Finalfamily Law Final Project

1
Changes Introduced in The Classical Concept By The Hindu

Succession Act, 1956
NYAYA NAGAR MITHAPUR,PATNA-800001
FAMILY LAW-I, PROJECT WORK

ON
“CHANGES INTRODUCED IN THE CLASSICAL

CONCEPT BY THE HINDU SUCCESSION ACT,1956”
Submitted To:-
Ms. Pooja Srivastava Submitted By:
Faculty of Family Law Vivek Kumar
Roll no. : - 1775

CHANAKYA NATIONA L LAW UNIVERSITY
Semester: - 4th
Session : - 2017-2022
Course:B.A.,LL.B.(Hons.)
1
2
DECLARATION
I hereby declare that the work reported in the B.A., LL.B. (Hons.) Project
Report entitled “Changes Introduced in The Classical Concept By The
Hindu Succession Act, 1956” submitted at Chanakya National Law
University, Patna is an authentic record of my work carried out under the
supervision of Ms.Pooja Srivastava I have not submitted this work elsewhere
for any other degree or diploma. I am fully responsible for the contents of my
Project Report.
2
3
ACKNOWLEDGEMENT
I take this opportunity to express my profound gratitude and deep regards to my guide
Ms. Pooja Srivastava for his exemplary guidance, monitoring and constant encouragement
throughout the course of this research. The blessing, help and guidance given by him time to
time shall carry me a long way in the journey of life on which I am about to embark.
I also take this opportunity to express a deep sense of gratitude to Ms. Pooja Srivastava for
providing me this research topic and for her cordial support, valuable information and
guidance, which helped me in completing this task through various stages.
Lastly, I thank almighty, my parents, brother and friends for their constant encouragement
without which this assignment would not be possible.
Thank You!
Vivek Kumar
Roll no:- 1775
3
4
TABLE OF CONTENTS
 Introduction.....................................................................................................05
 Aims and Objectives.........................................................................................06
 Hypothesis.......................................................................................................06
 Research Methodology.................................................................................................07
 Background..................................................................................................................08
 The Hindu Succession Act: Before 2005 Amendment.......................................13

 The Hindu Succession Act 2005 Amendment: A Prologue................................16
 Case Laws.......................................................................................................23
 Conclusion…………………………………………………………………………...29
 Bibliography…………………………………………………………………………31
4
5
1.INTRODUCTION
‘Succession’1 implies the act of succeeding or following, as of events,objects, places in a

series. In the eyes of law however, it holds a different and particular meaning. It implies the
transmission or passing of rights from one to another. In every system of law provision has to
be made for a readjustment of things or goods on the death of the human beings who owned
and enjoyed them.The rules of succession are, in modern systems of law, subject to many
rules. Such rules may be based on the will of a deceased person. However, there are cases
inwhich a will cannot be expressed, when the person holding the property may have died
intestate. In such cases, there need to be some broadly accepted rules upon which the
property shall devolve upon those succeeding him. There can be no doubt, however, that
these rules primarily are the characteristics of the social conditions in which that individual
lived. They represent the view of society as to what ought to be the normal course of
succession in the readjustment of property after the death of a citizen.
It is upon this basis that noted author Mulla states, “the law of inheritance comprises of rules
which govern devolution of property, on the death of the person, upon other persons solely on
account of their relationship with the former.”2] Speaking purely in legal terms, Black’s Law
Dictionary defines inheritance as “receipt of a property from an ancestor under the laws of
intestacy” i.e. “by bequest or device.”3 The Hindu Succession Act: Divergence from tradition
The Hindu law of succession underwent its first modification by the Caste Disabilities
Removal Act, 1850, a general statute, i.e., which applied to all communities and by which
conversion ceased to be a disqualification. The Act applied only to the person who had either
renounced his religion or was deprived of caste, but it did not enable his descendants to claim
the benefit of the provision. This is also the position under the Hindu Succession Act of1956.
Since the traditional Hindu law did not provide for testamentary succession, the Hindus were
permitted to dispose of their property by will for the first time by the Hindu’s Will Act, 1870.
In this regard, Madras passed the Hindu Transfer of Bequests Act in 1914 and finally the
Central Legislature passed the Hindu Disposition of Property Act in 1916. The provisions of
1
Latin: successio, from succedere, to follow after
2
Mulla, Hindu Law (2), (Butterworths, New Delhi, 2001), 277.
3
Bryan A. Garner (ed.), Black Law Dictionary, (West Group. St. Minn, 7th
edition), 787.
5
6
the Hindu’s Will Act, 1870 were, with some modifications, re- enacted in the Indian
Succession Act, 1925, which now governs the testamentary succession among Hindus. It is
also permitted by Section 30 of the Hindu Succession Act, 1956.
The Hindu Inheritance (Removal of Disabilities) Act, 1928, removedthe disqualification of
congenital lunacy and idiocy. Though this statute has not been expressly repealed, a similar
provision has been enacted in the Hindu Succession Act, 1956.The Hindu Women’s Right to
Property Act, 1937, was passed to amend the Hindu law of all schools so as to confer greater
rights on certain women than they had. It conferred upon the widow of a man, the right to
inherit to the property even when he left behind a male issue.
The Rau Committee on the Hindu Law Reforms submitted a comprehensive Report and a
draft Hindu Code Bill in 1948 which proposed to reform and codify the entire Hindu law.
Finally, the Hindu Marriage Act was passed in 1955 and the Hindu Succession Act and
Hindu Minority and Guardianship Act were passed in 1956.
AIMS AND OBJECTIVES
The main aim of the research work is to know in detail about Hindu Lw of succession act and
also know about the Changes brought about by the Hindu Succession Act of 1956.
HYPOTHESIS
The Researcher Presumes That There is no Relevance of These Schools in Current Situation.
RESEARCH METHODOLOGY
For the purpose of research, the researcher has followed the doctrinal method of research. The
researcher has relied upon various secondary sources to look for information related to the
information about the Hindu Succession Act1956. The researcher has done his initial research
keeping in mind the various frequently asked questions related to this topic.
The researcher has referred to renowned authors on subjects relating to Family Law. The
researcher has started his research by looking at the given topic critically. The researcher has
further relied upon various primary sources of information like newspapers, law journals,
editorials and articles to look for information related to recent changes brought by hindu
succession( amendment )act,1956.
6
7
SOURCES OF DATA
The researcher will be relying on both primary and secondary sources to complete the
project.
1. Primary Sources : Books.
2. Secondary Sources :Material available on the internet.
LIMITATIONS OF THE PROJECT

The researcher has territorial and monetary limitants in completing the project at hand
morever, taking the time into consideration, the researcher has to rely upon the doctrinal
method of research.
7
8
2.BACKGROUND
The United Nation's Report in 1980 presented that:
"Women constitute half the world's population, perform nearly two-thirds of its hours,
receive one-tenth of the world's income and less than one hundredth of the property."
Succession implies the act of succeeding or following, as of events, objects, places in a series.
In the eyes of law however, it holds a different and particular meaning. It implies the
transmission or passing of rights from one to another. In every system of law provision has to
be made for a readjustment of things or goods on the death of the human beings who owned
and enjoyed them.
Succession, in the sense of the partition or redistribution of the property of a former owner is,
in modern systems of law, subject to many rules. Such rules may be based on the will of a
deceased person. However, there are cases in which a will cannot be expressed and
eventually, there needs to be some broadly accepted rules upon which the property shall
devolve upon those succeeding him. There can be no doubt, however, that these rules
primarily are the characteristics of the social conditions in which that individual lived. They
represent the view of society at large as to what ought to be the normal course of succession
in the readjustment of property after the death of a citizen.
Since time immemorial the framing of all laws have been exclusively for the benefit of man,
and woman has been treated as subservient, and dependent on male support. The right to
property is important for the freedom and development of a human being. Prior to the Hindu
Succession Act, 1956 shastric and customary laws that varied from region to region governed
Hindus and sometimes it varied in the same region on a caste basis resulting in diversity in
the law. Consequently in matters of succession also, there were different schools, like
Dayabhaga in Bengal and the adjoining areas; Mayukha in Bombay, Konkan and Gujarat and
Marumakkattayam or Nambudri in Kerala and Mitakshara in other parts of India with slight
variations The multiplicity of succession laws in India, diverse in their nature, owing to their
varied origin made the property laws even mere complex. Earlier, woman in a joint Hindu
family, consisting both of man and woman, had a right to sustenance, but the control and
8
9
ownership of property did not vest in her. In a patrilineal system, like the Mitakshara school
of Hindu law, a woman, was not given a birth right in the family property like a son.
Discrimination against women is so pervasive that it sometimes surfaces on a bare perusal of

the law made by the legislature itself. This is particularly so in relation to laws governing the
inheritance/succession of property amongst the members of a Joint Hindu family. It seems
that this discrimination is so deep and systematic that it has placed women at the receiving
end. Recognizing this the Law Commission4 in pursuance of its terms of reference, which,
inter alia, oblige and empower it to make recommendations for the removal of anomalies,
ambiguities and inequalities in the law, they decided to undertake a study of certain
provisions regarding the property rights of Hindu women under the Hindu Succession Act,
1956.
Background
A woman in a joint Hindu family, consisting both of man and woman, had a right to
sustenance, but the control and ownership of property did not vest in her. In a patrilineal
system, like the Mitakshara school of Hindu law, a woman, was not given a birth right in the
family property like a son. Under the Mitakshara law, on birth, the son acquires a right and
interest in the family property. According to this school, a son, grandson and a greatgrandson
constitute a class of coparcenars, based on birth in the family. No female is a member of the
coparcenary in Mitakshara law. Under the Mitakshara system, joint family property devolves
by survivorship within the coparcenary. This means that with every birth or death of a male
in the family, the share of every other surviving male either gets diminished or enlarged. If a
coparcenary consists of a father and his two sons, each would own one third of the property.
If another son is born in the family, automatically the share of each male is reduced to one
fourth.
The Mitakshara law also recognises inheritance by succession but only to the property
separately owned by an individual, male or female. Females are included as heirs to this kind
of property by Mitakshara law. Before the Hindu Law of Inheritance (Amendment) Act 1929,
the Bengal, Benares and Mithila subschools of Mitakshara recognised only five female
relations as being entitled to inherit namely - widow, daughter, mother, paternal grandmother,
4
174th Report of Law Commission of India under the Chairmanship of Justice B.P. Jeevan Reddy, vide D.O.
No. 6(3)(59)/99-LC(LS), dated 5th May, 2000.
9
10
and paternal great-grandmother5. The Madras sub-school recognised the heritable capacity of
a larger number of females heirs that is of the son's daughter, daughter's daughter and the
sister, as heirs who are expressly named as heirs in Hindu Law of Inheritance (Amendment)
Act, 1929 6. The son's daughter and the daughter's daughter ranked as bandhus in Bombay
and Madras. The Bombay school which is most liberal to women, recognised a number of
other female heirs, including a half sister, father's sister and women married into the family
such as stepmother, son's widow, brother's widow and also many other females classified as
bandhus.
The Dayabhaga school neither accords a right by birth nor by survivorship though a joint
family and joint property is recognized. It lays down only one mode of succession and the
same rules of inheritance apply whether the family is divided or undivided and whether the
property is ancestral or selfacquired. Neither sons nor daughters become coparceners at birth
nor do they have rights in the family property during their father's life time. However, on his
death, they inherit as tenants-in-common. It is a notable feature of the Dayabhaga School that
the daughters also get equal shares along with their brothers. Since this ownership arises only
on the extinction of the father's ownership none of them can compel the father to partition the
property in his lifetime and the latter is free to give or sell the property without their consent.
Therefore, under the Dayabhaga law, succession rather than survivorship is the rule. If one of
the male heirs dies, his heirs, including females such as his wife and daughter would become
members of the joint property, not in their own right, but representing him. Since females
could be coparceners, they could also act as kartas, and manage the property on behalf of the
other members in the Dayabhaga School. However, during the British regime, the country CHANAKYA NATIONA L LAW UNIVERSITY
became politically and socially integrated, but the British Government did not venture to
interfere with the personal laws of Hindus or of other communities. During this period,
however, social reform movements raised the issue of amelioration of the woman's position
in society.
The earliest legislation bringing females into the scheme of inheritance is the Hindu Law of
Inheritance Act, 1929. This Act, conferred inheritance rights on three female heirs, i.e., son's
daughter, daughter's daughter and sister (thereby creating a limited restriction on the rule of
5
Mulla, Principles of Hindu Law (1998 17th ed. by SA Desai), p. 168.
6
Ibid.
1
0
11
survivorship). Another landmark legislation conferring ownership rights on woman was the
Hindu Women's Right to Property Act (XVIII of) 1937.
This Act brought about revolutionary changes in the Hindu Law of all schools, and brought
changes not only in the law of coparcenary but also in the law of partition, alienation of
property, inheritance and adoption.7 The Act of 1937 enabled the widow to succeed along
with the son and to take a share equal to that of the son. But, the widow did not become a
coparcener even though she possessed a right akin to a coparcenary interest in the property
and was a member of the joint family. The widow was entitled only to a limited estate in the
property of the deceased with a right to claim partition 8. A daughter had virtually no
inheritance rights. Despite these enactments having brought important changes in the law of
succession by conferring new rights of succession on certain females, these were still found
to be incoherent and defective in many respects and gave rise to a number of anomalies and
left untouched the basic features of discrimination against women. These enactments now
stand repealed.
The framers of the Indian Constitution took note of the adverse and discrimnatory position of
women in society and took special care to ensure that the State took positive steps to give her
equal status. Articles 14, 15(2) and (3) and 16 of the Constitution of India, thus not only
inhibit discrimination against women but in appropriate circumstances provide a free hand to
the State to provide protective discrimination in favour of women. These provisions are part
of the Fundamental Rights guaranteed by the Constitution. Part IV of the Constitution
contains the Directive Principles which are no less fundamental in the governance of the State
and inter alia also provide that the State shall endeavor to ensure equality between man and
woman. Notwithstanding these constitutional mandates/directives given more than fifty years
ago, a woman is still neglected in her own natal family as well as in the family she marries
into because of blatant disregard and unjustified violation of these provisions by some of the
personal laws. Pandit Jawaharlal Nehru, the then Prime Minister of India expressed his
unequivocal commitment to carry out reforms to remove the disparities and disabilities
suffered by Hindu women. As a consequence, despite the resistance of the orthodox section
7
Mayne's, Treatise on Hindu Law & Usage, (1996 14th Edn., edt. by Alladi Kuppuswami p. 1065.
8
M. Indira Devi, "Woman's Assertion of Legal Rights to Ownership of property" in Women & Law
Contemporary Problems, (1994 edt. by L. Sarkar & B. Sivaramayya) p. 174; also section 3(3) of Hindu
Women's Right to Property Act, 1937.
1
1
12
of the Hindus, the Hindu Succession Act, 1956 was enacted and came into force on 17th
June, 1956. It applies to all the Hindus including Buddhists, Jains and Sikhs. It lays down a
uniform and comprehensiye system of inheritance and applies to those governed both by the
Mitakshara and the Dayabahaga Schools and also to those in South India governed by the the
Murumakkattayam, Aliyasantana, Nambudri and other systems of Hindu Law.
1
2
13
3.THE HINDU SUCCESSION ACT: BEFORE 2005 AMENDMENT
The very preamble of the Act signifies that an Act to amend and codify t law relating to
intestate succession among Hindus. The Act aims to lay down an uniform law of succession
whereas attempt has been made to ensure equality inheritance rights between sons and
daughters. It applies to all Hindus including Budhists, Jains and Sikhs. It lays down an
uniform and comprehensive system of inheritance and .applies to those governed by the
Mitakshara and Dayabha schools as well as other9 schools. The Hindu Succession Act
reformed the Hindu personal law and gave women greater property rights, allowing her f
ownership rights instead of limited rights in property.
The daughters were also granted property rights in their father's estate. In the matter of
succession of property of a Hindu male dying intestate, the Act lays, down a set of general
rules in sections 8 to 13. Sections 15 and 16 of the act contain separate general rules affecting
succession to the property of a fem intestate. Under section 8 of the Act three Classes10 of
heirs recognized by Mitakshara Law and three Classes11 of heirs recognised by Dayabhaga
Law cease exist in case of devolution taking place after coming into force of the Act. The
heirs are divided into instead, four Classes viz:
(i) Heirs in Class I of the Schedule
(ii) Heirs in Class II of the Schedule
(iii) Agnates, and
(iv) Cognates.
Of course mother, widow, son and daughter are primary heirs. In the absence of Class I heirs,
the property devolves on Class II heirs and in their absence first on agnates and then on
cognates. Still some sections of the Act came under criticism evoking controversy as being
favourable to continue inequality on the basis of gender. One such provision has been the
retention of mitakshara coparcenary with only males as coparceners12.
9
Murumakkattayam, Aliyasantans and Nambudri.
10
Gotraja, Sapindas, Samanodlakas and Bandhus
11
Sapindas, Sakulyas and Bandhus
12
7th Report of Parliamentary Standing Committee dated 13th May, 2005.
1
3
14
As per the Law Commission Report, coparcenary constitutes a narrower body of persons
within a joint family and consists of father, son, son's son and son's son's son. Thus ancestral
property continues to be governed by a wholly patrilineal regime, wherein property descends
only through the male line as only the male members of a Joint Hindu Family have an interest
by birth in the coparcenary property, in contradiction with the absolute or separate property
of an individual coparcener, devolve upon surviving coparceners in the family, according to
the rule of devolution by survivorship. Since a woman could not be a coparcener, she was not
entitled to a share in the ancestral property by birth.Section 6 of the Act, although it does not
interfere with the special rights of I those who are members of a mitaksltara coparcenary,
recognises, without abolishing joint family property, the right upon death of a coparcener, of
certain members of his preferential heirs to claim an interest in the property that would have
been allotted to such coparcener if a parititon13 of the joint family property had in fact taken
place immediately before his death.
Thus section 6 of the Act, while recognising the rule of devolution by survivorship among the
members of the coparcenary, makes an exception to the rule in the proviso. According to the
proviso, if the deceased has left a surviving female relative specified in Class I of the
Schedule I or a male relative specified in that Class who claims through such female relation,
the interest of a deceased in mitakshara coparcenary property shall devolve by testamentary
of intestate succession under the Act and not as survivorship14. Thus non-conclusion of
women as coparceners in the joint family property under the mitakshara system as reflected
in section 6 of the Act relating to devolution of interest in coparcenary property, has been
under criticism for being violative of the equal rights of women guaranteed under the CHANAKYA NATIONA L LAW UNIVERSITY
Constitution in relation to property rights. This means that females cannot inherit ancestral
property as males do. If a joint family gets divided, each male coparcener takes his share and
females get nothing. Only when one of the coparceners dies, a female gets share of his
interest as an heir to the deceased. Further as per the proviso to section 6 of the Act, the
interest of the deceased male in the mitakshara coparcenary devolve by intestate succession
firstly upon the heirs specified in Class I of Schedule I. Under this Schedule there are only
four primary heirs, namely son, daughter, widow and mother. For the remaining eight, the
principle of representation goes up to two degrees in the male line of descent. But in the
13
Notional partition.
14
7th Report of Parliamentary Standing Committee
1
4
15
female line of descent, it goes only upto one degree. Thus the son's son's son and the son's
son's daughter get a share but a daughter's daughter's son and daughter's daughter's daughter
do not get anything.
Again as per section 23 of the Act married daughter is denied the right to residence in the
parental home unless widowed, deserted or separated from her husband and female heir has
been disentitled to ask for partition in respect of dwelling house wholly occupied by members
of joint family until the male heirs choose to divide their respective shares therein. These
provisions have been identified as major sources of disabilities thrust by law on woman.
Another controversy is the establishment of the right to will the property. A man has full
testamentary power over his property including his interest in the coparcenary.
On the whole the Hindu Succession Act15 gave a weapon to a man to deprive a woman of the
rights she earlier had under certain schools of Hindu Law. The legal right of Hindus to
bequeath property by way of will was conferred by the Indian Succession Act, 1925.
15
Before amendment of Hindu Succession Act, 1956 in 2005
1
5
16
4.THE HINDU SUCCESSION ACT - A PROLOGUE:
This amending Act of 2005 is an attempt to remove the discrimination as contained in the
amended section 6 of the Hindu Succession Act, 1956 by giving equal rights to daughters in
the Hindu mitakshara coparcenary property as to sons have. Simultaneously section 23 of the
Act as disentitles the female heir to ask for partition in respect of dwelling house wholly
occupied by a Joint Family until male heirs choose to divide their respective shares therein,
was omitted by this Amending Act. As a result the disabilities of female heirs were
removedThis is a great step of the government so far the Hindu Code is concerned.
This is the product of 174th Report of the Law Commission of India on "Property Rights of
Women: Proposed Reform under the Hindu Law". First, the 2005 act, by deleting a major
gender discriminatory clause - Section 4 (2) of the 1956 HSA - has made women's
inheritance rights in agricultural land equal to men's. Section 4(2) excluded from the purview
of the HSA significant interests in agricultural land, the inheritance of which was subject to
the succession rules specified in state-level tenurial laws. Especially in the north-western
states, these laws were highly gender unequal and gave primacy to male lineal descendants in
the male line of descent. Women came very low in the succession order and got only a
limited estate. The new legislation brings male and female rights in agricultural land on par
for all states, overriding any inconsistent state laws. This can potentially benefit millions of
women dependent on agriculture for survival. Second, the 2005 act makes all daughters,
including married ones, coparceners in joint family property. The 1956 HSA distinguished
between separate property and joint family property.
The separate property of a (non-matrilineal) Hindu male dying intestate (without leaving a
will) went equally to his class I heirs, viz, son, daughter, widow and mother (and specified
heirs of predeceased children). On joint family property, those previously governed by
`Mitakshara' (prevailing in most of India) differed from those governed by `Dayabhaga'
(prevailing in Bengal and Assam). For the latter, joint family property devolved like separate
property. But in Mitakshara joint family property, while the deceased man's "notional" share
went intestate to all class I heirs (including females) in equal parts; sons, as coparceners,
additionally had a direct birthright to an independent share. Sons could also demand partition
of the joint family property; daughters could not. The 2005 act does not touch separate
1
6
17
property. But it makes daughters coparceners in the Mitakshara joint family property, with
the same birthrights as sons to shares and to seek partition. In addition, the act makes the
heirs of predeceased sons and daughters more equal. Third, the 2005 act by deleting Section
23 of the 1956 HSA gives all daughters (including those married) the same rights as sons to
reside in or seek partition of the parental dwelling house. Section 23 disallowed married
daughters (unless separated, deserted or widowed) even residence rights in the parental home,
and unmarried daughters had rights of residence but not partition. Fourth, the legislation
removes a discriminatory section which barred certain widows from inheriting the deceased's
property, if they had remarried.
According to the amending Act of 2005, in a Joint Hindu Family governed by the mitakshara
Law, the daughter of a coparcener shall, also by birth become a coparcener in her own right
in the same manner as the son heir. She shall have the same rights in the coparcenary
property as she would have had if she had been a son. She shall be subject to the same
liabilities and disabilities in respect of the said coparcenary property as that of a son and any
reference to a Hindu mitakshara coparencer shall be deemed to include a reference to a
daughter. But this provision shall not apply to a daughter married before the commencement
of the Hindu Succession (Amendment) Act of 2005.
This provision shall not affect or invalidate any disposition or alienation including partition
or testamentary disposition of property which had taken place before 20th December,
2004.Further any property to which female Hindu becomes entitled by virtue of above
provision shall be held by her with the incidents of coparcenary ownership and shall be
regarded, as property capable of being disposed of by her by will and other testamentary
disposition. The provision was also made that where a Hindu dies after the commencement of
the Hindu Succession (Amendment) Act of 2005, his interest in the property of a Joint Hindu
Family governed by the Mitakshara Law, shall devolve by testamentary or intestate
succession under the Act and not by survivorship, and the coparcenary property shall be
deemed to have been divided as if a partition had taken place.
Further the daughter is allotted the same share as is allotted to a son. The provision was also
made that the share of the predeceased son or a predeceased daughter as they would have got,
had they been alive at the time of partition, shall be allotted to the surviving child of such
predeceased son or of such predeceased daughter.
1
7
18
Further the share of the pre-deceased child of a predeceased son or of a pre deceased daughter
as such child would have got, had he or she been alive at the time of the partition, shall be
allotted to the child of such pre-deceased child of the pre-deceased son or a pre-deceased
daughter. The most important fact is that the interest of a Hindu mitakshara coparcener shall
be deemed to be the share in the property that would have been allotted to him if a partition
of the property bad taken place immediately before his death, irrespective of whether he was
entitled to claim partition or not. This amending Act of 2005 has also clear provision that,
after commencement of the Amending Act of 2005, no court shall recognise any right to
proceed against a son, grandson or great grandson for the recovery of any debt due from his
father, grandfather or great grandfather (on the ground of the pious obligation under the
Hindu Law), of such son, grandson or great grandson to discharge any such debt. But if any
debt contracted before the commencement this Amending Act of 2005 the right of any
creditor, to proceed against son, grandson or great grandson, shall not affect or any alienation
relating to any such debt or right shall be enforceable under the rule of pious obligation in the
same manner and to the same extent as it would have been. enforceable as if Hindu
Succession Amending Act of 2005 had not been enacted.
Further for the purpose of creditors right stated above the expression son, grandson or great
grandson shall be deemed to refer to the son, grandson or great grandson who was born or
adopted prior to the commencement (9th September, 2005) of the Amending Act of 2005.
Such provisions shall not apply to a partition which has been done before 20th December,
2004. Sections 23 and 24 omitted. Likewise special provisions relating to rights in respect of
dwelling house and the disentitlement rights of widow's remarrying, respectively omitted CHANAKYA NATIONA L LAW UNIVERSITY
from the Act. The Amending Act also in the Schedule of the Hindu Succession Act, 1956
added new heirs viz, son of a pre-deceased daughter of a pre-deceased daughter of a pre-
deceased daughter daughter of a pre-deceased daughter, son of a pre-deceased daughter,
daughter of a pre-deceased son.
Thus the amendment of Hindu Succession Act of 1956 in 2005 is a total commitment for the
women empowerment and protection of women's right to property. This Amending Act in a
partrilineal system, like mitakshara School of Hindu Law opened the door for the women, to
have the birth right in the family property like the son. The women were vested the right of
control and ownership of property beyond their right to sustenance.
1
8
19
Amendments To The Hindu Succession Act And Gender Equality

The recent legislative proposals amending the Hindu Succession Act are important steps
towards gender equality and abolition of the patrilineal system of inheritance prevailing
among Hindus. These proposals are based on the 174th Report of the Law Commission
published in 2000 and seek to give Hindu women equal rights in the Mitakshara Joint Family
Property. The proposed Bill also seeks to do away with Section 23 of the Hindu Succession
Act which denies a woman the right to seek partition of an inherited ?dwelling? unit / house
if other male heirs are residing in it and further restricts her right to reside in the inherited
residence unless she is a widow or has been separated from or deserted by her husband.
However, the proposed changes are not comprehensive enough and women will still be
subjected to unequal property rights in agricultural land as Section 4(2) of the Hindu
Succession Act allows for special State laws to address the issue of fragmentation of
agricultural holdings, fixation of ceiling and devolution of tenancy rights in these holdings.
Thus, State laws exist in Delhi, U.P, Madhya Pradesh, Punjab & Haryana, which deny
women equal rights of succession in tenancy rights. Further, certain other Sections of the
Hindu Succession Act discriminate against women through the discriminatory order of
succession for male & female heirs. The proposed Amendments to the Mitakshara Joint
Family Property laws making women equal coparceners are sought to be made applicable
only to women who are not married at the time the law is passed and is thus patently unjust
also.
When the Hindu Succession Act was passed in 1956, the Mitakshara coparcenery system was
retained and the then Government refused to abolish this system of Joint family in spite of
contrary recommendations by the Select Committee and protest by AIWC. Under the
Mitakshra System of Joint Family, which prevails in all parts of India apart from Bengal only
males are members (coparceners) of the Joint Family and the right to inheritance was by way
of survivorship and not by way of succession . The son acquired a right and interest in Joint
Family Property on birth while a woman family member only had a right to maintenance.
However the Hindu Succession Act gave a share to the first class female heirs (daughters and
wives) in the share of the father / husband in the joint family property who died intestate
(without making a will). However this share was not equal to the share, which a son
inherited, since the son was deemed to be coparcener (member of the joint family) by birth.
1
9
20
For e.g. in a joint family consisting of a father, a son and a daughter, both the father and the
son, according to the Mitakshara coparcenary system , would be equal owners of the
property. Thus when the father died, after the 1956 Act, his share would devolve equally on
both the son and daughter. However the daughter in this particular case would only get 1/4th
share of the property whereas the brother who was already a co owner would have his half
share plus 1/4th share of the property. The Amendment cleared by the Union Cabinet
proposes to make the daughter also a coparcener in the Joint Family Property. It is pertinent
to point out that some states like Karnataka, Andhra Pradesh, Maharashtra and Tamilnadu
have already passed laws making the daughter a member (coparcener) of the joint family
while other states like Kerala have completely abolished the joint family system.
This could be done as laws of succession fall in Entry 5 of the concurrent list of the VIII th
Schedule to the Constitution. It is relevant to note that the Hindu Code Bill, as originally
framed by the B.N.Rao committee and piloted by Dr B.R.Ambedkar, had recommended
abolishing the Mitakshara coparcenery with its concept of survivorship and the son?s right by
birth in a joint family system and substitute it with a principle of inheritance by succession. In
fact, AIDWA had also during the Dowry Prohibition Act amendments in early 1980s, asked
for abolition of the Joint family System. In this sense the Amendment doesn't go far away.
The other Amendment, which was cleared by the Cabinet, was to abolish Section- 23 of the
Hindu Succession Act 1956. This provision denies a married daughter the right to residence
in an inherited parental home unless she is widowed, deserted or separated from her husband.
The section further denies the daughter, who has inherited a house along with a male member
of a family from asking for her share of the property if any member of the family resides in CHANAKYA NATIONA L LAW UNIVERSITY
the inherited house, until the male heirs also agreed. However, no such restriction has been
placed by the Section 23 on a male heir.
Apart from this the proposed amendment seeks to make the new law applicable only to those
women who are not married at the date of the amendment. This provision is based on the
Maharashtra Law and is said to be made on the presumption that women, who are married
have already received their share of property etc. as dowry / gift during their marriage. This is
patently unfair not only because many women may not have received dowry but also because
the amount of dowry received can hardly be equated to equal rights in property. In reality this
2
0
21
is a devise to restrict the number of women, who inherit and to maintain status quo as far as
possible.
Apart from the obvious discrimination in Section 6 and Section 23 discussed above, certain
other sections of Hindu Succession Act also blatantly discriminate against women and require
amendment. The most important section, which has been used to deny property rights to
women in agricultural land, is Section 4 (2) of the Hindu Succession Act, which allows for
State legislation to prevail over the Hindu Succession Act. This Section states that the Act
shall not apply to laws ?providing for the prevention of fragmentation of agricultural holdings
or for fixation of ceilings or for the devolution of tenancy rights in respect of such holdings?.
Judgments under this Section have upheld laws under Section 4 (2) of the Hindu Succession
Act and have mostly denied women equal rights in agricultural land. While some courts have
held that the Hindu Succession Act will apply to agricultural holding, this can only be in the
absence of State laws for the purposes mentioned in Section 4 (2) or if the States laws under
Section 4(2) themselves apply the Hindu Succession Act or personal laws to ?devolution of
tenancy rights?. Courts have upheld the State Land Reform Acts, relating to devolution of
tenancy rights even though these do not allow women to inherit these tenancies. Some courts
have further interpreted the term ?devolution? of tenancy rights broadly / comprehensively to
include devolution of tenure holder's right and have thus also denied women ownership rights
over agricultural land.
Thus even laws meant for land reform and to enforce ceiling have resulted in denying to
women equal rights over land and a chance to improve her disempowered status. Section 30
of the Hindu Succession Act allows any Hindu to dispose off his property including his share
in the Joint Family Property by will. As has been pointed by women's organizations/ groups
and activists this Section can and has been used to disinherit women. It has been
recommended by many that a limitation should be placed on the right to will. Such a
provision exists in Muslim law where a Muslim can only Will away up to a maximum of -
1/3rd of his property.
Section 15 of the Hindu Succession Act which specifies how the property of a female Hindu
will devolve also contains certain discriminatory provisions. It states that in the absence of
class I heirs( son, daughters & husband) the property of a female Hindu will go to her
husband's heirs and only if these heirs are not then will the property devolve upon her mother
2
1
22
and father. However, in the absence of the mother and father, the property will again devolve
upon the heirs of the father and only if there are no heirs of father will the property devolve
upon the heirs of the mother.
The proviso to Section-6 of Hindu Succession Act contains another instance of gender bias.
The proviso states that the property of the deceased in the Mitakshara Coparcenary shall
devolve by intestate succession if the deceased had a female heir or a male heir who claims
through such female relative. In order to appreciate the gender bias it is necessary to see the
rules of devolution of interest under section 8 of the Hindu Succession Act. In this section
there are only four primary heirs in the Schedule to class I, namely, mother, widow, son and
daughter. If, however, for example the son or daughter has already died, their children can
inherit the property. The principle of representation goes up to two degree in the male line of
descent; but in the female line of descent it goes only upto one degree. Accordingly, the
deceased son's son's son and son's son's daughter get a share but a deceased daughter's
daughter's son and daughter's daughter's daughter do not get anything. A further infirmity is
that a widow of a pre-deceased son and grandson are class-I heirs, but the husbands of a
deceased daughter or grand-daughter are not heirs.
2
2
23
5.CASE LAWS
In Anar Devi and Ors. Vs. Parmeshwari Devi and Ors.16sthe Supreme Court held that
“Thus we hold that according to Section 6 of the Act when a coparcener dies leaving behind
any female relative specified in Class I of the Schedule to the Act or male relative specified
in that class claiming through such female relative, his undivided interest in the Mitakshara
coparcenary property would not devolve upon the surviving coparcener, by survivorship but
upon his heirs by intestate succession. Explanation 1 to Section 6 of the Act provides a
mechanism under which undivided interest of a deceased coparcener can be ascertained and,
i.e., that the interest of a Hindu Mitakshara coparcener shall be deemed to be the share in the
property that would have been allotted to him if a partition of the property had taken place
immediately before his death, irrespective of whether he was entitled to claim partition or
not. It means for the purposes of finding out undivided interest of a deceased coparcener, a
notional partition has to be assumed immediately before his death and the same shall devolve
upon his heirs by succession which would obviously include the surviving coparcener who,
apart from the devolution of the undivided interest of the deceased upon him by succession,
would also be entitled to claim his undivided interest in the coparcenary property which he
could have got in notional partition. In the case on hand, notional partition of the suit
properties between Nagarmal and his adopted son Nemi Chand has to be assumed
immediately before the death of Nagarmal and that being so Nagar Mal's undivided interest
in the suit property, which was half, devolved on his death upon his three children, i.e., the
adopted son Nemi Chand and the two daughters who are plaintiffs in equal proportion. Nemi
Chand, the adopted son, would get half of the entire property which right he acquired on the
date of adoption and one third of the remaining half which devolved upon him by succession
as stated above. This being the position, each of the two plaintiffs was not entitled to one-
third share in the suit property, but one-sixth and the remaining properties would go to the
adopted son, Nemi Chand.
The suit properties in the hands of Nagar Mal were ancestral one in which his son Nemi
Chand got interest equal to Nagar Mal after his adoption and from the date of adoption, a
16
AIR 2006 SC
2
3
24
coparcenary was constituted between the father and the adopted son. Upon the death of
Nagar Mal, the property being ancestral, the half undivided interest of Nagar Mal therein
devolved by rule of succession upon his three heirs, including Nemi Chand. This being the
position each of the daughters would be entitled to one-sixth share in the suit properties and
the remaining would go to the heirs of Nemi Chand, since deceased.”
The Supreme Court in R. Mahalakshmi Vs. A.V. Anantharaman and Ors.17 held that:
“Perusal of the aforesaid provision of law makes it abundantly clear that the daughters who
have got married prior to 1989 may not have equal share as that of a son but the daughters
who got married after 1989 would have equal share as that of a son. In other words,
daughters who got married after 1989 would be treated at par with son having the same share
in the property.”
The Madras High Court, in Smt. Bagirathi and Ors. vs. S. Manivanan and Anr., 18 opined
that:
“a careful reading of Section 6(1) read with 6(3) of the Hindu Succession (Amendment) Act
clearly indicates that a daughter can be considered as a coparcener only if her father was a
coparcener at the time of coming into force of the amended provision. It is of course true that
for the purpose of considering whether the father is a coparcener or not, the restricted
meaning of the expression "partition" as given in the explanation is to be attributed. In the CHANAKYA NATIONA L LAW UNIVERSITY
present case, admittedly the father of the present petitioners had expired in 1975.
Section 6(1) of the Act is prospective in the sense that a daughter is being treated as
coparcener on and from the commencement of the Hindu Succession (Amendment) Act,
2005. If such provision is read along with Section 6(3), it becomes clear that if a Hindu dies
after commencement of the Hindu Succession (Amendment) Act, 2005, his interest in the
property shall devolve not by survivorship but by intestate succession as contemplated in the
Act.”
17
(2009) 9 SCC
18
2008 Mad 250
2
4
25
Critical Appraisal Of Amendments To The Hindu Succession Act

The recent amendment to the Hindu Succession Act has made the daughter a member of the
coparcenary. It also gives daughters an equal share in agricultural property. These are
significant advancements towards gender equality. The Hindu Succession (Amendment) Bill
2004, passed unanimously by the Lok Sabha, comes after a long gap: the Hindu Succession
Act was passed in 1956. The present debate about removing discrimination against women to
a large extent remains confined to the experts. The law, obtuse at the best of times, takes on
an even more tedious character when it comes to inheritance laws.
For almost half a century since the passing of the Hindu Succession Act, 1956, there has been
the widespread belief that under Hindu personal law daughters are equal to sons. This belief
was based on Section 10 of the Act dealing with the distribution of property of a Hindu who
has died without making a will, referred to as ?intestate? in law. The provision unequivocally
declares that property is to be distributed equally among Class I heirs, as specified in the
schedule. The schedule clearly lays down daughters, mothers and widows as Class I heirs
entitled to a share equal to that of sons. This, though seemingly a huge step in favour of
gender justice, was in fact more a sleight of hand.
The mischief lay in customary Hindu law and the concept of mitakshara
coparcenary property. A Hindu joint family consists of a common ancestor and all his lineal
male descendants, together with wives or widows and unmarried daughters. The existence of
a common ancestor, necessary to bring a joint Hindu family into existence, continues even
after the death of the ancestor. Upper links are removed and lower ones are added; the joint
family can continue indefinitely. Except in the case of adoption, no outsiders are permitted
and membership to the joint family is by birth or marriage to a male member. A Hindu joint
family is a unit and is represented by the karta or head.
The Hindu Succession Act retained the coparcenary. In fact, Section 6 specifically declares
that, on death, the interest of a male Hindu in mitakshara coparcenary property shall devolve
by survivorship to other members of the coparcenary and not by succession under the Act.
However, it laid down that the separate share of the deceased, computed through the device
of a deemed partition just before his death, would devolve according to the Succession Act.
2
5
26
The Act did not clearly spell out the implications of exclusion from membership to the
coparcenary in respect of inheritance of property. Thus, if a widowed Hindu male died
leaving a son and a daughter, then, according to the explanation in Section 6 of the Act, there
will be deemed to be a partition just before the death of the person. In this deemed or
?notional? partition, the father and son share equally and each gets half the property. The
father's half will be shared equally by his son and daughter as Class I heirs. In effect,
therefore, the daughter gets one-fourth of the property, while the son gets his own half from
the deemed partition as a coparcener and an additional half from the share of his father.
Together that would be three-fourths of the property. It is this inequity between son and
daughter that has now been removed by the amendment.
The preferential right by birth of sons in joint family property, with the offering
of shradha for the spiritual benefit and solace of ancestors, have for centuries been considered
sacred and inviolate. It has also played a major role in the blatant preference for sons in
Indian society. This amendment, in one fell swoop, has made the daughter a member of the
coparcenary and is a significant advancement towards gender equality.
After the amendment, daughters will now get a share equal to that of sons at the time of the
notional partition, just before the death of the father, and an equal share of the father's
separate share. However, the position of the mother vis-a-vis the coparcenary stays the same.
She, not being a member of the coparcenary, will not get a share at the time of the notional
partition. The mother will be entitled to an equal share with other Class I heirs only from the
separate share of the father computed at the time of the notional partition. In effect, the actual
share of the mother will go down, as the separate share of the father will be less as the
property will now be equally divided between father, sons and daughters in the notional
partition.
The original bill, introduced in 2004, exempted agricultural land from the purview of the
amendment. A considerable section of society is totally against equal shares to daughters with
respect to agricultural land. The inclusion of agricultural land in the amendment, giving equal
shares to daughters and overriding state-level discriminatory tenurial laws, is a great credit to
parliament. Effective lobbying by women's groups must also be given due credit.
2
6
27
The equal sharing of the father's property applies in cases where he dies intestate -- that is,
without making a will. Given the bias and preference for sons and notions of lineage,
discrimination against daughters in inheritance through wills is bound to remain. In most
cases, the terms of the will would favour the son. Perhaps the share of property that can be
willed by a person could be restricted, as a step towards greater gender equality. For example,
Islamic jurisprudence lays down that a person can only will one-third of his property.
Provisions to check the prevalent practice of persuading daughters to give up their share in
joint family property is another area that requires attention. This is an opportune time to keep
up the momentum for further reforms to reduce gender inequities and move towards a more
equal society.
The amendment will only benefit those women who are born into families that have ancestral
property. There is no precise definition of ancestral property. Given the fact that families
have long since been fragmented and the fact that the joint family system is on the decline, it
is not at all clear whom this law will benefit. It cannot apply to self-acquired property. No
person by birth will acquire any rights in self-acquired property. In today's context, most
property is self-acquired and that property must follow principles of succession under the
different succession laws. Moreover, its owner can dispose off such property during his
lifetime by gift. It can be bequeath by will to anyone of his choice. The proposed amendment
notwithstanding, a Hindu father can disinherit his wife or daughter by will, in his self-
acquired property. The amendment therefore by itself cannot offer much to Hindu women.
What is more, under the laws of certain states, it will actually disadvantage widows, as the
share of the daughter will increase in comparison to the widow. The amendment is not at all CHANAKYA NATIONA L LAW UNIVERSITY
well thought out and can play women against each other. There is no equity in that. Thus,
though seemingly progressive, it does nothing more than make a political point, that the state
is committed to abolishing discrimination against women, but only Hindu women. The
position of women married into the joint family will actually become worse.
The proposed amendment only makes the position of the female members of the joint family
worse. With a daughter along with the sons acquiring a birthright, which she can presumably
partition at any time, the rights of other members of the joint family get correspondingly
diminished. While the reforms of the 1950s disadvantaged a divorced wife, the reforms of the
present times will disadvantage married women as well. Until now, the only protection
2
7
28
women had in the marital home was the status of being married, which carried with it the
right to be maintained, not only by the husband, but by the joint family and its assets as a
whole. Thus married women who lived in a joint Hindu family had the protection of the
family home. This protection will now stand eroded, to the extent that the total divisible
amount gets reduced. Something similar will happen to Hindu widows. Daughters will
acquire a birthright in Hindu joint family property, mothers stand to lose a portion of the
cake, as an inheritance. Since Hindu law does not grant any rights to wives in marital
property, their only chance of getting anything was on an inheritance, as equal share with the
sons and daughters, if the marriage was subsisting on the death of the husband. On divorce,
of course, even that right to inheritance disappears. It is birthright in Hindu law that is the
root of the problem. Birthright by definition is a conservative institution, belonging to the era
of feudalism, coupled as it was with the rule of primogeniture and the inalienability of land.
When property becomes disposable and self-acquired, different rules of succession have to
apply. It is in the making of those rules that gender justice has to be located. What the
proposed amendment does is to reinforce the birthright without working out its consequences
for all women.
Justice cannot be secured for one category of women at the expense of another. It is
impossible to deal with succession laws in isolation. One has to simultaneously look at laws
of matrimonial property, divorce and succession to ensure a gender just regime of laws. The
present bill does nothing of the kind.
2
8
29
6.CONCLUSION
Although the Hindu Succession Act, 1956, and its amendments have gone a long way in
simplifying the rules regulating succession among the Hindus, there are various discripencies
still to be solved.Firstly, the explanation of the amended Section 6 defines “partition” as any
partition made by execution of a deed of partition duly registered under the Registration Act,
1908 or partition effected by a decree of court. This definition of “partition” does not include
oral partition and family arrangement. Since the amended Act has failed to include oral
partition and family arrangement within the definition of “partition”, which are common and
legally accepted modes of division of property under the Hindu Law, the Commission
undertook this subject suo motu. Secondly, the amended Section 6 includes the daughter into
the coparcenary, but no other female has been given recognition as a member of the
coparcenary.
Furthermore, it is only the daughter of the common male ancestor who has been included and
not the daughters of all the coparceners. Justice cannot be secured for one category of women
at the expense of another. It is impossible to deal with succession laws in isolation.
Thus, there is scope of change in the amended Act also. However, it cannot be argued that
The Hindu Succession Act made a revolutionary change in the law relating to succession,
especially for female Hindus. It has been a huge relief for females who were devoid of
property rights under the traditional Hindu law.
Empowerment of women, leading to an equal social status in society hinges, among other
things, on their right to hold and inherit property. Several legal reforms have taken place
since independence in India, including on equal share of daughters to property. Yet equal
status remains illusive. Establishment of laws and bringing practices in conformity thereto is
necessarily a long drawn out process. The government, the legislature, the judiciary, the
media and civil society has to perform their roles, each in their own areas of competence and
in a concerted manner for the process to be speedy and effective.
These amendments can empower women both economically and socially. and have far-
reaching benefits for the family and society. Independent access to agricultural land can
reduce a woman and her family's risk of poverty, improve her livelihood options, and
enhance prospects of child survival, education and health. Women owning land or a house
2
9
30
also face less risk of spousal violence. And land in women's names can increase productivity
by improving credit and input access for numerous de facto female household heads.
Making all daughters coparceners like wise has far-reaching implications. It gives women
birthrights in joint family property that cannot be willed away. Rights in coparcenary
property and the dwelling house will also provide social protection to women facing spousal
violence or marital breakdown, by giving them a potential shelter. Millions of women - as
widows and daughters - and their families thus stand to gain by these amendments.
3
0
31
BIBLIOGRAPHY
Books:
 Diwan Paras (2008), Modern Hindu law, Twentieth Edition, Allahabad Law Agency.
 Shastri Gopalchandra (2008), a Treatise on Hindu Law, Eighth Edition, New Delhi:
Ashoka Law House.
 Subzwari’s (2008), Hindu Law (Ancient & Codified), Second Edition, Ashoka Grover &
Sons.
 Gupte’s, Hindu Law, As Amended by the Hindu Succession (Amendment) Act, 2005
(39 of 2005) (w.e.f. 09-09-2005), Premier Publishing Company.
 Saxena Dr. Poonam Pradhan (2011), Family Law Lectures, Family Law-II, Third
Edition, Nagpur: Lexis Nexis Butterworths Wadhwa.
Articles:
 Hindu Law Reform, V. Govindarajachari

http://yabaluri.org/TRIVENI/CDWEB/HinduLawReform.htm Succession in Hindu
Law:
 Analysis of the Hindu Succession Act, 1956, Raabia Abuzer Shams, Student of
Chanakya National Law University, Patna
http://www.mightylaws.in/878/succession-hindu-law-analysis-hindu-succession-act-
1956
Websites:
 www.indiannow.org.com (visited on March 3, 2019)

 www.shodhganga.inflibnet.ac.in (visited on March 3, 2019)
 www.preservearticles.com ( visited on March 3, 2019)
 www.britanica.com (visited on Marchr 3, 2019)
3
1

Finalfamily Law Final Project

Caricato da

Informazioni sul documento

Titolo originale

Copyright

Formati disponibili

Condividi questo documento

Condividi o incorpora il documento

Opzioni di condivisione

Hai trovato utile questo documento?

Questo contenuto è inappropriato?

Copyright:

Formati disponibili

Finalfamily Law Final Project

Caricato da

Copyright:

Formati disponibili

1

Changes Introduced in The Classical Concept By The Hindu

NYAYA NAGAR MITHAPUR,PATNA-800001

FAMILY LAW-I, PROJECT WORK

“CHANGES INTRODUCED IN THE CLASSICAL

Ms. Pooja Srivastava Submitted By:

Faculty of Family Law Vivek Kumar

Roll no. : - 1775

CHANAKYA NATIONA L LAW UNIVERSITY

Roll no:- 1775

 The Hindu Succession Act: Before 2005 Amendment.......................................13

CHANAKYA NATIONA L LAW UNIVERSITY

‘Succession’1 implies the act of succeeding or following, as of events,objects, places in a

1. Primary Sources : Books.

2. Secondary Sources :Material available on the internet.

LIMITATIONS OF THE PROJECT

CHANAKYA NATIONA L LAW UNIVERSITY

The United Nation's Report in 1980 presented that:

Discrimination against women is so pervasive that it sometimes surfaces on a bare perusal of

CHANAKYA NATIONA L LAW UNIVERSITY

3.THE HINDU SUCCESSION ACT: BEFORE 2005 AMENDMENT

(ii) Heirs in Class II of the Schedule

(iii) Agnates, and

CHANAKYA NATIONA L LAW UNIVERSITY

4.THE HINDU SUCCESSION ACT - A PROLOGUE:

Amendments To The Hindu Succession Act And Gender Equality

CHANAKYA NATIONA L LAW UNIVERSITY

Critical Appraisal Of Amendments To The Hindu Succession Act

CHANAKYA NATIONA L LAW UNIVERSITY

CHANAKYA NATIONA L LAW UNIVERSITY

 Hindu Law Reform, V. Govindarajachari

 www.indiannow.org.com (visited on March 3, 2019)

 www.shodhganga.inflibnet.ac.in (visited on March 3, 2019)

 www.preservearticles.com ( visited on March 3, 2019)

 www.britanica.com (visited on Marchr 3, 2019)

Potrebbero piacerti anche