Short answer. Only up to a point. A probate order or grant of letters of administration is conclusive on the will and the administration themselves, but the rule makes it only prima facie evidence of the death — meaning the fact of death can still be disproved by contrary evidence.
What the law says
the probate of a will or granting of letters of administration shall only be prima facie evidence of the death of the testator or intestate
Rule 39, Section 47 — Effect of judgments or final orders. Read the full provision →
Two different effects in the same order
A judgment about a will or an estate binds the world, not merely the parties who appeared. The rule says that in a case concerning the probate of a will, or the administration of the estate of a deceased person, the judgment is conclusive upon the will or the administration. That is why a probate order does not have to be relitigated against every heir or creditor who later surfaces. The order settles the status of the will itself.
Why death is treated differently
The same sentence then pulls one fact out of that conclusiveness. The probate of a will or granting of letters of administration shall only be prima facie evidence of the death of the testator or intestate. Prima facie means the order is enough to establish death unless and until someone puts forward evidence to the contrary. It shifts the practical burden onto whoever disputes the death; it does not shut the question down the way conclusiveness would.
Why the distinction exists
The reason is practical. Probate proceedings are about whether a document is the person's will and who should administer what they left. Death is the assumption the proceeding starts from, not a matter the court investigates adversarially. Treating it as conclusive would mean a person wrongly presumed dead — or one whose death was asserted on thin proof — could never contest the point afterwards. So the rule preserves that opening while leaving everything else settled.
What this means in practice
If you are relying on a probate order to establish death for some other purpose, expect that it can be met with contrary proof, and expect agencies and registries to ask for the death certificate as the primary document. Conversely, if you have real reason to believe the person is alive, the probate order is not the wall it appears to be on the question of death — though it remains conclusive as to the will and the administration until set aside in the proper proceeding.
Who is affected by the distinction
The prima facie treatment of death matters most to people who were not parties to the probate and have reason to question it — an insurer, a bank, a second family, or the supposed decedent. For heirs and administrators the practical position is unchanged: the order governs the will and the administration, and they may act on it. What the rule prevents is the fact of death being placed beyond challenge by a proceeding in which nobody contested it, while leaving the rest of the order conclusive.