It seems to imply that after death the deceased, Alexander Litvinenko, returned to accuse Putin for causing him to die.
A sentence in the article disproves the headline: 'In a dramatic statement written before he died, the man called Russian President Vladimir Putin "barbaric and ruthless" and blamed him personally for the poisoning.'
Which means that Mr Litvinenko made the declaration prior to his death - which should have been stated much more clearly in the headline.
Sorry... I'm just disturbed by the way the headline appears every time I log into my Yahoo! mailbox during the time the article has been there.