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GENERAL PRINCIPLES OF SUCCESSION UNDER CHRISTIAN LAW
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GENERAL PRINCIPLES OF SUCCESSION
UNDER CHRISTIAN LAW
AUTHORED BY - ALIND GUPTA
Abstract
Succession implies devolution of a
person’s property to his heirs. It can be done in two ways i.e., through
testamentary succession or intestate succession. The paper looks at the
principles informing succession under Christian Law, more particularly the Indian
Succession Act of 1925. Due to their unique position, the British enacted the
Indian Succession Act 1865 to govern Christians. In recognition of numerous
other laws that were enacted later and to ensure consistency, the Indian
Succession Act of 1925 was passed. The first part gives a brief background of
the Indian Succession Act. The second part looks at a couple of features of
Christian succession: domicile and consanguinity. The third part covers
intestate succession under Christian Law with particular reference to right of
women. The last part deals with testamentary succession.
INTRODUCTION
Succession implies devolution of a
person’s property to his heirs. It can be done in two ways i.e. through
testamentary succession or intestate succession. Testamentary succession is the
succession of property though a written will by his property devolves to
specific heirs. Intestate succession refers to succession through a law (based
on religion) when a person dies without making a will.
The law of succession relating to
Christians is contained in Indian Succession Act, 1925. However, the existence
of many customary laws and specific legislations have ensured that the
Christian succession laws are not uniform. Before the landmark judgment in the
case of Mary Roy v. State of Kerala[1],
Christians in India were governed by multiple acts which has been discussed in
the latter part of the project.
Indian Succession Act of 1925 is a
consolidating act as it seeks to bring together all the laws, at least of
testamentary succession, applicable in India.[2] The
British were faced with the task of ascertaining the succession laws applicable
to different communities in India. With respect to Hindus and Muslims, the
respective sacred books served as yardstick to formulate their succession laws.
However, many other communities including Christians did not have a concrete
law and it would not have been appropriate to subject them to another
religion’s law. Due to these factors,
the British felt the need to legislate a new law especially for communities
having no concrete law. This led to the formulation of Indian Succession Act of
1865 based on English law. Many of the general principles relating to
testamentary succession were applicable to Hindus and Muslims as well. Many
other statutory legislations making it difficult to ascertain the law
applicable to particular community which led to the passing of the consolidated
Indian Succession Act of 1925.[3]
Section 2(d) defines ‘Indian
Christian’ as ‘a native of India who is, or in good faith claims to be, of
unmixed Asiatic descent and who professes any form of the Christian religion’.[4]
Domicile, under Christian law of succession, plays a very important role as it
determines the law which would apply in case of movable property of the
deceased.[5]
The act recognizes three types of heirs in case of Christians i.e. spouse,
lineal descendants and kindred.
Even after the coming into force of
the Indian Succession Act,1925 there are multiple laws governing Christians in
various places as mentioned above which make uniformity a distant dream. There
is also no room for illegitimate children in case of intestate succession.
1. INDIAN SUCCESSION ACT -
BACKGROUND
After the British came to India, they
initially adopted a policy of non-interference and were reluctant to change the
laws. However, as they settled down, it got increasingly difficult to ascertain
the laws applicable to their subjects owing to the heterogeneity and diversity
not seen in England. As far as the two major communities were concerned i.e.
Hindus and Muslims, the situation was much simpler as they had their ancient
texts which formed the basis of their laws. But there were many other religious
communities who could not relate to either of the above mentioned religions. It
would have been inappropriate to place them under Hindu or Muslim law as they
held no allegiance to them. These minor
communities included Christians, Parsis, etc.[6]
Owing to the legal vacuum with respect to the
communities such as Christians and the concomitant process of codification
taking place it India, it was thought that an enactment was required to fill
this lacuna. Thus, the British passed the Indian Succession Act in the year
1865 which was based mainly on the English principles of succession with appropriate
modifications. Various other supplementary legislations like Married Woman’s
Property Act 1874, Succession Certificate Act 1889, Probate and Administration
Act 1903 came into force in the subsequent years. This created a horde of
legislations which made it difficult to ascertain the law applicable to a
particular community. Thus, there was a
need to consolidate all the laws to ensure consistency and better justice
delivery. This purpose was fulfilled by the Indian Succession Act of 1925.
The Indian Succession Act, 1925 aims
to consolidate the intestate and testamentary succession laws in India. There
were numerous acts governing succession of various communities in India which
lead to confusion and lack of coherence.
Some of the acts were Indian Succession Act 1865, The Hindu Wills Act
1870, Probate and Administration Act 1889, Native Christian Administration of
Estate Act 1901, Succession Certificate Act 1889, etc. Since the preamble of
the act explicitly claims that the Indian Succession Act is consolidating act,
same effect should be given to the provisions as they stood before the coming
of the Indian Succession Act of 1925.[7]
Succession under Indian Succession
Act can broadly be divided into testamentary and intestate succession. The
various sections in the statute revolve around the devolution of immovable and
movable properties on the owner’s death either by will or inheritance. While
the succession laws relating to intestate succession are made applicable to
communities excluding Hindus and Muslims owing to their personal laws, the
provisions relating to testamentary succession are applicable to all the
communities barring minor exceptions.
The enactment of Indian
Succession Act was in line with the codification of laws in India in the latter
half of 19th century. Although the legislation did make the law
relating to non-Hindus and non- Muslims more concrete, it also had a huge
contribution in steamrolling the existing customs and usages. The case of Abraham v. Abraham[8] sums
up the entire change in the approach of the colonial rulers with respect to
customs.
This paper will be analysing the
testamentary and intestate succession provisions applicable to Christians in
the subsequent chapters. An ‘Indian
Christian’ has been defined under Section 2(d) of the Indian Succession
Act, 1925: "Indian Christian" means a native of India
who is, or in good faith claims to be, of unmixed Asiatic descent and who
professes any form of the Christian religion. [9] In Kamawati v. Digbijai Singh, the court conclusively held that a
person who has converted from Hinduism to Christianity would not be governed by
Hindu law but by Indian Succession Act, 1925. [10]
Although religion is a matter of faith and belief but in determining the law
that is applicable, one should look at the outward conduct of the person and
the formal manifestations of his belief. [11]
2. IMPORTANCE OF DOMICILE
Unlike other personal laws, domicile
plays a key role in devolution of property of a deceased Christian. Section 5
of the Indian Succession Act, 1925 lays down that succession to immovable
property in India shall be governed by the law of India irrespective of the
domicile of the deceased. However, as regard to the movable property domicile
of the deceased determines the law applicable to the devolution of the
property. The country where the person had his domicile when he died would
determine the devolution of immovable property belonging to him. e.g. G, an
Indian having his domicile in England died in India. The Indian law i.e. Indian
Succession Act of 1925 would apply to his immovable property while the law
applicable to his movable property would be of England since had his domicile
in England when he died.
Domicile and nationality are not
synonymous. Domicile is the place where you have permanent residence which can
be different from your nationality. A person can change the domicile without
changing his nationality and vice versa. Hence, domicile which has been
mentioned in the section cannot be construed as to mean nationality or
citizenship. Section 6 explicitly prohibits a person from having multiple
domiciles.[12]
Domicile as mentioned in Section 5 of
the Indian Succession Act becomes relevant only at the time of death of a person.
It is immaterial where the deceased was residing before his death. Domicile
only at the time of the deceased’s death is relevant. Every person come into
being with a domicile of origin that is super-imposed on him depending upon his
birth in the family. Generally, a legitimate child attains the domicile of his
father while an illegitimate child gets the domicile of his mother. Domicile of origin which has been attained by
person from his father or mother, remains with till he has relinquished it and obtained
a new domicile. A person acquires a new
domicile and gives up his domicile of origin by residing in a place different
from the domicile of origin with the intention of permanently staying there.
The domicile of the minor is
determined by the domicile of the parent from which he obtained his domicile of
origin. A change in parent’s domicile would affect the same change in the
domicile of the minor. However, after gaining majority a person can have a
domicile of choice i.e. he can choose to change his domicile by changing his
place of residence with the intention of permanently staying there. Section 10
of Indian Succession Act, 1925 provides when a person moves to a place for
fixed habitation, he acquires a new domicile and gives up the former one.[13] A
woman acquires the domicile of her husband when she enters into a marital bond.
However, this rule does not apply when they have been separated or the husband
is undergoing a sentence of transportation. [14]
Thus, we can see how important role
domicile plays while devolution of property has to be done. This is in stark
contrast to other personal laws of Hindus and Muslims where domicile plays an
insignificant role. Domicile of a person, in Christian succession, determines
the law applicable to the succession of the movable property of the deceased.
Hence, the domicile needs to be given due emphasis when devolution of property
under Indian Succession Act is in question.
Section 20 makes it clear that on
marriage no party shall acquire any vested interest in the property of another.
“Interests and powers not acquired
not lost by marriage. -(1) No person shall, by marriage, acquire any interest
in the property of the person whom he or she marries or become incapable of
doing any act in respect of his or her own property which he or she could have
done if unmarried.”[15]
This is in stark contrast to the
Hindu Succession Act in which the share of a co-parcenary keeps fluctuating
whenever there is a birth, addition or death of a member. This rule has been
created for Christians because the rights of succession emerge not upon
marriage but when there is a death in the family. Secondly, giving rights to
spouse on marriage would be in contradiction with other sections which regulate
and recognize rights of succession as between husband and wife. [16]
CONSANGUINITY
Section 25 defines that kindred or
consanguinity is the relationship of the people that have descended from a
common ancestor i.e. people from the same stock. This section lays down the
foundation for who can succeed to deceased’s property. In Christian law, there
are 3 heirs that are recognized in Indian Succession Act, 1925. There are two
types of consanguinity defined under the Indian Succession Act as per Sections
25 and 26. Section 25 defines lineal consanguinity as the relationship between
two persons, one of whom has descended in a direct line from the other, such as
the relation between a father and a child. Collateral consanguinity, as defined
under Section 26 covers relation between two persons who are descended from the
same stock or ancestor but neither of whom is descended in a direct line from
the other. Degrees can be ascertained by
first going to the common ancestor then to the person entitled to receive the
property. There is no difference between half blood and full blood in terms of
succession of the property of the deceased. There are three types of heirs
recognized in Christian law of succession i.e. lineal descendants, collaterals
and spouse.[17]
3. INTESTATE SUCCESSION
Section 30 of Indian Succession Act
determines as to when a person is qualified to die as intestate. ‘A person is
deemed to die intestate in respect of all property of which he has not made a
testamentary disposition which is capable of taking any effect.’[18]
Thus if a person has not made a will as regards to the devolution of his
property, he is deemed to have died intestate. However, even in cases where a
person has made a will, he can be considered to have died intestate if the will
is invalid, incomplete, illegal or revoked by a court of law. [19]In
the case of Fooks v. Cuffe, there was
a complete lapse of all the beneficial interests and the executor had
pre-deceased the testator. The court held that, since the testator died without
naming another person as testator, he was deemed to have died intestate. [20]
The Indian Succession Act lays down that a
person who has died intestate, his property would devolve upon his spouse or
his kindred. It’s explanation also provides that a widow can be excluded from
getting a share in husband’s property by a valid contract made before the
marriage.
If a person has died intestate and left behind
widow and lineal descendants, then 1/3rd property would go to the
widow and 2/3rd to the lineal descendants. If he has left behind no
lineal descendants but kindred, then the widow will get 1/2 property and rest
would go to collaterals. If there are no kindred, then widow will get the
entire property. Lineal descendants do not cover off-springs that are conceived
outside the marital bond of husband and wife.[21]
The same rule is applicable to a widower.[22]
If the deceased has left no widow,
then the property would devolve upon his lineal descendants or to his kindred
according to rules mentioned under Section 36.[23]
If a person has left no kindred, then the state would be entitled to get all the
property as ultimus haeres i.e. the
state’s prerogative to get the property of a person having no hier. This is
also known as the policy of escheat.
Child, as construed in the section,
does not include an illegitimate child. Section 38 lays down that property
shall equally divide among grandchildren if there are no surviving children of
the deceased and if there is a surviving grandchild then all property shall go
to him. When there are lineal descendants of varying degrees, then the property
shall be divided in such a number of equal shares as may correspond with the
number of lineal descendants who stood in the nearest degree of kindred to him
or having the same degree predeceased him. The devolution is similar to the
principles of Hindu Succession Act where nearest degree gets the share per stripes and their subsequent heirs, per capita. Doctrine of representation
has also been implicitly given place in Section 40(2) when it states the more
remote lineal descendants would take shares of their parents had they survived
the intestate.
When there are no lineal descendants
and the widow has taken her half share, the intestate’s father shall succeed to
the property. [24]If his
father his dead, then the mother and brothers/sisters shall be given equal
shares.[25]In
the case where the intestate has left no lineal descendant, brother or sister
then the property would devolve to the nearest degree relative present at the
time of the death of the intestate. These sections were specifically pointed
out by the law commission as violating right to equality under the Indian
Constitution.[26]
RIGHTS OF CHRISTIAN WOMEN
This divergence in the personal laws
relating a particular community made it easy to bypass the concrete provisions
enshrined in the Indian Succession Act, 1925 especially those related to
women’s rights. For example, Section 28 of the Travancore Succession Act, 1916
laid down that the sons would succeed to father’s property subject to the claim
of daughter’s streedhana. The section fixed streedhana at 5000 Rs. or 1/4th of
the share of son, whichever was less. This patriarchal section ensures that the
women were devoid of the majority of family property. It not only made the
Indian Succession Act kaput, but it also ensured that the Right to equality
guaranteed under the Constitution remained merely on paper.
The multiplicity of laws was a
concern and it was partially cured in the case of Mary Roy v. State of Kerala, when the Supreme Court held that the
Indian Succession Act would apply to the states of Cochin and Travancore and
would thereby, bypass them. Therefore, the Cochin and Travancore Christian
Succession laws were repealed.[27]
However, even after the passing of
the Mary Roy verdict, there are many
territories which are not governed by the Indian Succession Act, 1925 but by
their special or customary laws. Further, there have been various incidents
that the females are deprived of the family property by keeping them in the
dark and making them sign release deeds, which legally disentitles them from
claiming any share in the property. Many times, father-in-law keeps the
streedhana thereby further worsening the state of women in relation of holding
property. Since the Christians are in minority, their voices are seldom heard
by the government and the state of Christian women remains pitiable due to the
lack of government intervention and social awareness of the existing rights of
the Christian women.[28]
4. TESTAMENTARY SUCCESSION
In context of testamentary
succession, will is defined under Section 2(h) as ‘legal declaration of
intention of the testator with respect to his property which he desires to be
carried into effect after his death.’ Executor is the person who is appointed
by the testator to execute his will. [29]In
absence of an executor, a competent authority appoints an administrator to
administer the estate of the deceased.[30]
Codicil is an instrument made in relation to a will to alter, add or explain
any disposition mentioned in the will.[31]
Part VI of the Indian Succession Act
deals with the testamentary succession of property. It is one of the most
important parts of the legislation. Under testamentary succession, a person may
divide his property according to his wishes. The Supreme Court in Venkatachala v. Thimmajamma, the court
highlighted the importance of a will by stating that a will, unlike other
documents, becomes effective only on the death of the testator .[32]
Chapter II of the said part deals
with making of wills and codicils. Section 59 lays down the qualification for making
a will. ‘Every person of sound mind not being a minor may dispose of his
property by will.’[33]Thus,
the making of will is not just a physical act but also a mental act as it
involves a mentally sound mind capable of understanding the consequences of one’s
act. Therefore, a will affected under coercion, fraud or importunity is void.
Wills are divided into two categories
under Indian Succession Act i.e. privileged and unprivileged wills. Privileged
wills are those wills made by a soldier employed in warfare or a military
expedition. Unprivileged wills include all the wills other than privileged
ones.
Will can be securely sealed and
stored in possession. Upon the demise of the testator, either the executor of
the Will or an heir of the deceased testator may petition the court to
authenticate the will. The court will assume that the will is valid if there
are no challenges from the heirs. If a testator wishes to make specific
modifications to their Will without altering the entire document, they can
achieve this by creating a codicil to the Will. The codicil must be implemented
in a manner that is comparable to the execution of the Will. A Will or Codicil
can be modified or invalidated at any given moment. If any objections are
raised by any of the heirs, a citation must be served, summoning them to
provide their approval. This must be prominently exhibited in the court. If
there are no objections, the probate will be approved. Upon completing these
stages, a will is considered to be legally enforceable.[34]
The testator has the authority to
modify his Will at any given time, in manner he or she deems appropriate. Any
individual who is mentally competent and not underage has the ability to create
a will. If an individual lacks mental capacity at the moment of creating a
Will, the Will is deemed unenforceable. A Will that is acquired through force,
compulsion, or undue influence is considered null and void, as it deprives the
individual of their free will. A Will created while under the influence of
alcohol or in a state of body or mind that impairs the testator's ability to
make independent decisions is considered invalid.
An individual has the ability to
create a Will at any point during their lifetime. There are no limitations on
the frequency with which a testator can create a Will. Nevertheless, solely the
final Will executed prior to his demise is legally binding. The testator must
execute a Will by either signing it or affixing their thumb impression. The
Will must be corroborated by at least two witnesses, each of whom must have
witnessed the testator's signature.[35]
Assets that are obtained by oneself
can be transferred through a legal document called a Will. Assets obtained by
inheritance, gifts, or similar means, and held solely by an individual, can
also be included in a last will and testament. A member of a Hindu Undivided
Family (HUF) can transfer their part in the HUF's holdings through a Will. [36]
While making an unprivileged will,
one has to sign or affix it with the intention of giving effect to a will. It
also has to attested by two independent witnesses who have seen the testator
sign the will or received a personal acknowledgement from the testator
regarding the signature on the will.[37]A
soldier, while making a privileged will is exempted from going through such
formalities as it would be unreasonable to expect a soldier on national duty to
comply with such stipulations.
In case the will is challenged on the
grounds of vitiation by undue influence, fraud or coercion, then the burden
lies on the person who alleges such impeachment to substantiate his claims.
A legatee, who is beneficiary under
the will, can attest the will but the will would be void as far as his share
his concerned. [38]
Section 70 lays down the law
regarding the revocation of an unprivileged will. A will is deemed to be
revoked on marriage of its maker. It can also be revoked by making another will
or a codicil. Other ways of revoking it include burning, tearing, or otherwise
destroying the same by the testator or by some person in his presence and by
his direction with the intention of revoking the same.
The revocation, if any, has to be in
the same manner as the will was created. In absence of the animus revocandi i.e. the intention to revoke on the part of
testator, the revocation cannot be deemed to be fit by law. In such a case, the
original will take effect. When the will is burnt by mistake or torn by the
testator when he was in a state of delirium, revocation cannot be said to place
for the want to the intention to revoke i.e. animus revocandi.
Under the Indian Succession Act, a
will is not required to be registered or stamped. Its registration is optional
under the Indian Registration Act. In the case of Ishwar Narain Singh v. Kamala Devi,[39]
the Supreme Court categorically held that a will is void just because it has
not been registered. No adverse inference can be drawn against genuineness of a
will due to its non-registration. Hon’ble Justice S.R. Das in course of his
judgment laid down that there is nothing in law that warrants its registration.
CONCLUSION
The succession laws with respect to
the minorities, except Muslims, were not coherent and for the want of
consistency and uniformity, there was need to formulate succession law covering
Christians, Parsis and other religions. This led the British to formulate the
Indian Succession Act 1865. However, this enactment was supplemented by various
other legislations which propped out due to the codification waged by the
Britishers in the late 19th century. This required the legislature
to consolidate the existing laws to offer a concrete and holistic understanding
of the succession laws of the communities except Hindus and Muslims which
culminated in the formulation of the Indian Succession Act, 1925.
The Indian Succession Act, 1925
covers the devolution of property by testamentary and intestate succession.
Testamentary succession covers the property related matters when a valid will
is made by the testator making it clear who will get his property. Intestate
succession applies in cases where there is no will or an invalid will and
property devolves through the rules mentioned in the Indian Succession Act.
Despite consolidation of various
enactments through the Indian Succession Act in 1925, various territories are
still governed by special laws or the laws crystallized by the prevalent
customs and usages of that particular community. This defeats the purpose of
the consolidating legislation and leaves scope for inconsistency. This also
retains the patriarchal notions of the historical times when a woman’s
existence was considered to be a part of male after marriage. In lieu of this
understanding, the women were devoid of the property owing to the secondary stature
provided to them by the anachronistic mind set. This was exposed in the case of
Mary Roy, in which the court duly
interpreted the purpose of the Indian Succession Act as a consolidating act and
repealed the Cochin and Travancore.[40]
Even after the Mary Roy verdict, there are many Christian women who are deprived
of their property owing to various regional laws not congruous with the Indian
Succession Act. Due to the fact that these women form part of a minority
community, the government has turned a deaf ear towards their grievances.
There is also no scope for
illegitimate child under the Indian Succession Act which makes his position
under the succession law, very vulnerable.
Many provisions in the Indian
Succession Act, 1925 ranging from Section 42 to 48 are discriminatory to women
and do not honour the spirit of the Right to equality enshrined in the Indian
Constitution. 247th report by the Law Commission of India chaired by
Justice Ajit Shah brings out these very issues.[41]
Section 42 states that when there are no lineal descendants, the all the
property would devolve to the father irrespective of the fact whether mother is
alive. This is clearly differential to the mother who stands at an equal
pedestal to father.
The Law Commission in its earlier
report (110th) - “Indian Succession Act, 1925” reflecting on these provisions
have thus noted: “This is not in conformity with the current thinking as to
status of women. The law is in need of 12 reform on this point”.” With this
background in view the Commission believes that the need to reform is not only
timely but becomes more glaring when one looks around and finds that in many
other jurisdictions the law on the point is more sensitive and egalitarian.”[42]
Thus, there is a need to make the
Indian Succession Act, 1925 more comprehensive and up to date with the society
free of patriarchal notions.
BIBLIOGRAPHY
STATUTES
Indian Succession Act, 1865
Indian Succession Act, 1925
CASES
Hill
v. Administrator- General of Bengal ILR
23 Cal 506
Ishwar Narain
Singh v. Kamala Devi AIR 1954 SC 280
Ma Khin v
Ma Ahma ILR 12 Rang 184
Mary Roy
v. State of Kerala 1986 2 SCC 209
Sophia
Blin v. Maria David AIR 1919 UB 3
Venkatachala
v. Thimmajamma AIR 1959 SC 443
ARTICLES/ REPORTS/BOOKS
George O, ‘Inheritance law after Mary
Roy’ (Live Law 2014) < http://www.livelaw.in/inheritance-rights-christian-women-since-mary-roy/> accessed 11 March 2018
Law Commission of India, Section 41-48 of the Indian Succession Act,
1925 – Proposed Reforms (Law Commission of India, 247th report,
September 2014) < http://lawcommissionofindia.nic.in/reports/Report247.pdf>
accessed 16 April 2017
Row S, Indian Succession Act 1925 (7th edn, Butterworths 2000)
[1] Mary Roy v State of Kerala (1986)
2 SCC 209
[2] Indian Succession Act 1925,
Objects and Reasons
[3] Sanjiva Row, Indian Succession Act 1925 (7th edn, Butterworths 2000)
2
[5] Succession (n2) s5
[7] ibid
[8] [1863] 9 MIA 199
[9] Indian Succession Act 1925, s2(d)
[11] Sanjiva (n1)
[12] Succession (n6) s6
[13] Ibid s10
[14] Ibid s16
[15] Ibid s20
[17] ‘Christian Law of Succession’ <
https://www.lawteacher.net/free-law-essays/property-trusts/christian-law-of-succession.php> accessed 11 March 2018
[18] Succession (n6) s30
[19] Sanjiva (n1) 86
[20] Fooks v Cuffe (1908) 2 Ch 500
[21] Sophia Blin v Maria David AIR 1919 UB 3
[22] Succession (n6) s35
[24] Succession (n6) s42
[25] ibid s43
[26] Law Commission of India, Section 41-48 of the Indian Succession Act,
1925 – Proposed Reforms (Law Commission of India, 247th report,
September 2014) < http://lawcommissionofindia.nic.in/reports/Report247.pdf> accessed 16 April 2017
[27] Omana George, ‘Inheritance law
after Mary Roy’ (Live Law 2014) < http://www.livelaw.in/inheritance-rights-christian-women-since-mary-roy/> accessed 11 March 2018
[29] Succession (n6) s2(c)
[30] ibid s2(a)
[31] ibid s2(b)
[32] AIR 1959 SC 443
[34] ibid
[35] ibid
[37] ibid s63
[38] ibid s67
[40] Omana George, ‘Inheritance law
after Mary Roy’ (Live Law 2014) < http://www.livelaw.in/inheritance-rights-christian-women-since-mary-roy/> accessed 11 March 2018
[41] Law Commission of India, Section 41-48 of the Indian Succession Act,
1925 – Proposed Reforms (Law Commission of India, 247th report,
September 2014) < http://lawcommissionofindia.nic.in/reports/Report247.pdf> accessed 16 April 2017
Article Information
GENERAL PRINCIPLES OF SUCCESSION UNDER CHRISTIAN LAW
Authors: ALIND GUPTA
- Journal IJLRA
- ISSN 2582-6433
- Published 2024/01/01
- Issue 7
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