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The case revolved around the rarely used section 184 of the 1925 Law of Property Act, which deals with the “presumption of survivorship” in multiple fatalities.

It was at one time thought that there might be a presumption of survivorship in favour of the younger as against the older, of the male as against the female, &c.

Presumption of Survivorship.—When two or more related persons perish in a common accident, it may be necessary, in order to decide questions of succession, to determine which of them died first.