Introductory Summary

The Madhya Pradesh High Court recently set aside a lower court’s 2000 judgment that recognized actor Saif Ali Khan and his family as rightful heirs to the Nawab of Bhopal’s personal estate—now valued at approximately ₹15,000 crore. Justice Sanjay Dwivedi has directed the trial court to rehear the suits from scratch, emphasizing that the earlier decision relied on an Allahabad High Court precedent later overruled by the Supreme Court.

Background of the Dispute

The core of this dispute lies in the inheritance of personal properties belonging to Nawab Hamidullah Khan of Bhopal. Key milestones include:

• 1949: Bhopal Riyasat merged with India; Hamidullah Khan continued as titular Nawab.
• 1960: On Hamidullah Khan’s death, Sajida Sultan (his daughter) assumed the title, as her elder sister Abida Sultan had migrated to Pakistan.
• 1962: The Government of India officially recognized Sajida Sultan’s ownership of her father’s personal estate.
• February 2000: Trial court held that the estate formed part of the “gaddi” (throne) of Bhopal and passed to Sajida Sultan’s successors, including Saif Ali Khan’s branch of the family.

High Court’s Reasoning

Justice Dwivedi’s June 30 order critiques the trial court decision on two main grounds:

1. Reliance on Overruled Precedent
   The trial court’s decision leaned heavily on the 1996 Allahabad High Court ruling in Miss Talat Fatima Hasan v. Nawab Syed Murtaza Ali Khan. However, the Supreme Court overturned that decision in 2019, nullifying its applicability here.
2. Need for Fresh Adjudication
   Without re-examining the merger agreement, Muslim personal law implications, and competing claims, the trial court prematurely dismissed the suits. The High Court has remanded the case for a full partition hearing, allowing:

• Detailed assessment of the merger terms between Bhopal and the Government of India
• Application of Muslim personal law, if relevant
• Calculation of each party’s share at the preliminary decree stage

Parties and Their Contentions

Appellants (including Saif Ali Khan’s side):

• Argued that the merger agreement, not personal law, governs succession.
• Maintained only Sajida Sultan’s successors can claim the estate.

Respondents (other descendants of Hamidullah Khan):

• Contended government recognition of Sajida Sultan was unlawful.
• Sought distribution under Muslim personal law among all heirs.

Representatives:

• Appellants: Advocates Aadil Singh Bopari, Abhishek Dubey, Ayesha Jamal, K Jaggi, Gurlabh Singh Sidhu
• Respondents: Senior Advocates S Sreevastava, Sanjay Agrawal; Advocates Arjun Rao, Sooraj Bajpai, Aishwarya Vikram, and team

What Happens Next?

The remand means the trial court will now:

1. Reopen evidence on the merger agreement specifics
2. Examine whether Muslim personal law or merger terms apply
3. Determine each claimant’s share in a preliminary decree
4. Finalize the partition after necessary formalities

This fresh hearing could stretch over months, with new rounds of arguments from both sides.

Key Takeaways

• The Supreme Court’s 2019 overruling of the Allahabad precedent triggered this fresh look at the case.
• Merger agreements can supersede personal law in princely state successions.
• Partition suits under high-value estates often require granular factual and legal analysis.

This ruling underscores how shifts in higher-court precedents can upend decades-old judgments. The trial court must now untangle complex historical documents, personal laws, and merger notifications to arrive at a fair distribution of the Bhopal estate.