Re Sigsworth
Rule established
Golden Rule applied to read in words not present in the statute, preventing a murderer from inheriting on intestacy from the person he killed.
Facts
- Son murdered his mother
- Mother died intestate
- Administration of Estates Act 1925: estate devolves to "issue" (i.e., children)
- No express statutory bar on a murderer inheriting
Issue
- Whether a murderer can inherit from the estate of the person he has murdered under intestacy rules.
Held
- Literal reading permits a murderer to profit from his crime (repugnant to justice)
- Golden Rule applied: words read into the statute excluding a person who has killed the deceased
- Son barred from inheriting
Ratio Decidendi
Where the literal application of clear statutory words would produce a result repugnant to principles of public policy and justice, the court may read in words to prevent that repugnant result.
How to use it in an exam
- Golden Rule at its broadest: reading in words not present in the statute
- Contrast with R v. Allen (narrowing) and Adler v. George (extending)
- Key line: "In Re Sigsworth (1935), the court applied the Golden Rule to read in a qualification that a murderer cannot inherit from the victim, since a literal reading would allow a person to profit from his own crime."
Source
Source: [1935] Ch 89; standard textbook authority
This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.
Cited in study notes
Interpretation of StatutesGolden RuleBroadest application: reading in words not present in the statute