THE HINDU SUCCESSION ACT, 1956

ABSTRACT

It was the Hindu Succession Act, 1956, that revolutionized the laws of inheritance in India to a great extent, by changing principles of inheritance and succession among Hindus, Buddhists, Jains, and Sikhs. The traditional practices were mainly patriarchal in nature and had governed the succession of properties before this enactment. However, the enactment has been an important milestone since it has brought a complete revolution at the front lines of the Act with its aim on equality between genders. The Act abolished the long-standing rights which prohibited the accesses of women to property by giving inheritance to daughters on lines similar to that of sons. It empowered the feminine masses while precipitating a more equal or balanced wealth distribution within the Hindu families and reflecting changing social attitudes toward gender and property rights. Besides, the Act established classes of heirs. Class I heirs, that is, sons, daughters, widow, and mother, are always privileged in matters concerning inheritance. This means if there were no living Class I heirs, then the property would go to Class II heirs, which covered a far larger circle of relatives. Such a system was meant to ensure clarity and fairness in the whole process of distribution, thus there would be minimal disputes arising from the heirs. The Hindu Succession Act, 1956, helped establish a just and fair system of property succession through equality of sexes, clear hierarchy of heirs, and abolition of old doctrines. Evidently, this landmark legislation still signifies the delicate balance between tradition and the present-day principles of fairness and justice that provides for an equitable inheritance framework in Hindu families.

Keywords

Hindu Succession Act, 1956, 2005 Amendment, inheritance laws, gender equality, coparceners, ancestral property, daughters’ rights, legal reforms, testamentary succession, Mitakshara system and societal attitudes.

INTRODUCTION

The Hindu Succession Act, 1956, is a landmark development in the legal scenario of India and has significantly impacted the rights of Hindus in relation to inheritance. Enacted to amend and codify the law relating to intestate succession among Hindus, this Act brought uniformity and fairness in the distribution of property, avoiding patriarchal norms. The old inheritance laws were very biased in favor of the male lineage, thus leaving women to live under the mercy of male relatives for their sustenance. The Act was revolutionary in so far as it tried to give women legal rights in an ancestral property although with some limitations. But despite these enlightened intentions, the provisions proposed initially were a reflection of the prejudices of the times and placed women on a worse footing than men. The inequality at the heart of the original Act went straight to reveal deep-seated gender prejudices within Hindu society, and therefore further change was in order. The legislation got mixed reception because of the tug of war between tradition and modernity that defined Indian legal and social setups. It has become a land mark law which changed legal scenario fully. Daughters are accorded equal right like that of sons’ over the coparcenary properties. Ensured rights along with liabilities of daughters also are equated with their counterparts. In the case it does not matter whether it is ever married or otherwise. This was crucial for the cause of ensuring gender parity in inheritance legislation, as constitutional mandates such as equality and non-discrimination were followed. Though these have been seen, the effective implementation of such laws met resistance in society and were also due to a general lack of awareness. The courts interpreted and upheld such provisions through landmark judgments that reinstated the intent of the legislations. However, the road to total equality is not smooth and depends on continuous education and women’s empowerment towards their rights. In this regard, the journey of the Hindu Succession Act, from its initiation to this day, represents the general journey of India toward gender equity and justice.

This article begins with a detailed critique of the Hindu Succession Act, 1956. First, we shall explore the historical context that necessitated such legislation and then delve into a thorough examination of its prime provisions. Every chapter of this act will be discussed to clearly understand its scope and application. Significant amendments made to the Act over the years shall also be discussed, so that one can manifestly see the impact of the changes these have made upon the law of succession in India. The piece then goes into landmark judicial interpretation that greatly influenced the practice of the Act. It not only clarifies a number of provisions but sets important precedents for subsequent cases as well. This paper presents the judicial decisions concerning offering a holistic perspective of how the Act has developed, and in the modern day, how the Act remained relevant. This article tries to present an in-depth analysis of the Hindu Succession Act, 1956, its importance, and influence in Indian society. Whether you are a lawyer or a student or even the one interested in knowing in detail about inheritance law and its complexities, this paper will be helpful, trying to explain the act in quite simple and direct terms.[1]

MEANING OF HINDU SUCCESSION ACT, 1956

The Hindu Succession Act, 1956, is Indian law that determines the succession of the movable and immovable properties of Hindus, Buddhists, Jains, and Sikhs by reason of death without a will. Under this Act, the laws concerning the inheritance previous to its enactment were much based on informal, varied norms and traditions that may differ according to the region or community. The act simplified and codified these laws such that the system of succession was both fair as well as uniform. The greatest innovation amongst the major changes the Act has made is in making equal inheritance rights for women. Prior to this law, the rights of daughters to inherit the property of their parents were mostly limited. The Act modified this by giving daughters equal rights as sons to inherit the property of their fathers, ensuring equal gender representations and giving women power within the family unit. The Act also eradicated the earlier practice of only a male member of a family who would get the joint family property automatically. In such property, the Act provided that daughters and sons have an equal right.

The Hindu Succession Act, 1956, divides the class of heirs into different classes for inheritance. Class I heirs are widows, sons, daughters, and mothers, and they are preferred the most. When no Class I heir is present, the property is given to Class II heirs, which are more distant relatives or cousins and siblings and grandsons. This classification helps in giving clear focus and minimizing disputes among family members about who gets what. Another important aspect of the Act is that it is testamentary succession which allows people to make a will. This means people have some freedom to decide how they want their property distributed after death. The essence behind this is that if a person dies without making a will, then it is distributed according to the rules provided in the Act; thereby justice is meted out. Hindu Succession Act 1956 has been a crucial tool in modernizing and standardizing principles regarding inheritance among Indians, balancing traditional customs with the living ideas of balance and equality between genders.

BEFORE THE ACT: A LEGACY OF PATRIARCHY AND CUSTOM

In the pre-hindu Succession Act, 1956, the rules of inheritance among Hindus were, for the most part, grounded in customs and ancient texts that are themselves patriarchal. The traditional Hindu law of succession is derived from the two main schools of thought: the Mitakshara and the Dayabhaga. There have been contradictory interpretations and applications in India and in many regions. The Mitakshara system adhered to the doctrine of survivorship more widely. This doctrine concluded that any family property, being joint, would automatically go to the surviving male members upon the death of a male member, usually leaving no or little for females. The system further disadvantaged women, most of whom were excluded from inheritance of family property, while their rights were limited to maintenance and residence in the family home.

The Mitakshara coparcenary made it obvious that men within a joint family alone had rights to ancestral property birthright, thus further deepening gender inequality. It looked at women rather as a temporary phase in their natal families and not as permanent members of it; however on marriage, they would more likely alter their allegiance to their marital family. This perception was also reflected in the Dayabhaga system, mainly observed in Bengal, where property rights of women were as restricted, though a little more lenient than under the Mitakshara system. For instance, a widow generally had very limited rights to the property of her husband and only possessed life interest with no absolute right. This, therefore made the laws patrilineal, as they ensured that the properties remained within the man’s lineage and continued to uphold male supremacy and ownership of family assets.

In a nutshell, before the Hindu Succession Act, 1956, the laws of inheritance were a patchwork of customary practices and ancient legal doctrines characterized by patriarchal norms. Women were systematically marginalized in matters of property rights which were reflections of broader societal attitudes favoring male heirs. In the absence of a standardized legal framework, the system of property succession created significant disparity and injustice in property inheritance, leaving women with minimal economic security and independence. The Hindu Succession Act of 1956 was, by extension, a significant intervention to redress these deep-seated inequalities and create a more just and equitable system of inheritance.

Then, of course, there are the vague and inconsistent pre-hindu Succession Act inheritance laws, which often involved heavy litigation. The rights were different in different regions and communities within the country. This was really a very fragmented legal landscape, and the lack of codification also contributed to arbitrary application of inheritance rules under the influence of local customs and the discretion of male heads of families. This inconsistency not only created ambiguity but also fostered gender biases and discrimination. Women had to depend on the good will of their male relatives to get an appropriate share in the family property, many a times resulting in injustice and exploitation. Pre-Act social mores and practices were highly embedded in the patriarchal approach which considered women as dependents rather than equal partners in the family.

THE 1956 ACT: PIONEERING LEGAL CHANGE IN SUCCESSION

This was a landmark Act in the field of inheritance or succession laws, as it changed the landscape forever of how property was distributed upon the death of one of its owners, with Hindus, Buddhists, Jains, and Sikhs being involved in the prescribed way. While the earlier system had been patriarchal and largely governed by customs and, more often than not, excluded women from becoming owners of property at death, a drastic break from these age-old practices was made with the intent of serving both equity among the sexes and simplification of the laws of succession.

Problems solved by this act

Hindu Succession Act, 1956, solved many problems that had been embedded in conventional laws of inheritance that were largely patriarchal and discriminatory. It was a lacuna in the traditional laws of inheritance that tied most property rights during one’s lifetime to survivorship and coparcenary systems, giving weightage to the male lines of heirs, and women had no property or minimal property rights. This led to severe gender-based inequality where daughters and widows had hardly any claim on family properties, leading them economically dependent on male relatives. This act took away the patriarchal norms from the society as it accorded equal inheritance rights to daughters and enabled them to inherit the same rights as men. This also led to gender equality and ensured that the woman remained financially sound and independent so that she would be empowered not only in the family but also in society.

Secondly, the Act solved the various and sometimes unclear legacy laws that had been in use in different regions and communities, leading to more pronounced disagreements and litigations within the family. The codification of the “laws of inheritance” provided for a clear uniform legal framework regarding succession, hence the avoidance of more probable conflicts and confusion. The process was further streamlined by introducing a structured classification of heirs into Class I and Class II categories. This ensured fairness and transparency in the distribution of property. The Act further allowed testamentary succession, meaning an individual could will their property according to his wishes, thus granting greater autonomy and flexibility in asset distribution. These provisions ensured that inheritance practices became much more fair and balanced and closer to the ideals of fairness prevalent at that time, thus making the approach to property succession in Hindu families more inclusive and balanced.

Key Provisions of the Act:

Doctrine of Survivorship was abolished by the Act: The Act nullified the doctrine of survivorship in joint family property. It eradicated the principle where male members used to inherit properties automatically on the death of another male member. Under the system, females were completely eliminated from such properties. The Act replaced it with a system where daughters and sons have equal status in joint family property, an arrangement much more just for succession properties.
Classification of Hiers- The Act provided a structured categorization of heirs into classes. All sons, daughters, widows, and mothers would come under Class I heirs. Therefore, class I heirs are entitled to preference over others in the matter of inheritance. Should class I heirs cease to exist, the property would go to the class II heirs. Class II heirs, therefore, are the brother and sister and their descendants. This would provide transparency and avoid disputes.
Testamentary Succession: The Act conferred the right on individuals to bequeath the property through a will whereby the individuals are entitled to more rights in deciding how the assets should be distributed upon their death. In case there is no will, the same is shared pursuant to the intestate succession that was made under the Act. This way, the will of individuals to decide as far as the distribution of the assets is concerned is upheld while it gives an understandable order concerning that scenario in case there is no will.[2]

Main Problems Solved by this Act;

The Hindu Succession Act, 1956, addressed many issues that traditional inheritance laws had encapsulated in them, which were essentially patriarchal and discriminating. Inheritance patterns were primarily governed by the law of survivorship and the coparcenary systems, the results of which typically favoured male inheritors, granting women very limited or no rights over property. This led to profound gender inequality, since daughters and widows had little claim to any family property and therefore were totally economically dependent on male relatives. Therefore, by awarding equal inheritance rights to daughters, the Act tore down these patriarchal norms to ensure that women could inherit property on an equal footing with men. This helped increase gender equality and economic security as well as independence, whereby women empowered both within the family and in society.

The Act dealt with irregularities and obscurity relating to and governing the laws of inheritance as administered differently from one region to another or across communities, which usually instigated litigations and wars among some family members. Codifying these laws in an orderly succession, the Act reduced future probable conflicts and confusion. The process was finally rationalized with the introduction of a formal classification of heirs into two distinct classes, known as Class I and Class II, which would further promote the cause of fairness and transparency in the distribution of property. Testamentary succession was also allowed by the Act: this would mean an individual could bequeath their property in whatever way they wished to do so, providing even greater freedom and option in asset distribution. Altogether, these provisions ensured that inheritance was practiced more justly and fairly and in accordance with modern standards of fairness, which made the conception of a more inclusive and balanced approach towards succession to property in families who were usually Hindu more feasible.

WOMEN’S RIGHTS REVOLUTION: THE IMPACT OF THE 2005 AMENDMENT

This 2005 Amendment to the Hindu Succession Act, 1956 was a major step forward in the context of women’s property rights in India and attempts to wipe out long-standing gender imbalances enshrined in the country’s inheritance laws. Until the 2005 amendment, daughters were not considered co-heirs under the Mitakshara system, which essentially means they did not have any birth right to an equal share in joint family property. Through this very doctrine of survivorship, the benefit of birth rights to ancestral property was only extended to the male members of the HUF and thereby excluded daughters from such benefits. Thus, it became a form of gender inequality: daughters and widows seldom held much claim on family property and, therefore, remained economically dependent on their male kin. The 2005 amendment brought a sea change by the recognition of daughters as co-heirs by birth. In a nutshell, daughters were on an equal footing with sons. However, it would imply the daughters could now claim partition and a share in the ancestral property, including their birth date as long as the partition was not settled through some legal procedure before the amendment. Equitable property rights under the amendment mainly ensured that women enjoyed better economic security, autonomy, and stronger family and societal powers.

Asides from altering women’s property rights, the 2005 Amendment reflected a broader attempt to clarify and ensure the fair operations of inheritance laws in the country. Before the amendment, because inheritance laws were interpreted and applied differently in different places, their implementation led to much litigations and confusion. The amendment was therefore aimed at reducing these kinds of inconsistencies and possible conflicts by explicitly granting daughters equal rights. Through the introduction of a structured classification of heirs which included daughters as co-heirs, property distribution became much streamlined as well as ensured by having a more transparent system. In addition, the amendment strengthened testamentary succession rights so that it will allow the distribution of one’s wealth as one would want through a will where the rights of daughters do not fade away in relation to their share in ancestral property. This gave a family much more leeway and liberty in the disposal of assets, typically aligned with a more contemporary approach toward inheritance. The legal certainty and uniformity that the 2005 Amendment induced also contributed to the settlement of the line of succession on a fair and equal basis, supporting evolving societal attitudes in gender equality. It represented an important step in dissolving patriarchal structures and in reinforcing gender justice to advance the cause whereby women become recognized as equal participants in familial wealth and inheritance. The 2005 Amendment remains the basis of ongoing efforts towards increasing gender justice and women’s economic empowerment in India.

CHALLENGES IN THIS FIELD

The area of inheritance law, in relation to gender equality, has also faced significant challenges despite progressive amendments such as the Hindu Succession Act, 1956, and its amendment in 2005. Among the major challenges here is the survival of social norms and culture in society. Though the law provides rights to daughters equal to that of sons, practically people consider sons as heirs. Such societal pressures and expectations force women into situations where they give their brothers or male relatives their share of the inheritance. The limitations and societal expectations make it difficult for them to exercise rights under law. This creates a huge gap between the law as put on paper and its practice. The resistance in the society to fully embrace the gender-equal inheritance rights is a reflection of more pervasive patriarchy, whose hold is seen in many aspects of Indian society.

Another crucial point relates to some problems connected with the legal-administrative hurdles in the entitlement of inheritance by women. Many women from rural or lower socio-economic strata lack both awareness and resources to go through the system legally. They may not know or do not have the access to legal help or information regarding their rights under the Hindu Succession Act. Furthermore, the law is often long-drawn, protracted, and costly: factors which might deter women from further claims. Corruption and bureaucratic inefficiencies in the system also intensify these problems, and women cannot be sure of their inheritance. These barriers call for greater legal literacy, accessible legal services that are inexpensive, and an overhaul of the legal process to make it quicker and accessible to everyone, not to say, predominantly women.[3]

Another barrier that hinders enforcement is the informal conveyancing of property and the lack of proper documentation in the forms of wills, deeds, and titles. The transactions involving property matters and inheritance aspects are often not finalized in the formal structures of law, but informal assents or a kind of family consensus is most often considered as the method of doing it. Thus, such informal documentation and a lack of proper legal recognition of women’s rights over particular properties often lead to conflicts and issues of inconvenience for women regarding their rights over these properties. This also continues to prevent women from possessing crucial documents in formulating their rights over property since patriarchal influence often lies over family property. Input of efforts in regularizing transactions over the property, documentation, as well as knowledge of the significance of legal recognition of rights over the property are also important for these to resolve challenges. This also calls for a cultural shift to recognize and respect equal property rights among women, plus appropriate legal and administrative power to enforce them in that direction.

THE COURTS SPEAKS: LANDMARK CASES SHAPING SUCCESSION LAW

Vineeta Sharma v. Rakesh Sharma (2020): The Supreme Court of India in a landmark judgement held daughters equal to sons in rights to ancestral property whether father was alive or not when the 2005 Amendment took effect. The court ruled that the amendment was retrospective and applied to daughters born before the amendment as well. This case reinforced the principle of gender equality in rights in the matter of inheritance and ensured that daughters could claim their share of property that belongs to them by birth as coparceners.[4]
Prakash v. Phulavati (2016): In this case, the Supreme Court held that the amendment of 2005 to the Hindu Succession Act granting coparcenary rights to daughters was prospective and not retrospective. Therefore, if the daughters were born before this amendment, then they cannot claim any coparcenary rights unless their father was alive at the time of amendment. It is better understood that clear rules prevent the above kinds of problems and that inheritance rights would be equitably distributed.[5]
Danamma @ Suman Surpur v. Amar (2018): Held by the Supreme Court that daughters, whether born before or after the amendment of 2005, are also coparceners and share the ancestral property equally. The Supreme Court emphasized the prospective and retrospective application of the amendment but held that in no manner could the daughters claim any better right than their brothers. This would take a great place while enforcing gender equality concerning inheritance. It would further strengthen the implication regarding the amendment, as well.[6]
Shamim Ara v. State of U.P. (2002): In this case, the Supreme Court dealt with the issue of bigamy under Muslim personal law and its impact upon rights to inheritance. Even though it does not deal directly with the Hindu Succession Act, the case discourses a more general context about gender equality and rights in inheritance within India. The court laid down that the second marriage by a Muslim man when the first marriage was still in existence was void and without legal effect. The judgment required clarity in the provisions of law as well as the aspect of gender equality in matters of inheritance and personal law.[7]

LOOKING AHEAD: REFORMING SUCCESSION FOR A MODERN INDIA

The very area that holds crucial importance for reformation is the fact that laws relating to succession in India are so designed as to be modern and just. Even though marked with enormous progress with the help of the Hindu Succession Act, 1956, and the amending acts thereafter, still there is a long way to go before inheritance laws reflect the values of egalitarianism and justice contemporary to the present day. There is an urgent need to implement existing laws and see to their proper enforcement all over the country without any exception. The social attitude and patriarchal traditions do not permit women to assert their rights in property and inheritance; although the laws on the subject grant them equal status with daughters. Therefore, there is a need to take efforts to educate and sensitize the people at the grass root level about gender equal inheritance rights, as well as about respect and enforcement of legal provisions uniformly all over the country. For the purpose, grassroots awareness campaigns and legal literacy programs are badly needed, along with robust enforcement mechanisms that can safeguard the rights of women.

Another area of reform would be in the legal procedures for inheritance claims. Inheritance laws are highly overcomplicated, and they take much time and money. For this reason, a lot of women cannot seek their inheritance rights. Legal procedure reforms should make the procedures even more accessible and friendly to women in rural or economically disadvantaged settings. Providing free legal advice and aid can do much to embolden the women in asserting their rights without intimidation and an adverse cost burden. There is further justification in the institution of separate family courts to expedite inheritance disputes to clear off the accumulated backlog and delay in judgment.

The current practice of dealing with informal transfers of property, which involve incomplete documentation, only complicates matters in cases of inheritance. Thus, now many transactions of properties are involving the informal legal set-up of India, which creates a brawl and hassle to prove the ownership rights of the concerned women. Now, therefore, there should be efforts taken so that the transfer of property takes place through proper documentation and legal recognition so that the inheritance rights of the women will not be affected. This process can easily be simplified if the registration process of property takes lesser time and provides incentives to families so that they go through a formal property transfer. In addition, there is a need to place policies which will allow women to access and control all the critical documents required to stake their claims. It is possible for India to construct a balanced succession framework aligned with modern values and jointly pursued for gender equality by addressing these challenges and implementing comprehensive reforms.[8]

CONCLUSION

In a nutshell, the Hindu Succession Act of 1956 and statutory amendments specifically the landmark amendment that was introduced in the year 2005 have significantly enhanced the new dimension of gender equality in the inheritance laws of India. Such legal reforms not only lowered patriarchal norms but enabled women to seek inheritance rights equally so, which effectively empowered them economically and socially. This has been done fairly illustratively by the laws to exhibit a major change in towards gender justice and equity in the family distribution of wealth through recognizing daughters as co-heirs. Equitable rights were granted by giving the same rights to daughters as were being enjoyed by sons regarding ancestral property. This step has however, not been free of challenges. Deeply ingrained attitudes of social outlooks in resisting the changes continue to raise major hurdles for the rights of women while claiming the rightful share of inheritance. Legal complexities and bureaucratic impediments make matters more contentious with regard to the implementation of these rights, and, therefore, one requires constant and legal reformation with thorough enforcement mechanisms.

To fulfill the objective of these laws, it is important to fill in the implementation gap that pervades between the legal provision and its implementation in real life. Public awareness for them, regarding this equal gender inheritance right, is really critical so that legal reformations become practical phenomena. Legal literacy programs and accessible legal aid help empower women to effectively navigate the legal system and assert their rights without intimidation or financial cost. In addition, simplification of procedures in courts and the setting up of specifically dedicated family courts help speed up the solutions of inheritance disputes and ensure speedy justice to all parties concerned. Restructuring in the succession laws to try for the modern assimilation of values toward equality and fairness is the need of the hour.

The proper documentation of a property transaction can help avoid disputes, protect women’s inheritance rights, and internalize these changes into the cultural mindset along with a supportive judicial and administrative framework. India would set up a fairer and more just succession framework, attuned to the advent of modern concepts of fairness and justice, by working to address all of these issues and, generally implementing comprehensive reforms. While complete gender equality in inheritance remains a journey and, therefore, something yet to be achieved, additional effort will make it absolutely possible to build a society that affords everyone the opportunity to enjoy legal protective regulations and rights regardless of gender. The needs of successive reforms and reinforcement that should help to update succession laws focusing on serving the interest of all citizens in making an inheritance of property or assets in a controlled, systematic, and well-balanced way that really reflects the state’s avowed commitment to gender equality and social justice.

REFERENCES

Mulla, Hindu Law, 22nd ed. 2019 (LexisNexis). https://www.lexisnexis.in/en-in/products/mulla-hindu-law-22nd-edition.page (Last Visited Oct 18, 2024).
Paras Diwan, Modern Hindu Law, 14th ed. 2019 (Allahabad Law Agency). https://www.allahabadlawagency.com/modern-hindu-law (Last Visited Oct 17, 2024).
The Hindu Succession Act 1956 Bare Act, 2021 Edition (Government of India). https://www.indiacode.nic.in/handle/123456789/1497?view_type=browse&sam_handle=123456789/1392 (Last Visited Oct 19, 2024).
Amita Dhanda, “Equal Property Rights to Women: The Impact of the Hindu Succession Act Amendment 2005,” Indian Journal of Law and Society, 2020. https://www.ijls.in/articles/equal-property-rights-to-women (Last Visited Oct 20, 2024).
R.K. Agarwal, “Inheritance Law in India: Challenges and Reforms,” Journal of Indian Law Institute, 2018. https://www.jili.in/articles/inheritance-law-in-india (Last Visited Oct 16, 2024).
Neera Chandhoke, “Women’s Inheritance Rights in India: Progress and Pitfalls,” Law and Society Review, 2019. https://www.lawsocietyreview.org/articles/womens-inheritance-rights (Last Visited Oct 17, 2024).
“Rights of Women under Hindu Succession Act,” ipleaders Blog. https://blog.ipleaders.in/rights-of-women-under-hindu-succession-act (Last Visited Oct 19, 2024).
“Hindu Succession Act, An Overview,” Law Insider. https://www.lawinsider.in/columns/hindu-succession-act-overview (Last Visited Oct 20, 2024).

[1] Mulla, Hindu Law, Page no. 22-30, 22nd ed. 2019 (LexisNexis). (https://www.lexisnexis.in/en-in/products/mulla-hindu-law-22nd-edition.page) (Last Visited Oct 20, 2024).

[2] The Hindu Succession Act 1956 Bare Act, 2021 Edition (Government of India). (https://www.indiacode.nic.in/handle/123456789/1497?view_type=browse&sam_handle=123456789/1392) (Last Visited Oct 16, 2024).

[3] Amita Dhanda, “Equal Property Rights to Women: The Impact of the Hindu Succession Act Amendment 2005,” Indian Journal of Law and Society, 2020.(https://www.ijls.in/articles/equal-property-rights-to-women) (Last Visited Oct 18, 2024).

[4] Vineeta Sharma v. Rakesh Sharma, AIR 2020 SC 641

[5] Prakash v. Phulavati, AIR 2016 SC 1912

[6] Danamma @ Suman Surpur v. Amar, AIR 2018 SC 1238

[7] Shamim Ara v. State of U.P., AIR 2002 SC 3551

[8] Neera Chandhoke, “Women’s Inheritance Rights in India: Progress and Pitfalls,” Law and Society Review, 2019. (https://www.lawsocietyreview.org/articles/womens-inheritance-rights) (Last Visited Oct 20, 2024).

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