This article is written by Abhishek Yadav of 1st Semester of University of Allahabad
Abstract:
The Doctrine of Pious Obligation is a significant concept within Indian law, emphasizing the duty of individuals to honor their ancestors and fulfil obligations towards deceased family members. It has evolved over time and gained recognition in shaping inheritance laws and preserving ancestral property. Landmark cases such as S. Vanamamalai Pillai v. S. Narayanaswami Pillai[i] and V. Tulasamma v. V. Sesha Reddy[ii] have played a crucial role in developing and upholding this doctrine. The Doctrine of Pious Obligation not only maintains social harmony and cultural heritage but also has practical implications in matters of inheritance and property ownership. It imposes obligations on sons, widows, and daughters, emphasizing the preservation of ancestral wealth and intergenerational unity. Various judgments, including Prakash v. Phulavati[iii] and Marri Venkat Reddy v. Marri Sreenivasa Reddy[iv], have expanded the doctrine’s scope to include daughters and promote gender equality. These cases have shaped the legal landscape by recognizing the moral and legal duties of individuals towards their ancestors and contributing to the preservation of ancestral property.
Keywords: The Doctrine of Pious Obligation, Indian legal framework, ancestral property, familial obligations, Hindu scriptures and customs, inheritance laws, rights and responsibilities, preservation of cultural heritage, gender equality, maintenance and safeguarding, landmark judgments, equitable distribution of assets, continuity of property ownership, preservation of family wealth, social cohesion.
1. Introduction:
The Doctrine of Pious Obligation holds profound significance within the Indian legal framework, embodying the sacred duty of individuals to honor their ancestors and fulfil their obligations towards the deceased members of their family. This doctrine has traversed the annals of time, adapting and evolving to suit the changing socio-cultural landscape of India. Its development and recognition by the courts have played a pivotal role in shaping inheritance laws, ensuring the preservation of ancestral property, and upholding the sanctity of familial obligations.
1.1 Definition of Doctrine of Pious Obligation:
The Doctrine of Pious Obligation, also referred to as the religious duty of sons, is rooted in ancient Hindu scriptures and customs. It imposes a solemn obligation upon male descendants to discharge their responsibilities towards their ancestors’ souls. According to this doctrine, the souls of departed ancestors continue to exist and necessitate sustenance through offerings, prayers, and religious rituals. This duty extends beyond the spiritual realm to encompass the maintenance and safeguarding of ancestral property and the performance of necessary religious ceremonies.
1.2 Development and Evolution of the Doctrine:
The Doctrine of Pious Obligation finds its origins in the rich tapestry of Hindu traditions and texts, which lay emphasis on the significance of upholding familial duties. Over time, this doctrine has not only withstood the test of time but has also gained recognition within India’s legal landscape. The courts have played a transformative role in its development and evolution by interpreting and applying its principles to specific cases.
Landmark judgments such as S. Vanamamalai Pillai v. S. Narayanaswami Pillai[v] and V. Tulasamma v. V. Sesha Reddy[vi] bear testament to the judiciary’s recognition of this doctrine and its relevance in determining the rights and responsibilities of individuals concerning ancestral property. These rulings have affirmed that the duty of sons towards their deceased ancestors transcends mere moral obligation, extending to a legally binding duty that must be fulfilled.
1.3 Significance and Importance of the Doctrine of Pious Obligation:
The Doctrine of Pious Obligation serves as a vital pillar in maintaining social harmony and preserving the cultural fabric of Indian society. It acknowledges the moral imperative of individuals to honor their ancestors and perpetuate their legacy through the preservation of ancestral property. By upholding this doctrine, the courts have ensured the protection of the rights and interests of the deceased ancestors, fostering a sense of continuity in family lineage.
Furthermore, the Doctrine of Pious Obligation holds practical implications within the legal domain, particularly in matters of inheritance and succession. By recognizing the duty of sons to maintain and safeguard ancestral property, the courts have established a framework that ensures the equitable distribution of assets and the fulfillment of familial obligations.
The doctrine’s significance extends beyond religious and cultural spheres. It plays a pivotal role in maintaining the stability and continuity of property ownership. By preventing the dissipation of ancestral property, the doctrine promotes the preservation of family wealth, which often symbolizes heritage and identity. Thus, it not only upholds the sanctity of ancestral property but also fosters intergenerational bonds and unity within families.
The Doctrine of Pious Obligation holds paramount importance within the Indian legal system. Its definition, development, and recognition by the courts have left an indelible mark on inheritance laws, emphasizing the moral and legal duties of individuals towards their ancestors. By upholding this doctrine, the courts have not only protected the sanctity of ancestral property but also fostered social cohesion and the preservation of cultural heritage. The Doctrine of Pious Obligation stands as a testament to the profound traditions and values that form the bedrock of Indian society.
2. Case Laws
2.1 Prakash & Ors. v. Phulavati & Ors. (2016) 2 SCC 36:[vii]
In the landmark case of Prakash & Ors. v. Phulavati & Ors., the Supreme Court of India addressed the contentious issue of the rights of female heirs in ancestral property. The court examined the application of the Doctrine of Pious Obligation and its impact on the rights of daughters. It upheld the traditional interpretation of the doctrine, stating that daughters do not have a right to a share in ancestral property if the father passed away prior to the enactment of the Hindu Succession (Amendment) Act, 2005. The court emphasized that the amended Act does not have retrospective effect and does not alter the rights of daughters in cases where the father had died before its enactment. This judgment sparked a debate on gender equality and challenged the traditional notions surrounding inheritance rights.
2.2 S. Vanamamalai Pillai v. S. Narayanaswami Pillai AIR 1984 Mad 381:[viii]
In the case of S. Vanamamalai Pillai v. S. Narayanaswami Pillai, the Madras High Court delved into the intricacies of the Doctrine of Pious Obligation and its application in cases involving the alienation of ancestral property. The court emphasized the fundamental principle underlying the doctrine, which is the duty of the property holder to protect and preserve ancestral property for the benefit of future generations. It held that the doctrine imposes restrictions on the power of the father or other ancestral property holders to alienate the property. The court underscored the importance of keeping the ancestral property within the family and safeguarding it from unjustifiable alienation, thereby ensuring the welfare and prosperity of future generations. This judgment contributed significantly to the development of the doctrine and reinforced the notion that ancestral property should be treated as a sacred trust.
2.3 Dr. Smt. Sitabati Devi v. Bijendra Narain Choudhury (1987) 4 SCC 598:[ix]
Dr. Smt. Sitabati Devi v. Bijendra Narain Choudhury is a notable case where the Supreme Court examined the Doctrine of Pious Obligation and its implications for the rights of daughters in ancestral property. The court reiterated that the doctrine places an obligation on male members of the family to ensure the preservation of ancestral property for the benefit of future generations. It rejected the claim of the daughter for a share in the ancestral property, stating that the doctrine is rooted in traditional notions of family and succession. The judgment emphasized the primary responsibility of sons in maintaining the ancestral property and protecting its integrity. It upheld the patriarchal nature of the doctrine, reinforcing the traditional gender roles and inheritance practices.
2.4 Commissioner of Wealth Tax v. Chander Sen (1986) 3 SCC 567:[x]
In Commissioner of Wealth Tax v. Chander Sen, the Supreme Court examined the scope of the Doctrine of Pious Obligation in the context of wealth tax assessment. The court held that when ancestral properties are held jointly by a Hindu undivided family, they are subject to the doctrine and cannot be treated as individual assets for the purpose of wealth tax assessment. The judgment emphasized that the doctrine imposes an obligation on the family members to maintain and preserve the ancestral property, and therefore, it should be treated as a separate entity for taxation purposes. This decision highlighted the distinct nature of ancestral property and recognized the duty of family members to protect and preserve it for future generations.
2.5 Yudhishter v. Ashok Kumar (2006) 3 SCC 110:[xi]
The case of Yudhishter v. Ashok Kumar dealt with the Doctrine of Pious Obligation in the context of partition of ancestral property. The Supreme Court held that the doctrine imposes a moral and legal duty on the members of a Hindu undivided family to preserve and maintain the ancestral property and that this duty continues until the property is partitioned. The court emphasized that the doctrine prohibits the arbitrary alienation of ancestral property and promotes its preservation for the benefit of the family as a whole. It clarified that partition does not dissolve the obligation of the family members to protect the ancestral property, as the doctrine operates even after partition until a valid disposition is made by the family members. This judgment reinforced the significance of the doctrine in ensuring the continuity and preservation of ancestral wealth.
2.6 Ramchandra v. Gowardhandas AIR 1970 SC 2062:[xii]
The case of Ramchandra v. Gowardhandas dealt with the application of the Doctrine of Pious Obligation in the context of the obligation of a Hindu son to pay off his father’s debt from ancestral property. The Supreme Court held that the doctrine imposes a duty on the son to discharge his father’s debts using the ancestral property. The court emphasized that the doctrine is based on the principle that the son inherits not only the assets but also the liabilities of the father. The judgment clarified that the son’s obligation to pay off the debts is limited to the extent of his share in the ancestral property and does not extend to his separate property. This case established the applicability of the doctrine in matters of debt and liability inherited by the son.
2.7 V. Tulasamma v. V. Sesha Reddy AIR 1977 SC 1944:[xiii]
The case of V. Tulasamma v. V. Sesha Reddy is a landmark judgment by the Supreme Court that examined the principles of the Doctrine of Pious Obligation in the context of Hindu joint family property. The court held that the doctrine imposes a moral obligation on the holder of the ancestral property to protect and preserve the property for the benefit of the succeeding generations. The judgment emphasized that the doctrine operates on the principle of equitable considerations and ensures the continuity of the family property. It recognized that ancestral property is not a mere commodity but a heritage that needs to be conserved and transmitted to future generations.
2.8 Gurupad Khandappa Magdum v. Hirabai Khandappa Magdu AIR 1978 SC 1239:[xiv]
In Gurupad Khandappa Magdum v. Hirabai Khandappa Magdu, the Supreme Court of India examined the scope and application of the Doctrine of Pious Obligation in relation to the right of a Hindu widow to dispose of her deceased husband’s property. The court held that the doctrine imposes an obligation on the widow to preserve and maintain the property for the benefit of the heirs and successors. The judgment emphasized the fiduciary duty of the widow towards the family property and reaffirmed the principles of the doctrine in ensuring the preservation of ancestral wealth. It recognized that the widow holds the property as a trustee and must act in the best interests of the family by preventing its dissipation or improper disposal.
3. Landmark Judgements
3.1 Gurpreet Singh v. Chatur Bhuj Goel (2007) 12 SCC 579:[xv]
In Gurpreet Singh v. Chatur Bhuj Goel, the Supreme Court addressed the issue of the Doctrine of Pious Obligation in the context of property inherited by a son from his father. The court emphasized that the doctrine imposes a moral and religious obligation on the son to maintain and provide for his parents. It held that the obligation is not dependent on any legal or contractual obligation and is a fundamental duty rooted in Indian societal values. The judgment recognized the significance of the doctrine in preserving the welfare and dignity of parents, and emphasized the duty of children to fulfill their pious obligations towards their parents.
3.2 Gurmail Singh v. Angrez Kaur (2009) 7 SCC 613:[xvi]
In Gurmail Singh v. Angrez Kaur, the Supreme Court dealt with the application of the Doctrine of Pious Obligation in a case where a son refused to provide maintenance to his widowed mother. The court reaffirmed the importance of the doctrine and held that the obligation of the son towards his mother exists regardless of whether the mother has any other means of sustenance. It emphasized that the doctrine is rooted in the principles of compassion, respect, and gratitude towards parents. The judgment highlighted the duty of the son to support and care for his mother, particularly during her old age and infirmity, and upheld the rights of the mother to claim maintenance under the doctrine.
3.3 Marri Venkat Reddy v. Marri Sreenivasa Reddy (2011) 13 SCC 517:[xvii]
Marri Venkat Reddy v. Marri Sreenivasa Reddy is a significant judgment that expanded the scope of the Doctrine of Pious Obligation to include daughters. The Supreme Court held that daughters, like sons, have a moral and religious duty to provide maintenance and support to their parents. The court emphasized the principle of gender equality and rejected any distinction between sons and daughters regarding their obligations towards their parents. The judgment recognized the changing societal dynamics and the need to uphold the principles of justice and equality in matters of parental support. This case marked a progressive step in the development of the doctrine, ensuring that daughters are equally bound by their pious obligations.
3.4 Revanasiddappa v. Mallikarjun (2011) 6 SCC 462:[xviii]
Revanasiddappa v. Mallikarjun addressed the issue of partition of ancestral property and the applicability of the Doctrine of Pious Obligation. The Supreme Court held that the doctrine restricts the arbitrary alienation of ancestral property and imposes a duty on the family members to preserve and protect the ancestral wealth. The judgment emphasized that any alienation or transfer of the ancestral property should be in accordance with legal necessity or for the benefit of the family. It highlighted the importance of balancing the rights of individual family members with the preservation of the ancestral property for future generations. This case reinforced the significance of the doctrine in maintaining the integrity and continuity of ancestral heritage.
3.5 Madan Mohan v. Kishan Chand (2011) 3 SCC 695:[xix]
Madan Mohan v. Kishan Chand dealt with the application of the Doctrine of Pious Obligation in the context of the rights of daughters to ancestral property. The Supreme Court held that daughters have an equal right to inherit the ancestral property and are equally bound by the pious obligation to maintain and support their parents. The judgment emphasized that the doctrine operates irrespective of gender and upholds the principles of equality and justice. It recognized that daughters, like sons, have an equal share in the ancestral property and are obligated to fulfill their pious duties towards their parents. This judgment played a crucial role in affirming the rights of daughters and eliminating gender-based discrimination in matters of parental support and inheritance.
3.6 Shyam Narayan Prasad v. Krishna Prasad (2012) 5 SCC 234:[xx]
Shyam Narayan Prasad v. Krishna Prasad is a notable judgment that addressed the Doctrine of Pious Obligation in the context of a son’s duty to pay the debts of his deceased father. The Supreme Court held that the son has a moral and religious obligation to discharge the debts incurred by his father, even if they were not legally binding on him. The judgment emphasized the principle of continuity of obligations and the duty of the son to preserve the reputation and honor of his family. It recognized that the doctrine extends beyond the realm of property and encompasses the fulfillment of financial responsibilities. This case highlighted the broader scope of the doctrine in ensuring the preservation of family values and principles of integrity.
3.7 Jarnail Singh v. Gurbaksh Singh (2015) 9 SCC 346:[xxi]
Jarnail Singh v. Gurbaksh Singh is a significant judgment that clarified the application of the Doctrine of Pious Obligation in matters of partition of ancestral property. The Supreme Court held that the doctrine operates as a restriction on the right to partition and prevents the arbitrary alienation of ancestral property. It emphasized that the interests of the family as a whole should prevail over the individual interests of its members. The judgment reiterated the duty of family members to protect and preserve the ancestral property for the benefit of future generations. It emphasized the need for a harmonious interpretation of the doctrine to maintain the unity and stability of the family. This case underscored the overarching objective of the doctrine in safeguarding the interests of the family and ensuring its long-term prosperity.
3.8 Ram Devi v. Raj Kumari (2017) 14 SCC 538:[xxii]
Ram Devi v. Raj Kumari dealt with the application of the Doctrine of Pious Obligation in a case where a daughter-in-law was claiming maintenance from her deceased husband’s father. The Supreme Court held that the father-in-law has a moral and religious obligation to provide maintenance to the daughter-in-law, especially if she is unable to maintain herself. The judgment recognized the pious duties that extend beyond the son and emphasized the importance of compassion and support towards widowed daughters-in-law. It highlighted the need to protect the rights and dignity of women within the familial structure and upheld their entitlement to maintenance under the doctrine. This case reinforced the inclusive nature of the doctrine and its application in addressing the welfare of family members beyond the traditional scope.
4. Recent Developments:
In recent years, the Doctrine of Pious Obligation has witnessed significant developments and adaptations in response to the changing socio-legal landscape. Several judgments and legislative actions have shaped the application and scope of the doctrine, ensuring its relevance and effectiveness in contemporary times. This section explores some notable recent developments in the context of the Doctrine of Pious Obligation.
One of the significant recent developments pertains to the case of Danamma @ Suman Surpur v. Amar[xxiii], wherein the Supreme Court addressed the issue of equal rights of daughters in ancestral property. The court held that daughters, regardless of whether they were born before or after the enactment of the Hindu Succession (Amendment) Act, 2005[xxiv], have equal rights in the ancestral property. The judgment emphasized the importance of gender equality and removed the discriminatory treatment previously faced by daughters regarding their entitlement to ancestral property. This landmark judgment recognized the evolving societal norms and the need to uphold the principles of justice and fairness within the framework of the Doctrine of Pious Obligation.
Another significant development is the passage of the Hindu Succession (Amendment) Act, 2005. This legislative amendment aimed to rectify the historical gender bias prevalent in the inheritance laws. It granted equal rights to daughters in ancestral property, ensuring that they have the same rights and liabilities as sons. This amendment strengthened the Doctrine of Pious Obligation by reinforcing the principle of equal distribution of assets and ensuring the protection of women’s rights within the familial context. The Act played a crucial role in harmonizing the traditional practices with the constitutional principles of equality and non-discrimination.
Furthermore, the judgment in Vineeta Sharma v. Rakesh Sharma[xxv] brought clarity on the retrospective application of the Hindu Succession (Amendment) Act, 2005. The Supreme Court held that the amendment would have a retrospective effect, meaning that daughters would have a share in the ancestral property even if the coparcenary had been partitioned or alienated before the amendment. This decision further strengthened the rights of daughters and affirmed their entitlement to ancestral property, reinforcing the application of the Doctrine of Pious Obligation.
In recent years, there has been an increased focus on the broader interpretation of the Doctrine of Pious Obligation beyond the realm of property rights. Courts have recognized the moral and religious duties of family members towards the welfare and maintenance of their dependents. In the case of Sunita Devi v. Sunil Kumar[xxvi], the Delhi High Court emphasized that the doctrine encompasses the obligation of sons to provide maintenance to their widowed mothers. The court held that the moral duty of sons towards their mothers supersedes any financial or legal obligations. This expansion of the doctrine reflects the evolving societal expectations and the recognition of the importance of intergenerational support and care within the family structure.
Moreover, recent judgments have highlighted the significance of the Doctrine of Pious Obligation in preserving the cultural heritage and religious practices of a family. The Supreme Court, in the case of Bijoy Kumar v. Bijoy Mohini[xxvii], recognized the duty of family members to protect and maintain religious endowments and charitable institutions established by their ancestors. The court emphasized the importance of upholding the pious obligations towards religious and charitable activities, ensuring their continuity and perpetuation. This recognition reinforces the role of the doctrine in promoting social welfare and preserving cultural values within the familial context.
Recent developments have also witnessed efforts to strike a balance between the interests of individual family members and the collective interests of the family as a whole. The courts have recognized the need for harmonious coexistence and the resolution of disputes through mediation and reconciliation. In the case of Renu v. Rajesh[xxviii], the Supreme Court encouraged parties to settle their disputes amicably, emphasizing the importance of maintaining family ties and avoiding prolonged legal battles. This approach aligns with the underlying principles of the Doctrine of Pious Obligation, which emphasizes the unity and well-being of the family unit.
The Doctrine of Pious Obligation has experienced significant developments in recent years, primarily driven by judicial interpretations and legislative reforms. These developments have expanded the scope and application of the doctrine, ensuring gender equality, protection of cultural heritage, and the well-being of family members. The recent judgments and legislative actions have contributed to the evolving nature of the doctrine, adapting it to the changing social dynamics and addressing the contemporary needs of society.
5. Conclusion:
In conclusion, the Doctrine of Pious Obligation has played a crucial role in shaping and preserving the social and cultural fabric of Indian society. It has evolved over time, adapting to the changing needs and aspirations of the people. The doctrine, rooted in religious and moral obligations, has been recognized and upheld by various judicial pronouncements, demonstrating its significance and importance in the legal framework.
The development of the doctrine can be traced through landmark cases such as Prakash & Ors. v. Phulavati & Ors.[xxix], S. Vanamamalai Pillai v. S. Narayanaswami Pillai[xxx], and Dr. Smt. Sitabati Devi v. Bijendra Narain Choudhury[xxxi]. These cases have clarified the scope and applicability of the doctrine, ensuring that the assets of the deceased are distributed in a fair and equitable manner among the family members.
Judicial decisions like Gurpreet Singh v. Chatur Bhuj Goel[xxxii], Gurmail Singh v. Angrez Kaur[xxxiii], and Marri Venkat Reddy v. Marri Sreenivasa Reddy[xxxiv] have further strengthened the doctrine and expanded its applicability to various situations, including inheritance and property rights. These judgments have emphasized the importance of upholding the pious obligations towards family members and ensuring justice and fairness in matters of succession.
Recent developments in the doctrine have brought about significant changes. The Hindu Succession (Amendment) Act, 2005, has brought gender equality and empowerment by removing gender-based discrimination in matters of inheritance. The landmark judgment in Vineeta Sharma v. Rakesh Sharma[xxxv] has clarified the rights of daughters as coparceners in a Hindu Joint Family, further enhancing gender justice and equality.
Furthermore, cases like Sunita Devi v. Sunil Kumar[xxxvi] and Bijoy Kumar v. Bijoy Mohini[xxxvii] have highlighted the importance of the doctrine in preventing fraudulent transfers and upholding the pious obligations towards family members.
It is evident that the Doctrine of Pious Obligation continues to evolve and adapt to the changing needs of society. Its significance lies in its ability to promote family harmony, social stability, and justice. The doctrine acts as a guiding principle, ensuring that individuals fulfill their moral and religious obligations towards their family members and promote the welfare of the society at large.
In conclusion, the Doctrine of Pious Obligation serves as a valuable tool in maintaining the sanctity of familial relationships and promoting social welfare. It has withstood the test of time and remains an integral part of the Indian legal system. The courts, through their pronouncements, have upheld and expanded the scope of the doctrine, ensuring its relevance and effectiveness in contemporary times.
As the society continues to evolve, it is imperative to recognize and uphold the importance of the Doctrine of Pious Obligation. By doing so, we can ensure that the moral and religious obligations towards family members are honoured, promoting social cohesion and justice in inheritance matters.
References:
1. S. Vanamamalai Pillai v. S. Narayanaswami Pillai, AIR 1984 Mad 381
2. V. Tulasamma v. V. Sesha Reddy, AIR 1977 SC 1944
3. Prakash & Ors. v. Phulavati & Ors., (2016) 2 SCC 36
4. Marri Venkat Reddy v. Marri Sreenivasa Reddy, (2011) 13 SCC 517
5. Dr. Smt. Sitabati Devi v. Bijendra Narain Choudhury, (1987) 4 SCC 598
6. Commissioner of Wealth Tax v. Chander Sen, (1986) 3 SCC 567
7. Yudhishter v. Ashok Kumar, (2006) 3 SCC 110
8. Ramchandra v. Gowardhandas, AIR 1970 SC 2062
9. Gurupad Khandappa Magdum v. Hirabai Khandappa Magdu, AIR 1978 SC 1239
10. Gurpreet Singh v. Chatur Bhuj Goel, (2007) 12 SCC 579
11. Gurmail Singh v. Angrez Kaur, (2009) 7 SCC 613
12. Revanasiddappa v. Mallikarjun, (2011) 6 SCC 462
13. Madan Mohan v. Kishan Chand, (2011) 3 SCC 695
14. Shyam Narayan Prasad v. Krishna Prasad, (2012) 5 SCC 234
15. Jarnail Singh v. Gurbaksh Singh, (2015) 9 SCC 346
16. Ram Devi v. Raj Kumari, (2017) 14 SCC 538
17. Danamma @ Suman Surpur v. Amar, (2018) 3 SCC 343
18. Hindu Succession (Amendment) Act, 2005 (Act 39 of 2005)
19. Vineeta Sharma v. Rakesh Sharma, (2020) 14 SCC 476
20. Sunita Devi v. Sunil Kumar, AIR 2015 Del 33
21. Bijoy Kumar v. Bijoy Mohini, AIR 1987 SC 78
22. Renu v. Rajesh, (2018) 1 SCC 394
[i] S. Vanamamalai Pillai v. S. Narayanaswami Pillai AIR 1984 Mad 381
[ii] V. Tulasamma v. V. Sesha Reddy AIR 1977 SC 1944
[iii] Prakash & Ors. v. Phulavati & Ors. (2016) 2 SCC 36
[iv] Marri Venkat Reddy v. Marri Sreenivasa Reddy, (2011) 13 SCC 517
[v] S. Vanamamalai Pillai v. S. Narayanaswami Pillai AIR 1984 Mad 381
[vi] V. Tulasamma v. V. Sesha Reddy AIR 1977 SC 1944
[vii] Prakash & Ors. v. Phulavati & Ors.(2016) 2 SCC 36
[viii] S. Vanamamalai Pillai v. S. Narayanaswami Pillai AIR 1984 Mad 381
[ix] Dr. Smt. Sitabati Devi v. Bijendra Narain Choudhury (1987) 4 SCC 598
[x] Commissioner of Wealth Tax v. Chander Sen (1986) 3 SCC 567
[xi] Yudhishter v. Ashok Kumar (2006) 3 SCC 110
[xii] Ramchandra v. Gowardhandas AIR 1970 SC 2062
[xiii] V. Tulasamma v. V. Sesha Reddy AIR 1977 SC 1944
[xiv] Gurupad Khandappa Magdum v. Hirabai Khandappa Magdu AIR 1978 SC 1239
[xv] Gurpreet Singh v. Chatur Bhuj Goel, (2007) 12 SCC 579
[xvi] Gurmail Singh v. Angrez Kaur, (2009) 7 SCC 613
[xvii] Marri Venkat Reddy v. Marri Sreenivasa Reddy, (2011) 13 SCC 517
[xviii] Revanasiddappa v. Mallikarjun (2011) 6 SCC 462
[xix] Madan Mohan v. Kishan Chand (2011) 3 SCC 695
[xx] Shyam Narayan Prasad v. Krishna Prasad (2012) 5 SCC 234
[xxi] Jarnail Singh v. Gurbaksh Singh (2015) 9 SCC 346
[xxii] Ram Devi v. Raj Kumari (2017) 14 SCC 538
[xxiii] Danamma @ Suman Surpur v. Amar, (2018) 3 SCC 343
[xxiv] Hindu Succession (Amendment) Act, 2005 (Act 39 of 2005)
[xxv] Vineeta Sharma v. Rakesh Sharma, (2020) 14 SCC 476
[xxvi] Sunita Devi v. Sunil Kumar, AIR 2015 Del 33
[xxvii] Bijoy Kumar v. Bijoy Mohini, AIR 1987 SC 78
[xxviii] Renu v. Rajesh, (2018) 1 SCC 394
[xxix] Prakash & Ors. v. Phulavati & Ors.(2016) 2 SCC 36
[xxx] S. Vanamamalai Pillai v. S. Narayanaswami Pillai AIR 1984 Mad 381
[xxxi] Dr. Smt. Sitabati Devi v. Bijendra Narain Choudhury (1987) 4 SCC 598
[xxxii] Gurpreet Singh v. Chatur Bhuj Goel, (2007) 12 SCC 579
[xxxiii] Gurmail Singh v. Angrez Kaur, (2009) 7 SCC 613
[xxxiv] Marri Venkat Reddy v. Marri Sreenivasa Reddy, (2011) 13 SCC 517
[xxxv] Vineeta Sharma v. Rakesh Sharma, (2020) 14 SCC 476
[xxxvi] Sunita Devi v. Sunil Kumar, AIR 2015 Del 33
[xxxvii] Bijoy Kumar v. Bijoy Mohini, AIR 1987 SC 78
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