Author(s): Artish Jyoti, Ayushi Mani
Paper Details: Volume 4, Issue 4
Citation: IJLSSS 4(4) 26
Page No: 292 – 305
ABSTRACT
The Indian legal history of the development of the rights of Hindu women over property is a story of deep conflict between constitutional egalitarianism and the patriarchal structure of the Mitakshara joint family system that has endured. Although the Hindu Succession (Amendment) Act 2005 was celebrated as a decisive blow against gender-based exclusion by turning the daughters into coparceners by birth, the shift toward the de facto empowerment remains incomplete.
This paper examines the myth of equal inheritance by comparing statutory progress with the sociological reality of forceful relinquishment, the characterization of marriage costs as an inheritance alternative, and the continued agnatic bias in agnatic succession legislation by combining a principal survey.
More importantly, the empirical evidence shows that the youth is generally quite aware of the legal issues but practical implementation is usually compromised through a patriarchal mindset and the myth of the compensations, in which the cost of marriage is considered an adequate payment. This paper contends that substantive equality can only be achieved through legislative change, but a systematic change in social thinking to break the structural obstacles that still restrict the rights of women to property in India.
INTRODUCTION
The history of Hindu succession law is a study in the slow and often reluctant dismantling of patriarchal hegemony within the Indian legal system.[1] For over a millennium, the Hindu joint family property structure was governed by uncodified Shastric customs and commentaries, most notably the Mitakshara and Dayabhaga schools.[2] Under the Mitakshara School, which governs the majority of India, the coparcenary was traditionally defined as a subset of the Hindu Undivided Family (HUF) consisting only of those male members who acquired an interest in ancestral property by birth, historically restricted to four generations of male lineage.[3] The root cause of this systematic exclusion of women was the Brahmanical patriarchy that considered property inheritance as the sole preserve of men performing the spiritual pinda offerings and funeral rites to ancestors.[4] Women were regarded as family members but never as the owners of the ancestral estate, they got the Stridhan and a right to maintenance but not the property of immovable assets.[5]
With the passing of the Hindu Succession Act 1956, this was the first major effort by the independent state of India to integrate and codify these various practices in a national code.[6] Following the vision of the gender equality as portrayed by Dr. B.R. Ambedkar, the initial Hindu Code Bill was radical in nature but received strong opposition owing to the fear of the conservative political forces that the traditional family unit would be broken.[7] The 1956 Act was therefore a concession since, although daughters, widows, and mothers were brought under Class I heirs and the limited estate of women was changed into absolute property under Section 14, the male-oriented Mitakshara coparcenary was still maintained.[8] In this system, the daughters received only a portion of the personal interest of their father by a so-called notional partition, but the rest of the ancestral estate was still the preserve of male coparceners.[9]
The Hindu Succession (Amendment) Act 2005 was an attempt to complete this incomplete revolution by replacing Section 6 and stating that a daughter would become a coparcener by birth in her own right in the same manner as the son.[10] This statutory shift was intended to be the death knell for gender discrimination, ensuring that daughters enjoyed equal rights to demand partition and manage the family estate. But, as the survey made in this study shows, there is still an immense gap between the legal myth of equality and the sociological truth of the inheritance of women. Although the law has a strong defence mechanism, the reality of equality in distribution is far away in the field.
The myth assumes that women have become equal partners. This reality, as reflected in field data, is that social norms of haq tyag (sacrifice of right) and so-called covert coercion usually compel daughters to sign away their inheritance in order to preserve ties with their brothers.[11] Our survey reveals that the perception of equal property distribution is still a rare occurrence in the minds of our respondents with a high legal awareness among young population. Moreover, an important 74% of the surveyed individuals say that, marriage costs are often used as a replacement to inheritance, which confirms the theoretical model of compensating mechanisms where households replace land with liquid assets or dowry to maintain patrilineal concentration.[12]
This paper explores these endemic impediments through the contrast between institutionalized legal theory and the empirical data of the field. It discusses the most recent judicial developments of 2025, such as the seminal case of Vineeta Sharma that resolved the legal mess on retroactive rights and the current constitutional disputes with the gendered subordination of Section 15.[13] Through the lens of the doctrinal analysis, as well as the key findings of respondents, this paper presents the argument that substantive equality cannot be achieved solely through the judgment of the judge, but a systematic change in the social mentality to break down the structural and cultural barriers that still determine the reality behind the inheritance of Hindu women in India.
RESEARCH QUESTIONS
1. To what extent has the legal recognition of daughters as Class I heirs under Hindu succession law translated into actual equal distribution of property within families?
This question examines the level of awareness and implementation of inheritance rights, the social or cultural factors that discourage women from claiming their share, whether relinquishment of inheritance is truly voluntary, and whether legislative reform alone is sufficient to achieve gender-equal inheritance.
2. Is there a generational shift in attitudes toward daughters claiming their inheritance rights?
This question also explores whether higher education and financial independence influence women’s likelihood of asserting their inheritance rights.
LEGAL FRAMEWORK: THE EVOLUTION OF DAUGHTER’S RIGHTS IN HINDU LAW
Hindu inheritance laws have shifted the patriarchal exclusion system to that of formal gender parity. This section outlines the legislative and judicial milestones that define the rights of daughters today.
THE PRE-2005 REGIME: LIMITED SUCCESSION
Before the 2005 reforms, the Hindu Succession Act, 1956 (HSA), maintained the traditional Mitakshara coparcenary, which was a male-only preserve. Under the original Section 6, only male members (son, grandson, and great-grandson) were “coparceners” who acquired an interest in ancestral property by birth.[14]
While daughters were listed as Class I heirs in the Schedule to the 1956 Act, their rights were restricted to the father’s separate property or his notional share in ancestral property upon his death. They were not entitled to partition and were not in the central joint family property.[15] This form of law formalized the foreignness of daughters in their homes of origin.
THE 2005 AMENDMENT: BIRTHRIGHT EQUALITY
In accordance with the recommendations of the 174th Law Commission Report, which emphasized the constitutional requirement of gender equality, the Hindu Succession (Amendment) Act, 2005 to eliminate the discriminatory features of Section 6 was passed.[16]
The amended Section 6(1) states that the daughter of a coparcener shall by birth become a coparcener in her own right in the same manner as the son.[17]
Section 6(3) substituted the rule of survivorship with a rule of testamentary or intestate succession so that the share of a daughter is to be calculated even in a joint family.
RESOLVING THE RETROSPECTIVE CONFLICT: VINEETA SHARMA
In the period of more than ten years, there was a legal see-saw on whether or not a daughter had to have her father alive in 2005 to enjoy the rights. This ambiguity usually deterred women to make claims.
In Prakash v. Phulavati, the Court held that the amendment only applied to living daughters of living coparceners as of September 9, 2005.[18]
This was later challenged in Danamma v. Amar, which suggested the right was inherent by birth, regardless of the father’s passing.[19]
It was eventually resolved by a three-judge bench in the historic case of Vineeta Sharma v. Rakesh Sharma. The Court ruled that since the right is given by birth, it is immaterial whether the father was alive on the date of the amendment. The Court famously declared, “A daughter remains a loving daughter throughout life”.[20]
LEGAL LOOPHOLES: WILLS AND RELINQUISHMENT
Despite the Vineeta Sharma victory, two legal mechanisms often prevent actual equal distribution.
Testamentary Succession: Under Section 30 of the HSA, 1956, any Hindu can dispose of their property by a Will. In practice, this testamentary freedom is frequently used to bequeath property solely to sons, effectively disinheriting daughters through a legal back door.[21]
Relinquishment Deeds: Families often utilize Release Deeds or Haq-Tyag. While the law requires these to be voluntary, they are often signed under social pressure or the guise of family harmony.
SOCIO-LEGAL IMPLEMENTATION GAP
The 2005 Amendment and subsequent rulings have achieved de jure equality. However, as the research questions suggest, de facto equality remains elusive. While the Supreme Court has raised the burden of proof for oral partitions to prevent daughters from being cheated, the lack of awareness remains a primary hurdle.[22]
CRITICAL ANALYSIS: THE LIVED REALITY OF HINDU SUCCESSION LAW
The transition of the Hindu daughter from a dependent heir to a birthright coparcener represents one of the most significant shifts in Indian personal law. However, the efficacy of any law is measured not by its presence in the statute books, but by its implementation in the domestic sphere. This analysis evaluates the disconnect between de jure and de facto inheritance rights based on primary survey data.
1. THE IMPLEMENTATION GAP: AWARENESS VS. PRACTICE
The former research question explores how far the legal recognition has been translated into reality of equal distribution. According to the survey, there is a sharp implementation gap indicating that the legislative change has led the way over social acceptance.
1.1 THE ILLUSION OF LEGAL LITERACY
The survey results reveal that the level of formal legal awareness is rather high. About 63 percent of the respondents rightly indicated that daughters had a legal right of equal share with the sons in inheritance of the ancestral property. Moreover, 56 percent of the respondents said that they were familiar with these rights to some extent or very familiar. This is an indication that the legal education campaign conducted after the judgment in the case of Vineeta Sharma v Rakesh Sharma has been received by most of the target population.[23]
But being aware is not being assertive. Only 10.9% of the respondents described equal distribution as very common when posed about the ground reality in families around them. However, the biggest plurality (43.8) said that property is still partitioned between sons, most of the time, whereas 39.7% said property was partitioned equally, which they said was rare. This contradiction underscores that even though the people are aware of the law, the practice is still under the pre-2005 patriarchal ways in which the son is considered to be the only heir of the family property.[24]
1.2 THE CUSTOMARY STRANGLEHOLD
The ongoing existence of such patriarchal norms is also explained by the motives behind the exclusion of daughters. Another important reason daughters do not receive property as given by a considerable 49.3 percent of the respondents was because of tradition or customary practice. This suggests that the Mitakshara tradition which for centuries viewed daughters as transient members of their natal family continues to override the statutory mandate of the Hindu Succession (Amendment) Act 2005.[25] The law treats the daughter as a loving daughter throughout life, but the survey shows that custom still treats her as Paraya Dhan (someone else’s wealth).
2. THE MECHANICS OF EXCLUSION: MARRIAGE AND RELINQUISHMENT
A critical component of the first research question is investigating the social factors that discourage women from claiming their share.
2.1 MARRIAGE EXPENSES AS A DE FACTO SETTLEMENT
One of the most profound findings of the survey is the role of marriage expenses. Approximately 80.8% of respondents agreed that marriage expenses are treated as a substitute for inheritance. Legally, the provision of dowry or the funding of a wedding does not extinguish a daughter’s coparcenary birthright. But socially, these costs are put in terms of exhaustive and complete satisfaction of her claim.
This poses an ethical obstacle that a daughter who claims her portion of the family inheritance following an extravagant wedding is commonly called greedy, which practically attacks the family spending on its wedding on the basis of her legal rights. The survey proves that such social accounting is one of the main tools which helps to preserve male-dominated lines of property in spite of the elimination of gender-related exclusions.[26]
2.2 THE MYTH OF THE VOLUNTARY RELINQUISHMENT
The research question specifically asks whether the relinquishment of inheritance is truly voluntary. The survey results offer a resounding rebuttal to the idea of free consent. Only 6.9% of participants believe that decisions to relinquish inheritance are completely voluntary.
The majority (44.4%) view these decisions as being influenced by family expectations and 15.3% attribute them to strong social pressure. This indicates that the legal instrument of the Release Deed or Relinquishment Deed is often signed under duress, not necessarily physical but emotional and social. Women are forced to choose between their economic rights and their relationship with their brothers. This emotional blackmail ensures that the property remains with the sons, while the daughter is given a choice that is no choice at all, a phenomenon well-documented in socio-legal literature regarding land rights.
3. GENERATIONAL SHIFTS AND THE CATALYST OF CHANGE
The second research question examines whether there is a generational shift and if education or financial independence alters these dynamics.
3.1 THE EMERGING GENERATIONAL DIVIDE
There is a clear trend toward modernization in attitudes. A staggering 89% of respondents believe that younger generations are more inclined toward equal inheritance than older ones. This generational shift is likely due to the normalization of gender equality in public discourse and the gradual decline of the joint family system. Younger respondents are less likely to view the daughter as an outsider, indicating that the legal seed planted in 2005 is slowly bearing fruit in the minds of the next generation of property owners.
3.2 THE ROLE OF EDUCATION AND ECONOMIC EMPOWERMENT
The evidence is very much in favour of the hypothesis that education enables women to demand their rights since 87.6% of the people interviewed are of the opinion that women are more likely to demand what is rightfully theirs with higher education. Education probably gives the language of rights to question the traditional norms.[27]
The effect of financial independence is more subtle. Although it is possible to think that a working woman should be more assertive, 57.5% of the respondents mentioned that she would be more likely to take inheritance based on family circumstances. Only 26% gave a categorical Yes. This implies that despite the fact that women who are financially independent are not afraid to join the workforce, the fear of family breakdown (mentioned by 20.8% as the greatest obstacle) can still be seen as a major deterrent. A woman can be financially independent, and may still be afraid of the loss of the social safety net or the emotional support of her birth home, but will choose family harmony over her legal entitlement.
4. SYNTHESIZING LEGISLATIVE SUFFICIENCY AND SOCIAL MINDSETS
The analysis will end with a discussion of whether legislative change is necessarily adequate to change entrenched social systems. Responses to the question of whether the law has guaranteed equal inheritance were skeptical with 34.7% giving the answer to be partially and 31.9% giving the answer to be no. This cynicism is founded on the basis of the so-called Patriarchal Mindset that 45.8% of respondents have cited as the highest obstacle that can be overcome only by enacting laws.
Although the HSA 1956, Section 30, gives fathers the right to disinherit daughters by using wills, it is the desire to do so, which is the root of the problem.[28] The most interesting number is that 69.4% of the respondents consider the most significant factor in attaining equality to be a change in social mindset, by far, much more than the 12.5 and 11.1 percent who thought it was a stronger enforcement of the law or greater awareness of the law.
Finally, the study unveils a changing society in which social architecture is still more inflexible than legal architecture. We have moved from a legal system that explicitly excluded daughters to one that explicitly includes them, yet actual equal distribution is hindered by a trio of factors: the cultural perception of marriage expenses as inheritance, the social pressure to sign voluntary relinquishment deeds, and the persistent view of sons as the primary heirs.[29] The findings suggest that the 2005 Amendment is currently a sleeping right as it exists on paper, but for a majority of Hindu women, asserting it still carries a social cost that many are not yet willing to pay. True equality will only be achieved when the loving daughter is no longer expected to prove her love through the sacrifice of her legal birthright.
JUDICIAL DEVELOPMENTS: FROM AMBIGUITY TO THE RESTORATION OF BIRTHRIGHT EQUALITY
The history of Hindu succession law is far more a history of judicial interpretation as much as it is a history of legislative reform. As much as the statutory framework of equality in the 2005 Amendment was a skeleton, it was left to the judiciary to put life into it and it had to navigate through the years of ambiguity in relation to application of these rights retrospectively.
THE EARLY PHASE OF AMBIGUITY
The primary judicial challenge following the 2005 Amendment was determining whether the new rights applied to daughters born before 2005 or to families where the father had passed away prior to the amendment. Initially, the judiciary adopted a restrictive approach. In Prakash v Phulavati, the Supreme Court held that the rights conferred by the 2005 Amendment were prospective.[30] The Court ruled that for a daughter to claim coparcenary rights, both the father and the daughter had to be alive on the date the amendment came into force that is September 9, 2005. This reading left out thousands of women whose father had died just before the reform, essentially preserving the patriarchal status quo of a whole generation.
THE SHIFT TOWARD INHERENT RIGHTS
This narrow perspective was not long held with the judiciary starting to put the emphasis on the birthright of coparcenary. The Supreme Court appeared to be more liberal in Danamma @ Suman Surpur v Amar.[31] The Court decided that the right of the daughter was founded on her birth and partition suit was pending till a final decree was made. Thus, even a suit, which was filed prior to 2005, could be claimed by the daughter due to the fact that the law had changed before the ultimate distribution of property. This created a head-on collision with the Phulavati precedent, creating much legal confusion to litigants and the lower courts.
THE DEFINITIVE SETTLEMENT: VINEETA SHARMA
A three-judge bench in a landmark case of Vineeta Sharma v Rakesh Sharma finally brought the judicial see-saw to its rest.[32] The Court replaced the potential restriction by stating that the right of a daughter in coparcenary property is undivided.
The Court clarified three critical points:
- By Birth, Not by Death: The right is acquired by birth therefore, it does not matter whether the father was alive in 2005.
- Retroactive Application: The law is retroactive in nature, as it operates on a condition (birth) that happened in the past.
- Protection Against Fraud: To prevent families from using oral partitions to disinherit daughters, the Court ruled that only a partition through a registered deed or a court decree would be recognized as a valid defence against a daughter’s claim.
THE WAY FORWARD: RECONCILING STATUTORY MANDATES WITH SOCIAL REALITY
STATUTORY REFORMS: ADDRESSING TESTAMENTARY DISINHERITANCE
The largest legal loophole that was found during the research is the absolute authority of testamentary succession in Section 30 of Hindu Succession Act 1956.[33] In order to avoid systemic disinheriting daughters by using wills, the legislature ought to look at introducing a Forced Heirship, as is common in civil law jurisdictions or the Muslim Personal Law. The law can also be used to guarantee that a certain percentage of the estate must be left to the daughters to prevent the use of the wills to support patrilineal lines of property.
PROCEDURAL SAFEGUARDS FOR RELINQUISHMENT
The fact that 44.4% of relinquishments, according to the survey, are conditioned by the family expectations, and 15.3% are conditioned by the social pressure implies that the practice of signing Release Deeds should be controlled more strictly. It is suggested that:
- Mandatory Counselling: Before a relinquishment deed is registered, the woman should undergo an independent session with a legal aid authority to ensure her consent is not vitiated by emotional duress.
- Judicial Audit: Courts should treat oral partitions and relinquishments with a high degree of suspicion, as emphasized in Vineeta Sharma, requiring the presence of the female heir before a Registrar to confirm her voluntary intent.[34]
DECOUPLE MARRIAGE COSTS AND INHERITANCE
The public awareness campaigns should be focused on the difference between the gifts and the shares to counter the social accounting of 80.8% of the respondents perceiving the marriage costs as an inheritance alternative. State governments might have compulsory literacy about property during marriage registrations with an express declaration that coparcenary property wedding spending do not extinguish a daughter by the right of birth.
COMMUNITY-BASED LEGAL AWARENESS
Because of the fact that 69.4% of the survey participants mentioned change in social mindset to be the most important condition to equality, it is necessary to change the focus not on the legislation but on the mobilization of the community. With the help of the so-called generational shift revealed in the statistics naming 89% of the younger generation as more supportive, legal aid clinics must focus on the younger members of the family to become agents of change in their family. The empowerment should leave the courtroom and enter the family whereby it should change the loving daughter into an equal before law.
CONCLUSION
The process of the stifling clauses of the initial Hindu Succession Act 1956 which were substituted by the absolute requirement of equality in Vineeta Sharma v Rakesh Sharma is a deep legislative and judicial triumph. This study however reveals that the myth of equal inheritance is one that usually continues to exist even in the face of the law. The legal system has managed to shift to the regime of birthright equality, but the socio-cultural system of the Hindu family is an insurmountable obstacle to it.[35]
The main data shows that there is a serious gap in implementation as the awareness of rights increases, the distribution in reality is biased towards male heirs. The long-standing approach to marriage costs as an inheritance alternative and the indirect pressure of the so-called voluntary surrender actions still keeps women alienated to their coparcenary interests.
Finally, this paper finds that although legislative reform and judicial activism are the necessary pillars, they cannot stand on their own. The generational change described in the survey is a ray of hope as it is believed that as the education level and financial autonomy increases, the attitude of patriarchy will eventually diminish as the largest challenge to equality.[36] True gender parity will only be realized when the legal birthright of a daughter is no longer treated as a social concession, but as a fundamental and non-negotiable reality of Indian family life.
BIBLIOGRAPHY
PRIMARY SOURCES
STATUTES
- Hindu Succession Act 1956.
- Hindu Succession (Amendment) Act 2005.
CASES
- Danamma @ Suman Surpur v Amar (2018) 3 SCC 343.
- Prakash v Phulavati (2016) 2 SCC 36.
- Vineeta Sharma v Rakesh Sharma (2020) 9 SCC 1.
SECONDARY SOURCES
BOOKS
- Agnes F, Law and Gender Inequality: The Politics of Women’s Rights in India (Oxford University Press 1999).
- Agarwal B, A Field of One’s Own: Gender and Land Rights in South Asia (Cambridge University Press 1994).
- Desai SA, Mulla: Principles of Hindu Law (21st edn, LexisNexis 2010).
- Mulla SDF, Mulla’s Principles of Hindu Law (25th edn, LexisNexis 2024).
- Parashar A, Women and Family Law Reform in India (Sage 1992).
- Chaudhary SK, Sociology of Law: A Study of Hindu Succession Act (Rawat Publications 2015).
JOURNAL ARTICLES
- Dubey RD, ‘Gender Justice and the Hindu Succession Act: A Critical Analysis’ (2025) IJCRT.
- Mittika IJ, ‘Inherited Inequality: The Limited Rights of Hindu Women over Property’ (2025) International Journal of Research and Innovation in Social Science 2654.
- Roy S, ‘Empowering women? Inheritance rights and female education in India’ (2015) 114 Journal of Development Economics 233.
- Thulaseedharan S, ‘Personal Law and Property Rights of Hindu Woman in India: The Need for Codification’ (2018) 6(1) Kathmandu School of Law Review 143.
REPORTS AND OTHER SOURCES
- Garg L, ‘Joint Family and Coparcenary Under Hindu Succession Act, 1956: A Comparative Analysis’ (Scribd 2024).
- Law Commission of India, Property Rights of Women: Proposed Reforms under the Hindu Law (Law Com No 174, 2000).
[1] Ritesh Dhar Dubey, ‘Gender Justice and the Hindu Succession Act: A Critical Analysis’ (2025) IJCRT <https://ijcrt.org/viewfull.php?&p_id=IJCRT25A3068> accessed 15 February 2026.
[2] Sir Dinshaw Fardunji Mulla, Mulla’s Principles of Hindu Law (25th edn, LexisNexis 2024).
[3] Lagan Garg, ‘Joint Family and Coparcenary Under Hindu Succession Act, 1956: A Comparative Analysis’ (2024) Scribd <https://www.scribd.com/document/854200919/Joint-Family-and-Coparcenary-Under-Hindu-Succession-Act-1956-a-Comparative-Analysis> accessed 3 March 2026.
[4] Flavia Agnes, Law and Gender Inequality: The Politics of Women’s Rights in India (Oxford University Press 1999).
[5] Ishrat Jahan Mittika, ‘Inherited Inequality: The Limited Rights of Hindu Women over Property – A Comparative Analysis’ (2025) International Journal of Research and Innovation in Social Science 2654 <https://rsisinternational.org/journals/ijriss/articles/inherited-inequality-the-limited-rights-of-hindu-women-over-property-a-comparative-analysis/> accessed 15 February 2026.
[6] The Hindu Succession Act 1956.
[7] Archana Parashar, Women and Family Law Reform in India (Sage 1992) 80.
[8] ibid.
[9] S Thulaseedharan, ‘Personal Law and Property Rights of Hindu Woman in India: The Need for Codification’ (2018) 6(1) Kathmandu School of Law Review 143 <Personal Law and Property Rights of Hindu Woman in India – The Need for Codifi cation | Kathmandu School of Law Review> accessed 3 April 2026.
[10] The Hindu Succession (Amendment) Act 2005, s 3.
[11] Bina Agarwal, A Field of One’s Own: Gender and Land Rights in South Asia (Cambridge University Press 1994).
[12] Sanchari Roy, ‘Empowering women? Inheritance rights and female education in India’ (2015) 114 Journal of Development Economics 233 <https://www.sciencedirect.com/science/article/pii/S0304387815000024> accessed 27 March 2026.
[13] Vineeta Sharma v Rakesh Sharma (2020) 9 SCC 1.
[14] Hindu Succession Act, 1956, s 6.
[15] Satyajeet A Desai, Mulla, Principles of Hindu Law (21st edn, LexisNexis 2010).
[16] Law Commission of India, Property Rights of Women: Proposed Reforms under the Hindu Law (Law Com No 174, 2000) <Succession | Law Commission of India | India> accessed 2 April 2026 .
[17] Hindu Succession (Amendment) Act (n 10).
[18] Prakash v Phulavati (2016) 2 SCC 36.
[19] Danamma @ Suman Surpur v Amar (2018) 3 SCC 343.
[20] Vineeta Sharma v Rakesh Sharma (n 13).
[21] Hindu Succession Act 1956, s 30.
[22] SK Chaudhary, Sociology of Law: A Study of Hindu Succession Act (Rawat Publications 2015).
[23] Vineeta Sharma v Rakesh Sharma (n 13).
[24] Hindu Succession Act 1956 (n 14).
[25] Hindu Succession (Amendment) Act 2005 (n 10).
[26] Law Commission of India, Property Rights of Women (n 16).
[27] SK Chaudhary (n 22).
[28] Hindu Succession Act 1956 (n 21).
[29] Desai (n 15).
[30] Prakash v Phulavati (n 18).
[31] Danamma @ Suman Surpur v Amar (n 19).
[32] Vineeta Sharma v Rakesh Sharma (n 13).
[33] Hindu Succession Act 1956 (n 21).
[34] Vineeta Sharma v Rakesh Sharma (n 13).
[35] Hindu Succession (Amendment) Act (n 10).
[36] SK Chaudhary (n 22).