The Supreme Court in Zoharbee & Anr. v. Imam Khan (D) Thr. LRs. & Ors. (October 16, 2025), decided by Justices Sanjay Karol and Prashant Kumar Mishra, dealt with a property dispute between a Muslim widow and her brother-in-law over the estate of the deceased Chand Khan, who died childless. The widow claimed three-fourths of the property, while the brother contended that the land had already been sold through an Agreement to Sell. The Court held that an Agreement to Sell does not transfer ownership or create any charge over property; only a registered sale deed does so under Section 54 of the Transfer of Property Act. Since the sale deed was executed after the deceased’s death, the land remained part of his matruka (estate). Applying Muslim inheritance law, the Court ruled that the widow was entitled to one-fourth share, reaffirming that no one can transfer a better title than they possess (nemo dat quod non habet).