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The Supreme Court’s judgment in Manjula and Others v. D.A. Srinivas reflects a clear shift in the judicial approach towards benami property disputes. The Court has reinforced that civil litigation cannot be used as a backdoor mechanism to legitimise transactions prohibited under the Prohibition of Benami Property Transactions Act, 1988. The dispute involved properties allegedly purchased in another person’s name, while the claimant asserted that the funds had actually been provided by him. Although the suit was framed around a Will and declaratory reliefs, the Supreme Court emphasised that courts must examine the real substance of the pleadings and not merely the language used in drafting. The judgment strengthens the principle that “clever drafting” cannot conceal a statutory bar. If the foundation of the claim itself suggests a benami arrangement, courts are empowered to reject the plaint at the threshold under Order VII Rule 11 CPC without permitting a prolonged trial. Importantly, the Court also indicated a narrower interpretation of the fiduciary relationship exception under the Benami Act. Mere informal trust, employer-employee relationships, or personal confidence may no longer be sufficient to bypass statutory prohibitions. This signals a more rigorous judicial examination of ownership structures and financial arrangements. The ruling is likely to significantly impact property, succession, and declaratory suits where ownership is claimed indirectly through wills, family arrangements, or oral understandings. Courts are increasingly prioritising the actual nature of the transaction over the form in which relief is drafted. This judgment marks another step towards stronger enforcement of benami laws and reflects the judiciary’s growing unwillingness to permit disguised ownership claims to survive through procedural ingenuity.