Re Sigsworth
The golden rule prevented a son who murdered his mother from inheriting her estate under the intestacy rules.
Facts
Mr Sigsworth murdered his mother, who died without leaving a will. Under the Administration of Estates Act 1925, her estate would pass to her issue, which meant her son, the murderer. The Act made no exception for a person who had killed the deceased. The question was whether he, or his estate, could inherit.
Legal principle
Clauson J held that the son could not inherit. Applying the golden rule, the words of the Act should be read subject to the established public policy principle that a person cannot benefit from his own crime. Although the words of the statute were clear and unambiguous, giving them their literal meaning would produce a result repugnant to public policy, so they were read as not applying to a murderer. The principle is now known as the forfeiture rule.
Related cases on statutory interpretation
- Adler v George [1964] 2 QB 7
- Black-Clawson International Ltd v Papierwerke Waldhof-Aschaffenburg AG [1975] AC 591
- Corkery v Carpenter [1951] 1 KB 102
- Grey v Pearson (1857) 6 HLC 61
- Heydon's Case (1584) 3 Co Rep 7a
- Inco Europe Ltd v First Choice Distribution [2000] 1 WLR 586
- Jones v Tower Boot Co Ltd [1997] ICR 254
- London and North Eastern Railway Co v Berriman [1946] AC 278
Studying english legal system? Our tutors help you understand and apply cases like this in essays, problem questions and exams. Request a quote or browse our law notes.
This summary is for study and revision and is not legal advice. Although our case summaries are checked for accuracy, we do not guarantee that they are free from errors or omissions. Always read the full judgment for the court's reasoning.
