Benami transaction claims require reliable proof of name-lending, and apparent title prevails absent convincing contrary evidence.

A benami claim fails unless the person challenging apparent title produces reliable evidence that the ostensible purchaser was only a name-lender. The court examined the source of purchase money, possession, custody of title deeds, the parties' relationship, motive, and their conduct before and after the transaction. On the facts, the vendor's evidence and receipts supported payment by the defendant, the defendant was shown in possession and openly dealing with the property, and the plaintiff produced no convincing proof of funding, receipts, lease documents, or a satisfactory explanation for the delay and surrounding conduct. The sale deed was therefore not benami, and the plaintiff did not establish that the defendant held the property for his benefit.

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Issues: Whether the sale deed in favour of the defendant was a benami transaction for the benefit of the plaintiff.

Analysis: In a claim alleging benami, the burden lay heavily on the person asserting that the ostensible purchaser was only a name-lender, and the apparent title could be displaced only by reliable legal evidence. The Court assessed the source of purchase money, possession, custody of title deeds, the relationship and position of the parties, motive, and their previous and subsequent conduct. The vendor's evidence and the receipts showed payment by the defendant; the defendant was shown to be in possession and to have dealt with the property openly; the plaintiff failed to produce convincing proof of funds, receipts, lease documents, or any satisfactory explanation for the long delay and his own conduct. The surrounding circumstances did not support the plaintiff's version.

Conclusion: The sale deed was not benami, and the plaintiff failed to prove that the defendant held the property for his benefit.

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