State of Bihar v. Radha Krishna Singh AIR 1983 SC 684

STATE OF BIHAR V. RADHA KRISHNA SINGH

Whether the plaintiffs (Radha Krishna Singh and others) established their genealogical connection to Maharaja Harendra Kishore Singh to claim inheritance of the Bettiah Raj estate?
Whether Exhibit J and other evidence relied upon by the plaintiffs were admissible and sufficient to prove their claim?
Whether the State of Bihar’s claim of escheat could be upheld in the absence of proven heirs?

Genealogical evidence must be admissible under the Evidence Act (Sections 35 and 32(5)) and hold sufficient probative value to prove claims.
Claims of escheat require the State to demonstrate conclusively that no heirs exist to inherit the estate.

Maharaja Harendra Kishore Singh of Bettiah Raj died issueless on March 26, 1893, leaving behind vast properties in Bihar and Uttar Pradesh.
After his death, the estate was managed by his two widows: Maharani Sheoratan Kuer, who died on March 24, 1896, and Maharani Janki Kuer, who died on November 27, 1954.
Following the death of the widows, disputes over the estate arose between multiple claimants, including the State of Bihar (claiming escheat) and individuals asserting themselves as the nearest reversionary heirs.
Radha Krishna Singh and others filed T.S. No. 5/1961 in the Sub-Judge Court, Patna, claiming inheritance based on genealogical linkage to the Maharaja.
The trial court dismissed the suit, holding that the plaintiffs failed to prove their genealogical connection to the Maharaja’s family.
On appeal, the Patna High Court reversed the trial court’s decision by a majority judgment, ruling that the plaintiffs had proven their genealogy. However, one judge dissented, agreeing with the trial court’s findings.
The State of Bihar appealed to the Supreme Court, challenging the plaintiffs’ genealogical claims and the evidence relied upon, including Exhibit J, an entry in public records.

The Supreme Court held that while Exhibit J was admissible under the Evidence Act, it lacked probative value as the source and verification of its genealogical details were unreliable.
The plaintiffs failed to conclusively establish their genealogical connection to the Maharaja’s family, specifically proving that their ancestor, Ramruch Singh, was related to the Maharaja’s ancestor, Bansidhar Singh.
The Court emphasized that escheat claims by the State require proof of the absence of any heirs, which was not fully demonstrated in this case.
The appeal by the State of Bihar was allowed, the High Court’s judgment was set aside, and the suit by Radha Krishna Singh was dismissed.
The Court stressed the importance of clear and corroborated genealogical evidence in inheritance disputes to avoid fraudulent claims.