CLASSIFICATION OF HEIRS UNDER HINDU

SUCCESSION ACT
LIST OF CASES

Aruna v. Madhava, 2005 Kant. 422.


Aushutosh Chaturvedi v. Prano Devi, 2008 S.C.2171.

Chamanlal v. Mohanlal, 1977 Del. 97.


 Girija Singh v. Gyanwati Devi, 2001 Pat. 20. 


Kamak Goel v. Purshottam Das, 1999 P&H 254. 


Kasturi Devi v. Deputy Div. Commr, 1976 S.C. 2595.

Kenchava v. Girimallappa (1924) 51 IA 368. 


Madambath Rohini v. Devi, AIR 2002 Ker. 192. 


Vidya v Nand Ram 2001 10 SCC 747.

CONTENTS
 Introduction
 General rules of Succession
 General provisions
 Conclusion
 Bibliography
INTRODUCTION
There are specific legal provisions in relation to the succession i.e. section 18 to 28 of
Hindu Succession Act, 1956. These legal provisions apply to all the situations either
property belongs to a Hindu male or female. Following provisions are supplementary to
the section 5 to 17 of the act. Some of the legal provisions also involve the legal
principles.

HISTORY- Before the Hindu Succession Act, Classic Hindu law regulated 1956
Hindus.1 Hindu Succession Act, 1956 is the codification of the Hindu law of intestate
succession and

came into operation on 17 June 1956. It acquainted key changes with great Hindu law of
intestate succession. The act is the codification of the Hindu law of Succession. It rolls
out arrangement for specific improvements to the classic Hindu law of succession, and in
spite of the fact that it is basically a codification of the Mitakshara law of succession, it is
uniformly applicable to every school of Hindu law in India.

In classic Hindu law there are two modes of devolution, one is survivorship of
coparcenary property, and succession of separate property. Males are allowed to have a
share in coparcenary property. If the male coparcener dies, then his share of property
goes back to the remaining coparcenary property. The wife or other female heirs of
deceased coparcener have no right to the property.

Before the 2005 amendment, section 6 of the act bring the revolutionary change to the
Hindu law of succession by allowing the female heir, and the son of a daughter of
deceased Hindu, a share in the coparcenary property. If a coparcener dies leaving with a

1
Mulla’s principles of Hindu law vol I (19ed 2005) 101–363 and C Rautenbach
‘Hindu law of succession’ (2ed 2006) 269–287.
female heir, his share will devolve by mode of succession. The share will be calculated
by taking consideration of deceased share immediately before the time of his death. But
by the amendment the section changes and now section 6 says that a daughter in the
coparcener in a joint Hindu family becomes a coparcener in her own right. Now a female
has equal rights and responsibilities in the property and is allotted the same share as a
son.

The nullification of the constrained woman's estate was the second most vital advance
into the classic Hindu law of succession. In terms of classic Hindu law, if a female
inherited property from a male or stridhana from another female, she received only a
limited woman’s estate which meant that she was the owner of the property for as long as

she lived, but although she had full and exclusive ownership of the property
during that time, her ownership was restricted in all other respects. Section 14(1) of the
Act abolished the limited woman’s estate and converted existing limited woman’s estates
into full estates.2If a female acquires property in any way whatsoever, she becomes the
full owner of such property without any limitations. Furthermore, section 14(1) is
retroactive and applies to limited woman’s estates and property acquired before the
commencement of the Act. Section 15 of the act abolishes the various classifications of
stridhana under the Classic Hindu law.

Section 23 used to constrain the privilege of a female in regards to the residence to one
side of living arrangement as it were. Although female beneficiaries got to be proprietors
of the home house left by the deceased in equivalent shares with the male recipients, they
were not permitted to have the house divided. Such a privilege was just accessible to the
male beneficiaries.3 The reason for section 23 was to ensure the privileges of the son of

2
Vidya v Nand Ram 2001 10 SCC 747.


3
S Yadav ‘Women, Law and Judiciary in India’ in Sharma (ed) Justice and social
order in India (1994) 309.
the perished who act as the suppliers of the joint family, and who depend to their right to
live with their families in the residence house. On the off chance that a female had the
privilege to claim portion of the house, it could be problematic to the families living in it.
Such a contention can similarly be connected to one side of the male beneficiaries of the
perished. They have the privilege to claim partition paying little mind to whether such
segment would be troublesome to the female recipients having a partake in the residence
house. Section 23 was canceled by the Hindu Succession (Amendment) Act of 2005 and
it is these days workable for a female to claim partition of the residence house.

GENERAL RULES OF SUCCESSION

General rules of succession to the property of a Hindu male- Under the classic old Hindu
law the succession of the Hindu male and a female was separately dealt and this
continues with the, The Hindu Succession Act, 1856. There are four types of Hindu heirs-
Class I, Class II, agnates and cognates. The persons included in these categories are
mentioned in the Schedule to the Act.

Section 8 it dealt with the order of priority among classes of heirs by laying down that the
property will first go to the Class I heirs and then to Class II heirs, failing which to
agnates and thereafter to cognates.

Section 9 lays down that Class I heirs are simultaneous heirs, i.e., no one excludes the
other, all take simultaneously in accordance with the rules of distribution of property
among them, while Class II heirs, who are listed in nine categories in the Schedule, the
heirs in the previous category are preferred to later categories.

Section 10 it defines the property distribution among Class I heirs. Section 11 defines
rules of distribution of property between Class II heirs. Section 12 lays down that
agnates, however remote,

will always be preferred over a cognate, however proximate. Section 13 provides the
modes of computation of degrees among the agnates and cognates for the purpose of
determining their order of succession.

This is a divergence from classical Hindu law, where all the coparceners succeeded to the
property of the deceased and all other relations, however proximate and all the legal heirs
of the deceased were excluded.

General Rules of succession in the case of females- Law before the Act, the succession

to a female’s property differed according as the property was her Stridhan technically so
called, or was acquired by her by inheritance or by partition, etc. If it was the former, it
went to her heirs and if it was the later, it went to the heirs of a person from whom she
had inherited it from whose share it was taken out on partition, etc. It also varied
according as she was married or unmarried, and according as she- was married in a valid
or invalid form. The rules of descent again were different in different schools. This Act
ignores all such qualifications for the succession to female’s property and provides a
uniform law for all Hindu females, married or unmarried, belonging to one school or
another.

The act by section 14 confers absolute ownership on all females in respect of all
properties in their possession, whether acquired before or after the commencement of the
Act. And section 15 lays down the rules for the devolution of such property on the death
of the female in the event she has not made a testamentary disposition of the same under
section 30.

Devolution of property:

The property of a female Hindu dying intestate shall devolve according to the rules set
out in Section 16:

(a) Firstly, upon the sons and daughters (including the children of any predeceased son or
daughter) and the husband:
(b) Secondly, upon the heirs of the husband; (c) Thirdly, upon the mother and
father;
(d) Fourthly, upon the heirs of the father; and (e) Lastly, upon the heirs of the
mother.

The property, which belongs to the female Hindu and question, arise what happen to the
property after the death of the female. sub-section (2) makes a very clear and important
exception in respect of such property.

It provides that where a female Hindu had inherited property from her father or mother
and she died leaving behind neither son nor grandchildren, however she may have
deserted her husband the property would not go to her husband but rather return to the
heirs of the father. Similarly, any property inherited by a female Hindu from her husband
or from her father-in-law would decline in the absence of any kids or grandchildren of the
deceased, upon the heirs of the husband. As to will's identity the heirs in such cases, will
be determined in understanding with Rule 3 set down in section 16, which provides that
the property would revert in the same request and according to the same rules as would
have connected if the property had been the father's or the husband's as the case might be,
and such person had passed on intestate in respect thereof immediately after intestate's
death.

In view of the provisions to the definition of “related” in section 3 (j). It shows that the
heirs of a female Hindu will include her illegitimate children born from another husband
also. Thus, it appears that in case a female Hindu, who had inherited property from her
husband, dies intestate and leaves behind children from her previous husband, such
children along with the children of the second husband will succeed equally to her.
Reference may also be made to the general provisions relating to order of succession and
manner of distribution among heirs of a female provided for in section 16. Besides the
above order of devolution,, other rules of succession are that all the heirs of any one of
the above classes will take the property simultaneously4, per stripes and as tenant-in-
common and where an intestate leaves the children from a predeceased son or daughter of

4
Sec. 16, rule 1
her, the children of each predeceased son of a daughter will take between them such share
which they said predeceased son or daughter would have inherited had he or she been
alive at the time of the intestate’s death.5

On account of a property held by the intestate by inheritance it will decline on the heirs of
a person from whom she had inherited that property in such a way as though the
devolution is to occur of the property of that person and that person had died instantly on
the death of the intestate. A similar principle will apply to the cases where property other
than inherited property is to revert and the heirs are of classes (b), (d) and (e) mentioned
above, that is they are the heirs of the husband, the father or the mother. In these cases,
the property will decline upon the heirs of the husband, the father or the mother in a
similar way, as though property lapsing is the property of the said husband, the father or
the mother, all things considered, and the husband, the father or the mother had died
promptly after the death of the intestate. 6

This principle of property inherited by a female lapsing on her death on the heirs of the
person from whom she had inherited is administered by the devolution of inherited
property of a female under the first Hindu Law moreover. Therefore, while the Act tries
to change the law of devolution in regard of all property goes by a female it keeps up that
with respect to property gained by her by legacy. Another essential point important is that
not at all like the textual law without the son or daughters and the husband, the heirs of
the husband have been offered inclination to the mother, the father and their heirs; and
along these lines, the odds of a property controlled by a female, being lost to the family to
which she comes to have a place after her marriage, have been expelled.

5
Sec. 16, rule 2.
6
Sec. 16, rule 3.
GENERAL PROVISIONS IN RELATION TO
SUCCESSION
There are certain general provisions identifying with the succession, as set down from
section 18 to 28 of the Hindu Succession Act, 1956. These provisions apply to every one
of the properties independent of the fact whether a male or a female Hindu dying intestate
leaves it. Section 18 discusses half blood and full blood relations and succession among
them, while section 19 manages per stripes and per capita rules. Section 20 is about
succession with respect to posthumous child. Section 21 and 22, manage assumption in
instances of simultaneous death and preferential right or right of preemption individually.
Concept of Escheat, wherein absence of any legal heirs, property goes to the government
and different rules till section 28 of the demonstration are explicitly managed under the
part of general rules of succession. In addition, the provisions are logical as well as some
of them set down substantive rules including legal principles.

Section 18 sets out a lead of general applicability to male and female heirs alike yet the
applicability is liable to the words, "if the way of the relationship is the same in each
other regard." From the arrangements of the section obviously a full-blood relation is
wanted to half-blood relation. Be that as it may, the run can't be invoked when a specific
beneficiary is wanted to another by operation of any manage influencing the order of
succession.

Full blood preferred to half blood- Section 18 states that, “Heirs related to an intestate
by full- blood shall be preferred to heirs related by half-blood, if the nature of the
relationship is same in every other respect.”

Section 18 sets out a lead of general applicability to male and female heirs alike yet the
applicability is liable to the words, "if the way of the relationship is the same in each
other regard." From the arrangements of the section obviously a full-blood relation is
liked to half-blood relation.
Be that as it may, the lead can't be invoked when a specific beneficiary is wanted to
another by operation of any manage influencing the order of succession.

The words 'full-blood' and 'half-blood' have been explained in section 2 (e) of the Act.
Two people are said to be identified with each other by full blood when they are
plummeted from a common ancestor by a similar wife, and by half-blood when various
wives slide them from a common ancestor yet.

Section 18 makes it clear that the heirs related by full-blood might be wanted to heirs
related by half-blood, gave the way of relationship is same in each other regard. Thus, the
full sister’s daughter shall be preferred to half-brother’s son. Similarly, a full sister
excludes a half-sister.

Mode of succession to two or more heirs- Section 19 of the act provides that, “If two or
more heirs succeed together to the property of an intestate they shall take the property—

(a) Save as otherwise expressly provided in this Act, per capita and not per stripes; and
(b) As tenants-in-common and not as joint tenants.

The section sets out a general rule of distribution of the property. It says that when at
least two heirs succeed to the property of an intestate, they take the property per capita
and as inhabitants in like manner unless there is an express arrangement actually.
Occurrences of special cases to the general rule about distribution per capita are set down
under Rules 1, 3 and 4 of section 10 and Rule 2 of section 16, and so forth.

Joint tenancy and tenancy in common- Joint tenancy is the ownership of property in
common by several persons having a right of survivorship. On the death of one of the
joint tenants, the property vests in the survivor or survivors to the exclusion of the heirs
of the deceased joint tenant. The tenancy in common arises where two or more persons
are entitled to property in such manner that they have an undivided possession but
distinct estate in equal or unequal shares either by the same or different title. No one of
them is entitled to the exclusive possession of any part of the property, each being
entitled to whole in common with the others. On the death of any of them, his heirs
succeed to the property left by the deceased. In short, joint tenancy means joint
ownership with the right of survivorship, and tenancy-in-common means joint possession
with separate ownership without the right of survivorship.

The section lays down a presumption in case of simultaneous deaths that the younger
person survived the older, until the contrary is proved. This operates only in cases where
persons die in circumstances rendering it uncertain as to who died first. 7

Right of child in womb- Section 20 provides that, “a child who was in the womb at the
time of the death of an intestate and who is subsequently born alive shall have the same
right to inherit to the intestate as if he or she had been born before the death of the
intestate, and the inheritance shall be deemed to vest in such a case with effect from the
date of the death of the intestate.”

A child in the mother’s womb is presumed to be born before the death of the intestate,
although subsequently born. To quote Mulla, “It is by fiction or indulgence of the law
that the rights of a child born in justo matrimonio are regarded by reference to the
moment of conception and not of birth and the unborn child in the womb, if born alive is
treated as actually born for the purpose of conferring on him benefits of inheritance. The
child in embryo is treated as in esse for various purposes when it is for his benefit to be
so treated. The view is not peculiar to the ancient Hindu Law but one which as adopted
by all mature systems of jurisprudence. This section recognizes that rule of beneficent
indulgence and the child in utero although subsequently born is to be deemed to be born
before the death of the intestate and inheritance is to be deemed to vest in the child with
effect from the date of the death of the intestate.”8 But for the purposes of the application
of the provisions of section 20, it is essential that child must be in womb at the time of the
death of the propositus and the child must be born alive.

Presumption in cases of simultaneous death- Section 21 provides that, “Where two

persons have died in circumstances rendering it uncertain whether either of them, and if

7
Madambath Rohini v. Devi, AIR 2002 Ker. 192

8
Mulla, D.F., Principles of Hindu Law, Ed. XVI (reprint, 1994) p. 841
so which, survived the other, then, for all purposes affecting succession to property, it
shall be presumed, until the contrary is proved, that the younger survived the elder.”

Sometimes it may happen when two-person die in an accident and then it is impossible to
ascertain which of them died first. In such situations it may be presumed that both died
simultaneously or one died earlier. Controversy regarding inheritance in such a situation
can be arises as who will succeed whose property. Before the enactment of the said
section there was no answer to such situation. The burden of proof falls on the party who
asserted affirmative. 9 If the evidence in the court are proved then the probabilities of
decision is in the favor of the younger.10

In this section the presumption of survivorship applies, by which the younger is presumed
to survive the older. In this Section, ‘younger’ means younger in status not in age and
only when the status is the same, younger in age. Thus if an uncle aged thirty years and a
nephew aged thirty- five years, die in a plane crash or a ship wreck, it will be presumed
that the nephew died later, even though he is older in terms of actual age. On the other
hand, if two brother die simultaneously in any accident or calamity, the brother younger
in age is presumed to have died later.

This is a peculiar feature of this Act, as it was altogether not provided for at all in the
classical law or the previous legislations regarding Hindu succession.

Preferential right to acquire property in certain cases-

Section 22 provides a preferential right to other heir or heirs to acquire property when
one of them desires to transfer his or her interest in the property inherited. Section 22
runs as follows:

(1) Where, after the commencement of this Act, an interest in any immovable property of
an intestate, or in any business carried on by him or her, whether solely or in conjunction

9
Digendra Kumar Roy v. Kuti Mian, AIR 1944 Cal 132.
10
Yeknath v. Lakshmibai, AIR 1922 Bom 347.
with others, devolves upon two or more heirs specified in class I of the Schedule, and any
one of such heirs proposes to transfer his or her interest in the property or business, the
other heirs shall have a preferential right to acquire the interest proposed to be
transferred.

(2) The consideration for which any interest in the property of the deceased may be
transferred under this section shall, in the absence of any agreement between the parties,
be determined by the court on application being made to it in this behalf, and if any
person proposing to acquire the interest is not willing to acquire it for the consideration
so determined, such person shall be liable to pay all costs of or incident to the application.

(3) If there are two or more heirs specified in class I of the Schedule proposing to acquire
any interest under this section, that heir who offers the highest consideration for the
transfer shall be preferred.

In this section," court" means the court within the limits of whose jurisdiction the
immovable property is situate or the business is carried on, and includes any other court
which the State Government may, by notification in the Official Gazette, specify in this
behalf.

Section 22 recognizes the rules of pre-emption, which has the tendency to raise clogs on
the full sale and purchase of property. But the rule of preferential right to acquire
property or business in certain cases is subject to certain rules laid down under this
section. The provisions of the section were necessary in order to safeguard the interests of
the co-heirs, otherwise the very foundations of the Hindu family would have been
shattered. The preferential right to acquire property in certain cases as is provided under
this section is limited only to those cases where the property has devolved upon two or
more heirs specified in class I of the schedule.

The preferential right can be claimed within 1 year of alienation and not after 13 years.11
The right of co-heir to seek transfer of property proposed to be sold is only a personal

11
Aushutosh Chaturvedi v. Prano Devi, 2008 S.C. 2171.

right, which is neither transferable nor heritable.12 By exercising the preferential right to
purchase the share of a co-heir in the business or estate, the strangers can be prevented
from stepping into the joint business or estate.

Section 23 Has Been Deleted from The Act by Virtue of Hindu Succession (Amendment)
Act, 2005.

Section 23 used to limit the right of a female regarding the dwelling house to a right of
residence only. Although female beneficiaries became owners of the dwelling house left
by the deceased in equal shares with the male beneficiaries, they were not allowed to
have the house partitioned. Such a right was only available to the male
beneficiaries. 13 The purpose of section 23 was to protect the rights of the sons of the
deceased who act as the providers of the joint family, and who rely on their right to reside
with their families in the dwelling house. If a female had the right to claim partition of the
dwelling house, it could be disruptive to the families living in it. Such an argument can
equally be applied to the right of the male beneficiaries of the deceased. They have the
right to claim partition regardless of whether such partition would be disruptive to the
female beneficiaries having a share in the dwelling house. Section 23 was repealed by the
Hindu Succession (Amendment) Act of 2005 and it is nowadays possible for a female to
claim partition of the dwelling house.

Section 24 repealed: Certain widows remarrying may

not inherit as a widow –
In classical Hindu law, certain female heirs if they had remarried after the death of their
spouses, before the succession opened were disqualified from inheriting the property of

12
Kamak Goel v. Purshottam Das, 1999 P&H 254.


13
S Yadav ‘Women, Law and Judiciary in India’ in Sharma (ed) Justice and social
order in India (1994) 309.
the deceased intestate, for being unfaithful to their obligations widows. Under the Hindu
Widow Remarriage Act, 1956, if a Hindu widow remarried, she could not inherit the
property of her deceased husband. Under this Section of the Act, only three female heirs
were disqualified on such grounds, namely:

Son’s widow 


Son’s son’s widow 


Brother’s widow 
Now, this Section has been omitted 14 , rendering

such disqualification null and void, which is a great diversion from Hindu
traditional law. 


Murderer disqualified- Section 25 says that, a person who commits murder or abets
the commission of murder shall be disqualified from inheriting the property of the person
murdered, or any other property in furtherance of the succession to which he or she
committed or abetted the commission of the murder. 
It is a general policy of practically
in all the system of law that no one should be allowed to reap benefits of his crime. Such
provisions however, were not specifically provided for traditional Hindu law. In
dayabhaga school it was leads to disqualification, but not same in the Mitakshara school.
However only murderer was disqualified from the Dayabhaga School not the abettor of
murder. But the said section disqualifies both the murderer and the abettor. The Joint
Select Committee on the Hindu Succession Bill observed:


“A murderer even if not disqualified under the traditional Hindu law from succeeding
to the estate of the person whom he has murdered is so disqualified upon the principles of
justice, equity and good conscience.” 


14
Omitted by Section 5, Act 39 of 2005. 

In the case of Kenchava v. Girimallappa,15 the Privy Council held that “the murderer is
not to be regarded as the stock for a fresh line of descent but should be regarded as non-
existent.”

Under section 25 the murderer as well as the abettor of murder is disqualified. But if he is
acquitted on the basis of benefit of doubt, the disqualification does not attach to him.16

Convert’s descendants disqualified- Section 26 says that, Where, before or after the
commencement of this Act, a Hindu has ceased or ceases to be a Hindu by conversion to
another religion, children born to him or her after such conversion and their descendants
shall be disqualified from inheriting the property of any of their Hindu relatives, unless
such children or descendants are Hindus at the time when the succession opens.

Under the old Hindu law, conversion of any Hindu person into another religion was a
disqualification, which was later removed by the Caste Disabilities Removal Act of 1850
and upheld by this Act. However, although conversion does not disqualify a person form
succeeding to the property of an intestate under this Act, his descendants are disqualified
from inheriting such property unless such children or descendants are Hindus at the time
when the succession opens.17

Thus, the children of a convert and their descendants are disqualified. But if at the time of
death of the intestate, any of them are Hindu, they are no longer disqualified.

Effect of Disqualifications—Section 27-If any person is disqualified from inheriting any

property under this Act, it shall devolve as if such person had died before the intestate.

This means that no title or right to succeed can be traced through the disqualified person.
As the disqualified person is deemed to have died before intestate, it follows that no

15
(1924) 51 IA 368.


16
Chamanlal v. Mohanlal, 1977 Del. 97.
17
S.26, Hindu Succession Act, 1956.
person can claim a right of inheritance to such property, through him or her. For, this can
only happen if the property had vested in the disqualified person, and he or she had
thereafter immediately died. The property, in fact, never vests in the disqualified person.
Therefore, a disqualified person cannot be a fresh stock of descent and a person claiming
as an heir of the disqualified person cannot inherit.

Disease, defect, etc. not to disqualify –

Disease, deformity and unchastity are no longer disqualifications.18 Section 28 runs:

“No person shall be disqualified from succeeding to any property on the ground of any
disease, defect or deformity, or save as provided in this Act, on any other ground
whatsoever.”

Under the old Hindu law dome diseases, deformities and unchastity were
disqualifications of heirs, though they were not the same in both Dayabhaga and
Mitakshara law. According to the Mitakshara law, some disqualifications were: congenial
lunacy or idiocy, adoption of a religious order (i.e. taking a sanyas) and unchastity of
widows. According to the Dayabhaga law, the disqualifications were: blindness,
deafness, dumbness, want of any limb or organ since birth, idiocy, lunacy, unchastity of
widows and, any virulent and incurable form of leprosy rendering one unfit for
intercourse.

The widowed mother and widowed stepmother are not disqualified from inheritance even
if they have remarried. 19 If she has remarried during the lifetime of her husband, her
second marriage is void and therefore she would not be considered to have remarried. If
she has remarried after divorcing her husband, and therefore has ceased to be his wife so,
she will not be his widow when propositus dies. But the subsequent marriage of the

18
Girija Singh v. Gyanwati Devi, 2001 Pat. 20. 

19
Kasturi Devi v. Deputy Div. Commr., 1976 S.C. 2595.
widow is no disqualification.20

CONCLUSION

On 17 June 1956, the most important law regarding the Hindu succession came into
operation as ‘The Hindu Succession Act, 1956’. It was clearly different with the many
classic Hindu laws but not free of discrimination. The fact that there are two different
schemes of succession for males and females may be seen as unequal treatment. In terms
of the schedule to the Act, the mother of the deceased is a Class I heir and the father a
Class II heir. The result is that the father of the deceased only inherits if there are no
Class I heirs. This may also be seen as discriminatory.

Before 1956, many disqualifications were recognized which prevented heir from
inheriting property. Not only disqualifying the heir from the property but also
disqualified his/her heirs from the property. Before 1956, the classic Hindu law of
succession is different for Dayabhaga and Mitakshara schools. Some of the rules are
common between them.

The Hindu Succession Act, 1956 has clearly simplified the law in the easy form and
reduces the disqualifications to the minimum.

However, Hindu succession Act focuses on the rights and issues of the female heirs in the
family. Section 23, which stops female heir to claim partition in the house was repealed
by the amendment in 2005. It also simplifies the rules regarding the succession among
the Hindus, but there are many more scope to settle the disqualifies among the heirs. The
women in India not properly known their rights to the succession, there is a urgent need
for proper propagation and popularization of their rights so that they can be used
effectively for the benefits of the females.

20
Aruna v. Madhava, 2005 Kant. 422.
BIBIOGRAPHY

Paras Diwan, Law of Intestate and Testamentary Succession, (3rd ed.,

Universal Law Publishing Co. Pvt. Ltd. New Delhi 2006) 


Dr. Poonam Pradhan Saxena, Family Law Lectures, Family Law II 10

(3rd ed, LexisNexis 2011). 


Flavia Agnes, Family Law and Constitutional Claims (Vol. I Oxford

University Press 2011) 


Brian H. Bix, Family Law, (Oxford university Press, New York, 2013).