Let $M_i$, $i=1,2,3$, be the relativistic masses of three (static) black holes and $E_i=M_i/c^2$, $i=1,2,3$ their corresponding relativistic energies. Consider the idealized situation that $E_3$ is obtained after $M_1$ and $M_2$ have merged in such a way that we can suppose the energy conservation
$$E_3=E_1+E_2.$$
Now, for the horizon area of a black hole we can write:
$$A=4\pi\,r_s^2=4 \pi\left(\frac{2 G}{c^4}\right)^2\,E^2=\frac{\kappa^2}{4\pi}\,E^2,$$
while $\kappa=8\pi G/c^4$ is Einstein's gravitation constant.
From the latter expression and the energy conservation it follows that the horizon area of the final black hole is $$A_3=(A_1^{1/2}+A_2^{1/2})^2.$$ On the other hand, from the general mathematical inequality $x^{1/2}+y^{1/2}\geq (x+y)^{1/2}$, it follows that $$A_3\geq A_1+A_2.$$ That is, the area of the merged black hole is always greater than the sum of its parts before they have merged.
Is this proof reasonable?