relationship between the plaintiff and the deceased, that the object of the underlying MOUs was unlawful (to circumvent land reform laws), and that the plaintiff was disqualified from inheriting the property under Section 25 of the Hindu Succession Act, 1956 (on grounds of alleged murder). The suit properties were declared benami and directed to be confiscated.

1. Basic Information of the Judgment

• Case Title: Manjula and Others vs. D.A. Srinivas

• Civil Appeal No.: 7370 of 2026 (arising out of SLP(C) No. 7924 of 2024)

• Bench: Justice R. Mahadevan and Justice J.B. Pardiwala (Division Bench)

• Date of Decision: May 8, 2026

• Citation: Not specifically provided in the extract; the judgment is reported as 2026 INSC (number to be assigned)

• Appeal From: Judgment and final order dated 22.02.2024 of the High Court of Karnataka at Bengaluru in Regular First Appeal No. 2216 of 2023

2. Legal Framework

Laws and Provisions Involved

• Code of Civil Procedure, 1908: Order VII Rule 11 (rejection of plaint – grounds (a) and (d)), Order XIV Rule 2 (preliminary issues), Order VI Rule 2 (pleading material facts), Section 26 (institution of suits), Section 35A (costs for false claims)

• Prohibition of Benami Property Transactions Act, 1988 (as amended in 2016): Sections 2(9) (definition of benami transaction), 2(9)(A)(ii) (exception for fiduciary capacity), 3 (prohibition), 4 (bar to recovery), 5 (confiscation), 45 (bar of jurisdiction of civil courts), 53, 54 (penal provisions)

• Indian Contract Act, 1872: Sections 10 and 23 (lawful consideration and object)

• Hindu Succession Act, 1956: Section 25 (murderer disqualified from inheriting), Section 30 (testamentary succession)

• Karnataka Land Reforms Act, 1961: Sections 79A, 79B (restrictions on purchase of agricultural land)

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