Article

Scoping Review on Women’s Right to Property: Bird’s Eye View

Author:- Kumar Gaurav and Muskan Vaswani

Keywords: – Legislative Role, Judiciary, Live-in Couples, Senior Citizens, Independence, Property, Indian culture, inheritance, Right to Property

ABSTRACT

This research paper examines the path of various laws from the era of pre-independence to the era of post-independence. Part I of the paper contains the introduction and the structured history of women’s rights over property in India. The Part II of the paper briefly describes the legislative role in framing the laws from time to time and the judiciary’s role in determining the correct sense of rights guaranteed to women through various case laws revolving from 1912 to 2022. Part III compares the rights guaranteed to different categories of women and their different religions regarding right over the property. Furthermore, lastly, Part IV shall operate as further developments in respect of the rights of live-in couples and their children, exclusive rights of senior citizens, and conclusion.

INTRODUCTION

From the beginning of Indian culture, Hindu women’s legal right to inherit property has been restricted. “Her father protects her in childhood, her husband protects her in youth, and her sons protect her in old age. A woman is never fit for independence,” Manu writes in the ancient text Manusmriti.”. [1]Woman weren’t permanently barred from inheriting movable or immovable property from maternal and paternal families. However, their share of the property was far less than that of their male counterparts. 

In a patriarchal society, laws are based on gender, and women’s property and inheritance laws in India have historically been exploitative. Things began to improve after independence, especially in recent years. Because India lacks a Uniform Civil Code, claims on property and inheritance are based on the claimants’ faith. However, inheritance laws for women, regardless of faith, community, or sect, treat women slightly differently than men. Recent changes to Hindu inheritance laws for women have relieved daughters and wives. The Islamic Laws for Women, on the other hand, are different and more rigid. In recent times there have been some little changes, though not regarding inheritance or property rights.

Hindu women’s property rights have been restricted throughout history, and current laws governing these rights are more liberal than those of ancient Hindu society. Patriarchal Hindu society provided women with stridhan (literally, women’s property or fortune). Primarily from marriage gifts (clothes, jewelry, and in some rare cases, landed properties). On the other hand, women were denied property rights to ancestral or marital landed property, and their right to inherit landed family property was limited. 

STRIDHAN

The concept of stridhan began to expand its literal and legal meaning. The emergence of different schools of Hindu law granted women more rights to certain forms of property. Later, in the nineteenth and twentieth centuries, legislation was passed to remove more barriers to full and equal property rights for Hindu women. The recent Hindu Succession (Amendment) Act effectively ended sexual discrimination in Hindu succession rules (2005).

HISTORY 

Women in different parts of the globe have struggled to have rights over family properties for ages. The philosophy behind this struggle was that once married, women move into their marital families and become a part of them. They do not permanently stay in their birth family. Thus, only the male members of the family have rights over the properties. Women were only offered property when they were married. In the form of Stridhan or on other rosy occasions and this property mainly consisted of movable items.

According to Classic Hindu Laws, in ancient times, Manu talked about three people. A son, a wife, and an enslaved person had no right over the property; their property would belong to the men who controlled them. It shows us that women’s transaction in those times was invalid. Women were only offered property when they were married. In the form of Stridhan or on other particular junctures and this property mainly consisted of movable items.

Scenarios after the introduction of the Hindu Women’s Right to Property Act, 1937: – 

With the introduction of this Act, the widowed wife had a right to the property of her dead husband. However, it did not make her a coparcener on the property. They left the widows with a Right to the limited estate on their deceased husband’s property and gave them the right to ask for a partition. The widow had no right to dispose of the property but only to use it. It was inherited by the rules of inheritance and survivorship in the case of self-acquired and ancestral property, respectively, by the heirs of her deceased husband. Though the Hindu Women’s Right to Property Act’s main aim was to strengthen women’s rights in matters of property. It only helped to bring about a change for the widows.[2]

If we look at Indian history, all property laws have been structured exclusively for the welfare of males, and women have been treated as slavish and dependent on male support. However, with time, women have come to par with men. They have become independent and have started contributing as the household’s breadwinners. Moreover, to keep up with the change in times, the laws in India have also been structured. To promote the plight of women in matters of property. Statutes, such as the Hindu Women’s Right to Property Act, of 1937, the Hindu Succession Act, of 1956, and the Hindu Succession (Amendment) Act, of 2005, are a few.

LEGISLATIONS: SINCE 1937- 2005

When the British Crown established its power over India and made it one of its colonies. The colossal problem was the socio-religious-cultural situation prevailing in India. These include religious practices like stridhan, Sati, Dowry, female infanticide, marrying a young girl with a dying man, and many more. These religious practices are evidence of how women were deprived of their fundamental rights for eternity. Today, some of these practices can be witnessed in different parts of the country. Various legal, as well as social actions, were taken by Mughal emperors, British rulers, freedom fighters including Mahatma Gandhi, and social reformers such as Raja Ram Mohan Roy to stop these barbaric religious practices.

Women’s right over property was also one of the significant issues prevailing at that time, and the British Crown enacted and enforced the “Hindu Women’s Right to Property Act (1937)” to provide women with their essential property right. After independence, various legal developments have taken place regarding the rights of women to property.

1. Colonial Law of Hindu Women’s Right to Property Act (1937)

Hindu traditional norms and rules were still followed even after the series of invasions by the Mughals, the East India Company, and finally, the British Crown. In the eighteenth and nineteenth centuries, British colonial rulers created uniform rules governing other aspects of social life. Such as crime and commerce, but they also acknowledged various Hindu family laws for various religious groups and other cultural groups. Thus, the Mitakhshara and Dayabhaga rules dominated inheritance laws until the start of the twentieth century.

The Hindu Women’s Right to Property Act (1937), which strongly emphasizes women’s estates, was the first attempt to create a unified law of succession by British rule. This Act established Hindu women’s rights to landed estates acquired from male proprietors, particularly from husbands. Even if to a restricted level, was the first of its type to put an end to the contentious discussion over the attributes of stridhan.

The 1937 Act recognized three different widow types:

1. intestate widows,
2. widows of deceased persons, and
3. widows of deceased persons’ grandchildren who are the sons of deceased persons.

The Hindu Women’s Right to Property Act received much attention as a development tool for bettering the status of Hindu women, particularly young widows. European and Indian social reformers, going back to Raja Ram Mohan Roy, fought for this kind of societal transformation. The historic Shastri laws have persisted unaltered, notwithstanding this reformist intent. The major problem with the 1937 Act was that it could never guarantee any rights to women successors when the decedent had divided his property by will. Even though it gave Hindu women limited rights in their intestate husband’s property. The Act said nothing about women’s part in agricultural fields either.

Even after India gained independence, Hindu women had minimal interest in the landed property (1947). Dr. B.R. Ambedkar[3] brought up the shortcomings in the Hindu women’s succession rules during the 1948 discussions. Constitutive Assembly of India’s (legislative) session and proposed modifications to the prevailing legislation in the new Hindu Code Bill. Consequently, the Hindu Code Bill represented the first step toward eliminating the notion of a restricted inheritance of women and replacing it with entire inheritance.

2. Stridhan’s Modernized Concept: The Hindu Succession Act of 1956

The Hindu Succession Act (1956) uniform succession law, based on the Hindu Code Bill, was implemented for Hindus in independent India. Ultimately putting an end to the historical method of barring women from inheriting landed property from male heirs. With the passage of this Act, the idea of women’s estate was utterly abandoned. Also the definition of stridhan was broadened to include landed property and other moveable and immovable assets. Section 14 of the legislation changed women’s estate into stridhan, stating that any property a Hindu woman acquires after June 17, 1956, will be her sole property.

The term “property” as used in the Act refers to movable and immovable property. Whether given to her as a gift, as maintenance, as an inheritance, or by her skill or through purchase, prescription, partition, etc. All of the categories of property that were listed in the ancient text Vijnaneshwar. In which stridhan was demonstrated to be of nine varieties. That are included in the definition of the property stated in Sub-section 1 of Section 14 of the Act. Moreover, even the Hindu Succession Act did not fully vest the women’s right over the property. As Section 14(2) still allows anyone or the Court to distribute a limited estate to a woman in the same way as a limited estate may be distributed to anyone else.

Thus, Section 14 has looked at the past or retrospect. Only when both of the following conditions are met—namely, that she already owned the estate at the time the Act went into effect and that it was not limited ownership. Does it transform an existing women’s estate into stridhan, or the absolute estate. The Act also refrains from mentioning a woman’s late husband’s possessions. The property cannot become her sole possession, except the maintenance right.[4]

Punithavalli Ammal v. Ramalingam and Anr. (1964)

In this dispute, the Supreme Court ruled that Section 14(1) guarantees women an inalienable right that cannot be restricted by assuming anything or using any legal interpretation. It further stated that the date of possession of such property is irrelevant because women who owned the property before the introduction of the clause would now have access to rights that were previously restricted on an absolute basis[5].

In Pratap Singh v. Union of India (1985), Section 14(1) came under heavy fire from Hindu men who claimed it violated their right to equality by Article 14 and was therefore unconstitutional. However, the Supreme Court ruled in Pratap Singh that the provision violated neither Article 14 nor Article 15(1). It was ruled constitutional because it was necessary to strengthen women’s rights.[6]

Modification in four states

With the introduction of the coparcener status for unmarried daughters in 1985, Andhra Pradesh was the first state to change the succession laws significantly. As a result, Andhra Pradesh passed this statute two decades before other states. Other states, such as Tamil Nadu, Maharashtra, and Karnataka, were inspired by this change and gave unmarried daughters the status of a coparcener. These states served as an example, and B.P. Jeevan Reddy later recommended revisions to centrally legislated law in his Law Commission Report[7].

3. The Hindu Succession (Amendment) Act 2005

The Hindu Succession Act (amended) 2005 granted Hindu women the same rights as men to become co-owners of ancestral property. Daughters have equal rights to ancestral properties under Section 6 of the Hindu Succession (Amended) Act (2005). Furthermore, her marital status would be irrelevant in this context. It replaced Section 6 of the 1956 Act and now states:

“On and from the commencement of the Hindu Succession (Amendment) Act, 2005, the daughter of a coparcener in a Joint Hindu family governed by Mitakshara law shall –

1. by birth, become a coparcener in her own right in the same manner as the son;

2. have the same rights in the coparcenary property as she would have had if she had been a son;

3. be subject to the same liabilities in respect of the said coparcenary property as that of a son.”

As a result, daughters are now considered coparceners on par with sons and have an equal right to coparcenary property.

2005 Amendment

As a result of the 2005 Amendment, the following events are now possible:

1. A Hindu woman now has an equal right to become the Karta of the Hindu Undivided family if she is the family’s senior member, which was previously not possible.

2. Second, she can now place her self-acquired property in the family fund, which the Act previously prohibited.

3. In the case of a deceased father, whether married or unmarried, a daughter has equal rights to his property.

4. Daughters now have a claim to the coparcenary property and can even seek partition.

5. Women can now start their coparcenary as well as their own joint family.

As a result, Hindu women have been elevated to the status of men, with all of the rights granted to sons under the coparcenary.[8]

ROLE OF THE JUDICIARY IN DETERMINING ISSUES RELATED TO PROPERTY RIGHTS OF WOMEN: –

1. Controversy on Stridhan

IN THE CASE OF Devi Prasad. Mahadeo,[9]

The concept of Stridhan evolves into two distinct categories of rights over the property: –

1. the full ownership, which includes the right to alienate.
2. the other being limited, which does not include the right to alienate. The two leading schools of Hindu thought regarded stridhan as a women’s “own property.”

Stridhan was divided into two types – the sauadayika and the other one was the non-sauadayika. It stated that the property with limited rights is a women’s estate, whereby the female owner takes it as a limited owner. 

It also differentiated women’s estate from Stridhan and stated that two classifications that differentiate them are 

(i) women could not ordinarily alienate the corpus, and 

(ii) on her death, it goes to the next heir of the last complete owner, which is the male owner from whom the woman had inherited.

2. The definition of property in the Modernized Concept of Stridhan and the Hindu Succession Act (1956): –

CASE – Deenadayal v. Raju Ram, 1970 S.C.R. 1019 (1970) (Hedge, J.).[10]

The Hon’ble Court held that Section 14, which talks about the property, has a retrospective stand. An existing women’s estate is converted into stridhan or absolute estate when the following two conditions are satisfied: 1) ownership of the property must vest in her and which should not be limited ownership, and 2) possession of the estate when the Act came into force must be with her.

3. Cases of a woman’s deceased husband’s property.

CASE- Gurupad Khandappa Magdum v. Hirabai Khandappa Magdum [ AIR [1978] SC 1239.][11]

The Court held that the deceased’s property would devolve by intestate succession under the Hindu Succession Act and not by survivorship. The Hon’ble Court also highlighted that according to classical Hindu law, the wife would get an equivalent share to that of her sons in a partition between a father and his sons.

4. Highlighting the controversy of women’s succession – married, unmarried, and widowed daughters’ ability to claim the right of residence:-

CASE: – Sripatinath v. Ira Ram

The Hon’ble Court states that Section 23 distinguishes between married, unmarried, and widowed daughters’ ability to claim the right of residence. The Act under this section does not give the right to claim partition but gives a right of residence only if the daughter is either unmarried. It has been deserted, or has been separated from her husband, and married daughter does not have either right to claim partition or right to the residence.

A married daughter who has left the husband of her own accord and is not deserted by her husband has no right to reside in the dwelling house. The restriction on the partition is imposed only on the female heirs. In case of a male heir chooses to partition the dwelling house, the female heirs will be entitled to their share but cannot prevent him.

This concept excludes married daughters from the right of residence in the dwelling-house and a share of partition and shows the controversy for women’s succession.[12]

5. Judicial Decisions After Hindu Succession (Amendment) Act, 2005:-

 One of the most revolutionary changes brought in by the 2005 Amendment Act is that now even daughters were eligible to be coparceners in the Joint Hindu Family of his father.

Q- Can daughter be a Karta of a Hindu Undivided Family (H.U.F.):

CASE– Sujata Sharma v. Manu Gupta, 

Issue: The issue before the Delhi High Court was whether the senior-most member of an undivided Hindu family (H.U.F.) is eligible to be a Karta in respect of the amendment in 2005.

Held: The Court, in this case, held that daughters could be Karta because the amendment recognizes them as coparceners. Furthermore, the woman’s marital status could not disqualify her from occupying the position of a Karta.[13]

Q- Clarity on whether these new rights and liabilities would apply to daughters born before 2005?

CASE – Prakash & Ors. v. Phulavati and Ors. (2016)

ISSUE– Would the amended Section 6 of the Hindu Succession Act apply retrospectively?

FACTS-In this case, the daughter acquired the property from her deceased father, who had acquired it from his adoptive mother. The appellant in the present case contended that the respondent had a right over only the father’s self-acquired property. However, the 2005 Amendment was introduced at this time, and the respondent now claimed share as per the amendment.

HELD-The Supreme Court held that “only living daughters of living fathers could become coparceners“. Also no remedy would lie if the father died before the Hindu Succession (Amendment) Act, 2005. Therefore, no retrospective effect could be given to the Act. Also in the case of a pre-deceased father, the property would devolve as per the rules of survivorship. Therefore, such a daughter whose father died before the date of commencement of the Act could only have a right to his self-acquired property and not coparcenary property.

CASE– Danama Suman Surpur & Another v. Amar[14],

Facts: The facts of the case were that a man died in 2001. Leaving behind a wife, two daughters, and two sons, and after the death, the grandson of the deceased grandfather sought partition. However, at the time of partition, they denied any share to the two daughters claiming that they were born before the enactment of the HSA, 1956. This contention was upheld by both the trial court and High Court, though the 2005 Amendment had already come into being by then.

Issue: Would the amendment under section 6 of the Hindu Succession Act (H.S.A.) apply even in cases where the father had passed away before the H.S.A. came into force?

Held: The case came before the Division Bench of the Supreme Court on appeal. Court held that amended S-6 would apply even in cases where father had passed away before the H.S.A. came into force. Due to this, daughters could be treated as coparceners and be given a share in coparcenary property if the case had been pending before the 2005 Amendment Act. It also held that the daughter’s date of birth was irrelevant, the only condition being that she should be alive on the partition date.

6. Resolving conflicting opinions caused by judgments delivered in Prakash & Ors. v. Phulavati (2016) and Panama Suman Surpur & Another v. Amar (2018)

CASE – Vineeta Sharma v. Rakesh Sharma[15],

 A three-Judge Bench was constituted in – Vineeta Sharma v. Rakesh Sharma case to give the correct interpretation of section 6 of the amended 2005 Act, where it was held that

Held: The Hon’ble Supreme Court, overruling Phulavati’s case and partly overruling Danamma’s case. It said that to decide the conflicting question, the origins of coparcenary rights must be examined and concluded that these could not be decided in respect of at a point in time. Such as before or after the enforcement of the H.S.A. Since, by definition, these were rights which were created by birth. It even observed that the question of when the father died was irrelevant in deciding whether coparcenary rights existed or not. 

The Hon’ble Court highlighting the importance of equality and gender justice. Which was not only brought about through the 2005 amendment but also enshrined under Article 14 of our Constitution. It ordered that daughter will be given a share in the coparcenary property even if the father died before 2005. It also pointed to the object of the Act which was to remove gender discrimination regarding rules of the coparcenary and this object could be fulfilled if the Act was applied retroactively. So, from then, a daughter is entitled to will away her share in any joint family property post the 2005 amendment as directed in section 30 of the Act.

7. Dilemma with regards to the daughter’s right to inherit the self-acquired property of a father who died intestate–

The judgment in Vineeta Sharma v. Rakesh Sharma (2018) was limited to coparcenary property and not the self-acquired property of a father who died intestate. So now, in the year 2022, the Supreme Court in

CASE– Arunachala Gounder (Dead) v. Ponuusway[16],

ISSUE -. The issue before Division Bench, was whether sole surviving daughter could inherit her father’s self-acquired property by inheritance. Or whether it would devolve by the concept of survivorship as the father had died intestate before the enactment of the Hindu Succession Act.

HELD-. The Hon’ble Court relied on the customary Hindu law as well as precedents to arrive at its conclusion. It observed that where a deceased individual was part of a coparcenary, their undivided interest in the coparcenary property would devolve on the remaining coparceners by survivorship, and in this case. The deceased had separate or self-acquired property; therefore, it would devolve to their heirs, and not their coparceners by succession. 

Further, the Hon’ble Court relying on the case of Gopal Singh v. Ujagar Singh[17], which ordered that a daughter would receive the self-acquired property of her father upon his death. In preference to collaterals, the Court finally held in the present case, that the self-acquired property would devolve to the daughter by inheritance and not survivorship. Also, it was held in this case that if a female dies intestate. Then the ancestral property was inherited from her father. After her death, having no progeny and intestate, the property will vest towards the father’s heirs. If the property is delegated to her from her husband’s side. She dies without having any child and intestate, the property will devolve upon the husband’s heirs.

COMPARISON IN WOMEN RIGHT OVER PROPERTY IN DIFFERENT RELIGIONS

RELIGION/ PARTIES	HINDU	MUSLIM	CHRISTIAN
DAUGHTERS	Daughters now have the same right to their father’s estate as sons. They are entitled to a share of their mother’s property. The Hindu Succession (Amendment) Act, 2005 repeals the discriminatory gender provisions of the Hindu Succession Act, 1956 and now grants the following rights to daughters:1. In the case of a coparcener,the daughter has the same rights as the son,must bear the same liability in the property as the son,and is allotted the same share as the son;2. The married daughter does not have the right to ask for maintenance or to seek shelter in her parents’ home. However, if a married daughter is abandoned, widowed, or divorced, she has the right to reside.	The daughters are entitled to half the son’s share of their father’s estate.She has completed has control over her share of the property and the legal right to control, manage and dispose of it as she sees fit, both during her lifetime and after her death.The daughter may accept gifts from those she may inherit property, but this does not diminish her claim under inheritance laws.The daughter has the right to live in her parent’s home and to seek support until she marries.If a married daughter divorces, the maintenance charges fall on her parents after the iddat period, which lasts about three months, but if she has children who can support her, it is their responsibility to do so.	The daughters share equally in the estates of their fathers and mothers with any brothers.The daughter has a right to shelter and maintenance from her parents until she marries, but she cannot request it.When she reaches the age of majority, she acquires full ownership of her personal property. Her father is her natural guardian until this happens.
WIVES	A married woman has complete ownership of her property, whether given to her, passed down through generations, or earned by her. She has the authority to give it to anyone, in part or whole. The married woman is entitled to support and livelihood from her husband. If the husband is a member of a joint family, she is entitled to safeguard and support from the family. When it comes to the division of joint family property (between her husband and his sons), the wife has the same right as any other person. When her husband dies, she and her children and his mother are entitled to an equal share of his estate.	The wife has the same right to maintenance as any other wife, and she has the right to sue her husband if he discriminates against her. She is entitled to retain control over her personal property and goods. In divorce, the wife has the right to expect her husband to make fair and reasonable provisions for her future, maintenance. According to the contract terms agreed upon at the time of the wedding, the wife has the right to Mehr. When there are no children, she is entitled to one-fourth of the inheritance; if children are present, she is entitled to one-eighth of the inheritance.	The wife has the right to maintenance from her husband, and if he does not pay it, she has the right to divorce. When her husband dies, the wife is entitled to one-third of his estate, with the remaining portion divided equally among his children.
MOTHERS	The mother is entitled to maintenance from her children, who can support her. She is a Class I heir under Inheritance Law. In the case of a Joint Family, the widowed mother is entitled to a share equal to her son’s share. She can dispose of her property through sale, gift, or will. If the mother dies intestate, her estate will be divided equally among her children, regardless of gender.	If the mother is widowed or divorced, she is entitled to maintenance from her children. She is entitled to inherit one-sixth of her deceased child’s property. The mother’s property will be divided according to Muslim law.	The mother has no legal right to maintenance from her children. She may inherit one-fourth of their property if her children die without a spouse or any living child

FURTHER DEVELOPMENTS: –

1. Inheritance and property rights of live-in couples and their children: –

In India, no religion accepts live-in relationships as legal, but the law provides a little relief.

Hon’ble Supreme court in the year 2015 ruled that couples in a domestic partnership for an extended period will be treated as married; the rules are valid only when the partners must have cohabited for a long time, and “walk-in and walk-out” relationships will not be considered as a live-in relationship.

Section 125 of the Criminal Procedure Code provides that women in live-in relationships are eligible for legal rights and maintenance. Other legislatures under section 16 of the Hindu Marriage Act provide that children born of live-in relationships are entitled to the parents’ self-acquired property and can claim maintenance. In 2008, the Supreme Court 2008 ruled that children born to a live-in couple would have the same right of inheritance as a legal heir. However, if the child is born out of people who have not entered into matrimony are only eligible for the property of their parents and not of any other relation, by the Hindu Marriage Act, 1955[18].

2. Senior citizens and their exclusive right to property and son, and daughter-in-law are licensees: –

On July 23, 2021, The Calcutta High Court, in its Virtual hearing, upheld the senior citizen’s rights to reside in their house. It also stated the rights of their sons and daughter as ‘at best licensees’ living in their property and hence thereby liable to evicted. The Hon’ble High Court also said that such license of children and their spouses living in the senior citizen’s houses. It could be terminated and end if the senior citizens are not well-situated with their children and their families.[19]

 CONCLUSION: –

A three-judge bench headed by Hon’ble Justice Arun Kumar Mishra said, “A daughter always remains a loving daughter. A son is a son until he gets a wife, but a daughter is a daughter throughout her life.“ India has witnessed an era where it was erased from the shared memory of people to realize the importance of women’s property rights in this country. Women’s deprivation of property rights was the root cause of the secondary status of women in India. There were several customs and countless instances of women doing Haq tag for their property. 

However, now that the scenarios have been settled, there has been tremendous development done by the legislative and judiciary. Relating to women’s rights regarding holding and disposing of their property. Making them economically self-sufficient to tackle social barriers that curb women’s property rights. Incessant evaluation of the judicial principles and the interpretation of texts finally made a woman a right holder to stand equal to her male similitude.

Footnotes

1.  G. Buhler trans. 1886), Manu IX.3: Manusmriti: The Laws of Manu, in Sacred Books of the East 56, https://www.hinduwebsite.com/sacredscripts/hinduism/dharma/manusmriti.asp ,2019.
2.  Aarushi, Evolution of Women’s Right To Property In India,  Lawyers Club India, 15 January 2022,
   https://www.lawyersclubindia.com/articles/evolution-of-women-s-right-to-property-in-india-14572.asp
3.  B.R Ambedkar, Law Minister of India, Remarks on the Hindu Code Bill 599 (C.A. (Leg.)D., Vol. IV, 9th April 1948, pp. 3628-3633,  http://wxvw.ambedkar. org/_ambcd/ 
4.  Hindu Succession Act § 14(1) (1956).
5. Punithavalli Ammal v. Ramalingam and Anr, 1970 AIR 1730
6.  Pratap Singh v. Union of India, 1985 AIR 1695
7. Reddy, B., 2000. Property Rights of Women: Proposed Reforms under the Hindu Law. 174TH REPORT, LAW COMMISSION OF INDIA, https://lawcommissionofindia.nic.in/kerala.htm, Accessed 5 May 2000.
8.  The Hindu Succession Act, section 6, 1956
9.  Devi Prasad. Mahadeo, 39 I.A. 121 (1912)
10.  Deenadayal v. Raju Ram, 1970 S.C.R. 1019, 1970,Hedge, J.
11.  Gurupad Khandappa Magdum v. Hirabai Khandappa Magdum, AIR [1978] SC 1239.
12.  Sripatinath v. Ira Ram, 1992 Cal. 60 (1992)
13.  Sujata Sharma v. Manu Gupta [2016] 226 DLT 647
14.  Danama Suman Surpur & Another v. Amar AIR [2018] SC 721.
15.  Vineeta Sharma v. Rakesh Sharma A.I.R. [2020] SC 3717
16.  Arunachala Gounder (Dead) v. Ponuusway MANU/SC/0071/2022
17.  Gopal Singh v. Ujagar Singh A.I.R. [1954] SC 579
18.  Riju Mehta, Money & relationships: What are the inheritance rights of children?, THE ECONOMICS TIMES, Sep 28, 2021, 10:11 AM IST
19.  HINDUSTAN TIMES, ‘Senior citizens have right to property; son, daughter-in-law are licensees’: Calcutta HC | Latest News India – Hindustan Times

For any Query

Mail us at edumoundofficial@gmail.com