amity law school lucknow- family law

7/22/2019 Amity Law School Lucknow- Family Law

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MITY L W SCHOOL

LUCKNOW

FAMILY LAW - II

HINDU SUCCESSION ACT 1956: A

Peep Into The Status Of Woman

After The Amendment Of 2005

SUBMITTED TO: SUBM ITTED BY:

MRS. VI JETA DUA TANDON MAYURIGUPTA

B.A; L L.B (H); I V(B)

A8111111069


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ACKNOWLEDGEMENT

The assignment work bears the imprint of many people, and I express my

gratitude to all those who have helped me and rendered their help in all the

possible ways in a completion of my assignment.

No work can be successful without the guidance and blessing of elders and this

work is no exception. It is a matter of immense pleasure to express my gratitude

to my faculty HonbleMrs. Vi jeta Dua Tandon for her guidance and excellent

insights which gave direction and focus to this paper. I thank her for lending her

precious time in making this assignment an authentic piece of work.

I also owe sincere gratitude to the staff at library for always helping in the process

of finding material and other sources for research. I am very grateful to my

seniors and all the individuals involved in the subgroup for their contributions and

assistance in compiling this assignment and the recommendations that go with it:

they are the outcome of an open, interactive and creative cooperation.

I also thank social networking site for searching the required information in

precise and as per needed. How I can forget to give credit and my satisfaction to

my friends. My sense of gratitude is due to AMITY LAW SCHOOL,

LUCKNOW.

At last, I express my heartfelt gratitude to the God Almighty, without whose

blessing and motivation, the completion of this assignment would have been

impossible.

Thanks to all.......

Mayuri upta


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TABLE OF CONTENTS

INTRODUCTION.............................................................................................4-5 CONSTITUTIONAL CONCERNS..................................................................6-7 SECTION 6 OF THE HINDU SUCCESSION ACT, 1956.................................8 THE HINDU SUCCESSION (AMENDMENT), ACT, 2005........................9-11 CASE LAWS IN SUPPORT OF THE AMENDMENT...............................12-14 CHANGES BROUGHT IN THE POSITION OF WOMEN (SPECIALLY

FOCUSING ON SECTION 6)......................................................................15-16

COMPARATIVE STUDY OF WOMENS INHERITANCE RIGHT UNDERHINDU SUCCESSION ACT.............................................................................17

CONCLUSION AND SUGGESTION...............................................................18 BIBLIOGRAPHY...............................................................................................19


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INTRODUCTION

"Women constitute half the world's population, perform nearly two-thirds of its

hours, and receive one-tenth of the world's income and less than one hundredth of

the property."

The United Nation's Report, 1980

Women since the Vedic times were held in great regard and enjoyed various

rights and privileges. She shared equal rights and obligations with her husband.

However, the only discrimination they were subjected to was in matters of

inheritance but they were never excluded completely from inheriting. Slowly this

discrimination crept into other areas. The presence of fewer rights of women than

men in Indian Personal laws is generally attributed to the sanctity of religious

law. Several changes effected over the decades indicate the selective application

of sanctity argument.

The Hindu Succession Act came into force on 17

th

June 1956. It broughtcomprehensive changes in the law of intestate succession among Hindus

compatible with the changed socio-economic scenario of the Hindu society. The

long felt need of improving the position of Hindu females through an effective

legislation was fulfilled and attempts were made to give equal status to females as

compared to males. Various measures have been taken to bring some reforms far

reaching reforms in the system of Hindu inheritance and succession.

The Government after passing the H indu Womens Right to Property Act, 1937

had set upRau Commi tteeto suggest reforms. The Committee after studying the

existing rules of Hindu Succession suggested some revolutionary changes in the

system in order to remove inequalities and injustice to womenfolk amongst

Hindus and accordingly recommended for the codification of the law relating to

succession and codification of Hindu law in successive stages.


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On the basis of the suggestions and recommendations of the Rau Commit tee

several legislations were adopted by the legislature, the most outstanding of

which is H indu Succession Act 1956passed to meet the needs of a progressive

Hindu society.

Many changes were brought about with the onset of Hindu Succession Act 1956

that gave women greater rights but they were still denied the important

coparcenary rights. Subsequently, a few States enacted their own laws for

division of ancestral property.

In what is known as the Kerala model, the concept of coparcenary was abolished

and according to the Kerala Joint Family System (Aboliti on) Act, 1975, the heirs

(male and female) do not acquire property by birth but only hold it as tenants as if

a partition has taken place.

Andhra Pradesh [The Hindu Succession (Andhra Pradesh Amendment) Act,

1986],Tamil Nadu[The Hindu Succession (Tamil Nadu Amendment) Act, 1989],

Karnataka [The Hindu Succession (Karnataka Amendment) Act, 1994] , and

Maharashtra[The Hindu Succession (Maharashtra Amendment) Act, 1994] also

enacted laws, where daughters were granted coparcener' rights or a claim on

ancestral property by birth as the sons.

In 2000, the 174th reportof the 15th Law Commissionsuggested amendments to

correct the discrimination against women, and this report forms the basis of the

present Act. Discrimination against women was the key issue before the Law

Commission. The amendment made in 2005 gives women equal rights in the

inheritance of ancestral wealth, something reserved only for male heirs earlier. It

indeed, is a significant step in bringing the Hindu Law of inheritance in accord

with the constitutional principle of equality. Now, as per the amendment, Section

6 of the Hindu Succession Act, 1956 gives equal rights to daughters in the Hindu

Mitakshara coparcenary property as the sons have. The amendment was made

because there was an urgent need for certainty in law.


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CONSTI TUTI ONAL CONCERNS

Due to these inequalities with regard to women and property rights, the very

constitutionality of the Act is questionable. Part III of the Indian Constitution

guarantees to India's citizens certain fundamental rights, and Article 13 therein

voids "laws in force" that are in derogation of these rights. 1 The Hindu

Succession Act seems to contravene some of these fundamental rights,

particularly the right to equality between women and men.

Article 14 says,"The State shall not deny to any person equality before the law or

the equal protection of the laws."2

Article 15(1) prohibits discrimination on grounds of sex, and Article 15(3) allows

the State to make special provisions for women and children3. Part IV of the

Constitution, "Directive Principles of State Policy," includes a provision

mandating the State to direct its policies towards securing equal economic rights

to all citizens, regardless of sex.4

In combination with the "Fundamental Rights" section, the Constitution seems to

set forth inalienable rights that should force both Parliament and the judiciary to

amend the current state of succession rights for Hindu females. However, this has

not been the case, presumably due to Articles 25 and 26 of the Constitution.

These articles guarantee to all Indians the liberty to freely practice their religions

and grant to religious denominations the freedom to manage their own affairs,

providing the justification for the existence of a separate system of personal laws

based on religion.5The Parliament has the power under Article 44 to amend the

current personal law system and create a Uniform Civil Code, but this power does

not extend to the courts. Thus, the courts have no power to use gender

1I ndian Constitution, Part I I I , Article 31.

2Ibid. Part.I I I , Article 14.

3Ibid. Part. I I I , Arti cles. 15(1) and15(3).

4See I bid. Part. IV, Ar ticle. 39(d).

5

See John H . Mansfield, The Personal L aws or a Uni form Civil Code?, in REL IGION ANDLAW IN I NDEPENDENT INDI A 139, 153 (Robert D. Bair d ed., 1993).


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discrimination claims to declare the personal law system to be per se

unconstitutional.6

In P.E. Mathew v. Uni on of I ndia, the High Court of Kerala upheld certain

provisions of the Indian Divorce Act that created an extra burden only for

Christians, who challenged the Divorce Act under the "Fundamental Rights"

articles of the Constitution.7The Court held that personal laws do not fall into the

category of "laws" or "laws in force" encompassed by Article 13 in its definition

of laws subject to fundamental rights limitations.8 This same holding probably

also applies to claims of gender discrimination in personal laws. 9

Although the Constitution leaves room for abolishing religious personal

laws through Article 44's mandate for a Uniform Civil Code, it is not necessarily

unconstitutional to continue giving effect to these laws, presumably because

of the power of Articles 25 and 26 protecting religious custom and practice. The

Law Commission of India (see Part IV below) argues that this stance on the

conflict between fundamental rights and the personal laws is a "blatant disregard

and unjustified violation" of the equal rights guaranteed to women by the Indian

Constitution.10

The courts should take a more activist reading of Articles 13, 14, and 15, as

well as of the Constitution's "Directive Principles of State Policy," in order to

create greater economic protections for women. The judiciary should protect

women's economic rights through the laws that are already in force, using as a

starting point Parliament's intent in codifying the Succession Act in 1956 to

include greater rights for women.11

6Supra Note 5

7A.I .R. 1999 (Ker.) 345, 353.

8Ibid

9Supra Note 5, At 153

10

Law Commission Report11I bid


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SECTION 6 OF THE HINDU SUCCESSION ACT, 1956

(RESTATED FOR CONVENI ENCE)-

Devolution Of Interest In Coparcenary Property.

Whenever a male Hindu dies after the commencement of this Act, having at the

time of his death, an interest in the Mitakshara Coparcenary property, his interest

in the property shall devolve by survivorship upon the surviving members of the

coparcenary and not in accordance with this Act:

Provided that, if the deceased had left him surviving a female relative specified in

class I of the Schedule or a male relative, specified in that class who claims

through such female relative, the interest of the deceased in the Mitakshara

coparcenary property shall devolve by testamentary or intestate succession, as the

case may be and not by survivorship.

Explanation 1.- For the purpose of this section, the interest of a Hindu

Mitakshara coparcener shall be deemed to be the share in the property that would

have been allotted to him if a partition of the property had taken place

immediately before his death, irrespective of whether he was entitled to claim

partition or not.

Explanation 2.- Nothing contained in the proviso to this section shall be

construed as enabling a person who has separated himself from the coparcenary

before the death of the deceased or any of his heirs to claim on intestacy a share

in the interest referred to therein.


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THE HINDU SUCCESSION (AMENDMENT) ACT, 2005-

[6. Devolution Of Interest In Coparcenary Property.-

(1)On and from the commencement of the Hindu Succession (Amendment) Act,

2005, in a Joint Hindu family governed by theMitakshara law, the daughter of a

coparcener shall,--

(a)by birth become a coparcener in her own right in the same manner as the son ;(b)have the same rights in the coparcenary property as she would have had if she had

been a son;

(c)be subject to the same liabilities in respect of the said coparcenary property asthat of a son,

and any reference to a HinduMitakshara coparcener shall be deemed to include a

reference to a daughter of a coparcener:

Provided that nothing contained inthis sub-section shall affect or invalidate any

disposition or alienation including any partition or testamentary disposition of

propertywhich had taken place before the 20th day of December, 2004.

(2) Any property to which a female Hindu becomes entitled by virtue of

subsection (1) shall be held by her with the incidents of coparcenary ownership

and shall be regarded, notwithstanding anything contained in this Act, or any

other law for the time being in

force in, as property capable of being disposed of by her by testamentary

disposition.

(3) Where a Hindu dies after the commencement of the Hindu Succession

(Amendment) Act, 2005, his interest in the property of a Joint Hindu family

governed by the Mitakshara law, shall devolve by testamentary or intestate

succession, as the case may be, under this Act and not by survivorship, and the

coparcenary property shall be deemed to have been divided as if a partition had

taken place and,-


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(a)the daughter is allotted the same share as is allotted to a son;(b) the share of the pre-deceased son or a pre-deceased daughter, as they would have

got had they been alive at the time of partition, shall be allotted to the surviving

child of such pre-deceased son or of such pre-deceased daughter; and

(c) the share of the pre-deceased child of a pre-deceased son or of a predeceaseddaughter, as such child would have got had he or she been alive at the time of the

partition, shall be allotted to the child of such pre-deceased child of the pre-

deceased son or a pre-deceased daughter, as the case may be.

Explanation.- For the purposes of this sub-section, the interest of a Hindu

Mitakshara coparcener shall be deemed to be the share in the property that would

have been allotted to him if a partition of the property had taken place

immediately before his death, irrespective of whether he was entitled to claim

partition or not.

(4)After the commencement of the Hindu Succession (Amendment) Act, 2005,

no court shall recognize any right to proceed against a son, grandson or great-

grandson for the recovery of any debt due from his father, grandfather or great-

grandfather solely on the ground of the pious obligation under the Hindu law, of

such son, grandson or great-grandson to discharge any such debt:

Provided that in the case of any debt contracted before the commencement of the

Hindu Succession (Amendment) Act, 2005, nothingcontained in this sub-section

shall affect--

(a)the right of any creditor to proceed against the son, grandson or great-grandson,as the case may be; or

(b) any alienation made in respect of or in satisfaction of, any such debt, and anysuch right or alienation shall be enforceable under the rule of pious obligation in

the same manner and to the same extent as it would have been enforceable as if

the HinduSuccession (Amendment) Act, 2005 had not been enacted.


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Explanation.-For the purposes of clause (a), the expression "son", "grandson" or

"great-grandson" shall be deemed to refer to the son, grandson or great-grandson,

as the case may be, who was born or adopted prior to the commencement of the

Hindu Succession (Amendment) Act, 2005.

(5)Nothing contained in this section shall apply to a partition, which has been

effected before the 20th day of December 2004.

Explanation- For the purposes of this section "partition" means any partition

made by execution of a deed of partition duly registered under the Registration

Act, 1908 (16 of 1908) or partition affected by a decree of a court.]


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CASE LAWS IN SUPPORT OF THE AMENDMENT-

Even after passing of the Amending Act and substitution of S. 6, a number of

questions were raised in the legal circles as to whether the Amending Act was

prospective or retrospective and whether a daughter born before coming into

force of the Amending Act i.e., 9th September 2005 was entitled to benefit under

the newly incorporated S. 6 of the Act. There were divergent views and

conflicting arguments.

Fortunately, these issues have now come up before our Courts and we now have

the benefit of some judicial pronouncements on the effect of the new S. 6 of the

Act.

In Pravat Chandra Pattnaik and Others vs. Sarat Chandra Pattnaik and

Another12, the Orissa High Court had occasion to consider the effect of the

Amending Act and the new S. 6 of the Act. It was a case relating to partition of

Hindu Mitakshara coparcenary property. After decision by the lower Court, an

appeal was preferred to the High Court. The Court held that the Amending Act

was enacted to remove the discrimination contained in S. 6 of the Act by giving

equal rights and liabilities to the daughters in the Hindu Mitakshara Coparcenary

property as the sons have. The Amending Act came into force with effect from 9-

9-2005 and the statutory provisions create new right. The provisions are not

expressly made retrospective by the Legislature. Thus, the Act itself is very clear

and there is no ambiguity in its provisions. The law is well settled that where the

statute's meaning is clear and explicit, words cannot be interpolated. The words

used in provisions are not bearing more than one meaning. The amended Act

shall be read with the intention of the Legislature to come to a reasonable

conclusion. Thus, looking into the substance of the provisions and on conjoint

reading, Ss.(1) and (5) of S. 6 of the Act are clear and one can come to a

conclusion that the Act is prospective. It creates substantive right in favour of the

daughter. The daughter got a right of coparcener from the date when the amended

12AIR 2008 Orissa 133


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Act came into force i.e., 9-9-2005. The Court also did not accept the contention

that only the daughters, who are born after 2005, will be treated as coparceners.

The Court held that if the provision of the Act is read with the intention of the

legislation, the irresistible conclusion is that S. 6 (as amended) rather gives a right

to the daughter as coparcener, from the year 2005, whenever they may have been

born. The daughters are entitled to a share equal with the son as a coparcener.

The same issue also arose before the High Court of Karnataka in Sugalabai v.

Gundappa A. Maradi and Others13. The Court was considering appeals where

pending the appeals the Amending Act was passed by the Parliament. The Court

held that as soon as the Amending Act was brought into force, the daughter of a

coparcener becomes, by birth, a coparcener in her own right in the same manner

as the son. Since the change in the law had already come into effect during the

pendency of the appeals, it is the changed law that will have to be made

applicable to the case. The daughter, therefore, by birth becomes a coparcener

and that there is nothing in the Amending Act to indicate that the same will be

applicable in respect of a daughter born on and after the commencement of the

Amending Act. In coming to the conclusion, the Court referred to the following

principles of interpretation of statutes as laid down by the Apex Court :

(1)Statutory provisions which create or take away substantive rights areordinarily prospective. They can be retrospective if made so expressly or by

necessary implication and the retrospective operation must be limited only to

the extent to which it has been so made either expressly or by necessary

implication.

(2)The intention of the Legislature has to be gathered from the words used by it,giving them their plain, normal, grammatical meaning.

(3)If any provision of a legislation, the purpose of which is to benefit a particularclass of persons is ambiguous so that it is capable of two meanings, the

meaning which preserves the benefits should be adopted.

(4)If the strict grammatical interpretation gives rise to an absurdity orinconsistency, such interpretation should be discarded and an interpretation

13ILR 2007 KAR 4790; 2008 (2) Kar LJ 406


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which will give effect to the purpose will be put on the words, if necessary,

even by modification of the language used.

The Court also applied the principles stated in American Jurisprudence14quoted

with approval by the Supreme Court in S. R. Bommai v. Union of

India15 .One additional issue was raised before the Court in this case as to

whether there was a conflict between the Amending Act and the provisions of the

Hindu Succession (Karnataka Amendment) Act, 1994.

The Court held that When there is a conflict between the State law and the subsequent

law made by the Parliament on an Entry in Concurrent List, it is the law made by the

Parliament that will prevail over the State Law even though the State law was passed

after obtaining assent of the President and it is not necessary that law made by the

Parliament should expressly repeal a State law.

It is submitted that, in view of the aforesaid decisions of the Orissa and the

Karnataka High Courts, the issue is presently settled and that the daughter of a

coparcener becomes, by birth, a coparcener in her own right in the same manner

as the son, irrespective of whether she was born before or after the Amending Actcame into force.

14

2nd Edition, Vol. 73, Page 434, Part 366.15

AIR 1994 SC 1980.


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CHANGES BROUGHT I N THE POSITION OF THE WOMEN

(SPECIF ICALLY FOCUSING ON SECTION 6):

Out of many significant benefits brought in for women, one of the significant

benefit has been to make women coparcenary (right by birth) in Mitakshara joint

family property. Earlier the female heir only had a deceased man's notional

portion. With this amendment, both male and female will get equal rights. In a

major blow to patriarchy, centuries-old customary Hindu law in the shape of the

exclusive male Mitakshara coparcenary has been breached throughout the

country.

The preferential right by birth of sons in joint family property, with the offering

of "shradha" for the spiritual benefit and solace of ancestors, has for centuries

been considered sacred and inviolate. It has also played a major role in the

obvious preference for sons in Indian society. This amendment, in one fell swoop,

has made the daughter a member of the coparcenary and is a significant

advancement towards gender equality.

The significant change of making all daughters (including married ones)

coparceners in joint family property - has been of a of great importance for

women, both economically and symbolically. Economically, it can enhance

women's security, by giving them birthrights in property that cannot be willed

away by men.

In a male-biased society where wills often disinherit women, this is a substantial

gain. Also, as noted, women can become kartas of the property. Symbolically, all

this signals that daughters and sons are equally important members of the parental

family. It undermines the notion that after marriage the daughter belongs only to

her husband's family. If her marriage breaks down, she can now return to her

birth home by right, and not on the sufferance of relatives. This will enhance her

self-confidence and social worth and give her greater bargaining power for

herself and her children, in both parental and marital families.


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Now under the amendment, daughters will now get a share equal to that of sons at

the time of the notional partition, just before the death of the father, and an equal

share of the father's separate share and equal distribution of undivided interest in

co-parcenery property.

However, the position of the mother vis--vis the coparcenary stays the same.

She, not being a member of the coparcenary, will not get a share at the time of the

notional partition. The mother will be entitled to an equal share with other Class I

heirs only from the separate share of the father computed at the time of the

notional partition.

In effect, the actual share of the mother will go down, as the separate share of the

father will be less as the property will now be equally divided between father,

sons and daughters in the notional partition.


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COMPARATIVE STUDY OF WOMENS INHERITANCE

RIGHT, UNDER H INDU SUCCESSION ACT16

1.The Deceased Mans Separate Property.Before the passing of HSA Amendment, 2005: Equal shares for class I heirs,

viz., son, daughter, widow, mother and specified heirs of predeceased sons and

daughters.

The heirs of both the sexes have full right to alienate inherited property.

Af ter the passing of HSA Amendment, 2005:No change, except for expanding

the list of class I heirs for gender equality.

No change.

2.Agr icultural L and (Section 4(2)Befor e the passing of HSA Amendment, 2005:Inheritance of agricultural land is

subject to state-level tenurial laws and not to HSA. Many of the tenurial law

specify inheritance rules that are highly gender unequal.

After the passing of HSA Amendment, 2005:Inheritance rights in all

agricultural land are subject to the HSA(overriding state laws inconsistent with

the Act), and so effectively are now gender equal.

3.The Mitakshara oint F amily Property (Section6)Before the passing of HSA Amendment, 2005:Class I heirs(males and

females)as specified above have equal claims in mans notional share of the

undivided joint family property. A man can however always will his notional

share.

Son has additional independent birth right in joint family property, as a

coparcener. Daughters cannot be coparcener.

Af ter the passing of HSA Amendment, 2005:No change except the specification

of Class I heirs.

Substituted Section 6 : Sons and daughters both have independent birth rights

(and liabilities) as coparceners in joint family property. These shares cannot be

willed away by the father.

16Landmark Step to gender equal ityBy Bina Agarwal, The Hindu, September 25, 2005, (Weekly Edi tion,2).


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CONCLUSION AND SUGGESTION:

1. One stems from retaining the Mitaksara joint property system. Making daughterscoparceners will decrease the shares of other Class I female heirs, such as the

deceased's widow and mother, since the coparcenary share of the deceased male

from whom they inherit will decline. In States where the wife takes a share on

partition, as in Maharashtra, the widow's potential share will now equal the son's

and daughter's. But where the wife takes no share on partition, as in Tamil Nadu

or Andhra Pradesh, the widow's potential share will fall below the daughter's.

2. Co-parcenary remains a primary entitlement of males; the law, no doubt providesfor equal division of the male co-parcener's share on his death between all heirs,

male and female; still, the law puts the male heirs on a higher footing by

providing that they shall inherit an additional independent share in co-parcenary

property over and above what they inherit equally with female heirs; the very

concept of co-parcenary is that of an exclusive male membership club and

therefore should be abolished. But such abolition needed to be dovetailed with

partially restricting the right to will (say to 1/3 of the property). Such restrictions

are common in several European countries. Otherwise women may inherit little,

as wills often disinherit them. However, since the 2005 Act does not touch

testamentary freedom, retaining the Mitaksara system and making daughters

coparceners, while not the ideal solution, at least provides women assured shares

in joint family property (if we include landholdings, the numbers benefiting could

be large).

3. If a Hindu female dies intestate, her property devolves first to husband'sheirs,then to husband's father's heirs and finally only to mother's heirs; thus the

intestate Hindu female property is kept within the husband's lien. Another reasonfor having an all India legislation is that if the Joint Family has properties in two

states, one which is governed by the Amending Act and the other not so

governed, it may result in two Kartas, one a daughter and the other a son.

Difficulties pertaining to territorial application of Amending Act will also arise.

Thus is the need for an all India Act or Uniform Civil Code more immediate.


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BIBLIOGRAPHY

BOOKS REFFERED:

DR.U.P.D.KESARI; MODERN HINDU LAW DR. PARAS DIWAN; FAMILY LAW P.K.DAS; NEW LAW ON HINDU SUCCESSION MULLA; PRINCIPLES OF HINDU LAW

ARTICLES REFFERED:

174th Report of Law Commission of India under the Chairmanship ofJustice B.P. Jeevan Reddy, dated 5th May, 2000.

7th Report of Parliamentary Standing Committee, dated 13th May, 2005.

URLs REFFERED:

www.hindu.com/2006/02/06/stories.htm www.indiainfoline.com/lega/feat/nomin.html www.ebc-india.com/lawyer/articles.htm www.prayer.de/dharmashastra.htm www.jkhighcourt.nic.in www.indiankanoon.com www.scconline.com www.lawyersclubonline.com www.legaltrigger.com
http://www.hindu.com/2006/02/06/stories.htmhttp://www.hindu.com/2006/02/06/stories.htmhttp://www.indiainfoline.com/lega/feat/nomin.htmlhttp://www.indiainfoline.com/lega/feat/nomin.htmlhttp://www.ebc-india.com/lawyer/articles.htmhttp://www.ebc-india.com/lawyer/articles.htmhttp://www.prayer.de/dharmashastra.htmhttp://www.prayer.de/dharmashastra.htmhttp://www.jkhighcourt.nic.in/http://www.jkhighcourt.nic.in/http://www.indiankanoon.com/http://www.indiankanoon.com/http://www.scconline.com/http://www.scconline.com/http://www.lawyersclubonline.com/http://www.lawyersclubonline.com/http://www.legaltrigger.com/http://www.legaltrigger.com/http://www.legaltrigger.com/http://www.lawyersclubonline.com/http://www.scconline.com/http://www.indiankanoon.com/http://www.jkhighcourt.nic.in/http://www.prayer.de/dharmashastra.htmhttp://www.ebc-india.com/lawyer/articles.htmhttp://www.indiainfoline.com/lega/feat/nomin.htmlhttp://www.hindu.com/2006/02/06/stories.htm

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