S. M. KARIM vs MST. BIBI SAKINA

The Supreme Court held that Section 66 of the Code of Civil Procedure bars claims based on benami transactions, protecting not only the certified purchaser but also anyone claiming through him. The Court clarified that the second sub-section pertains to creditors, while the first addresses transferees. It further established that if the real owner's possession matures into title under the Limitation Act, he may sue for possession without relying on the benami nature, provided he adequately proves adverse possession. The appeal was dismissed, affirming the High Court's decision.