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TABLE OF CASES

1. Mohammad Ahmed Khan v. Shah Bano Begum

2. Sarla Mudgal (Smt.), President, Kalyani and others v. Union of India and Others
3. Lily Thomas etc. v. Union of India and others
4. Swapana Ghosh v. Sadananda Ghosh
5. Ammini E.J. v. Union of India
6. Pragati Verghese v. Cyrill George Verghese
7. Naveen Kohli v. Neelu Kohli
8. Ramesh Jangid v. Sunita
9. Prabhakar v. Shanti Bai
10. Sarla Mudgal Vs. Union of India
11. Lily Thomas v.Union of India

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CHAPTER: - 1

ABSTRACT

Part IV of the Indian Constitution provides for Directive Principles of State Policy. Though
these principles are guidelines and are not enforceable in a court of law however they are
indispensable in the governance of the country. One such directive principle is given under
Article 44 of the Constitution which creates an obligation on the state to enact a Uniform
Civil Code. Various directions have been issued by the Apex Court for its implementation
however, due to excessive politicization in our country it is still a distant dream. In the
absence of a uniform law regarding personal matters like marriage, divorce, adoption etc.,
various personal laws are applicable to different religious communities who reside in our
country. These laws find their source and authority in their religious texts and customs which
provides for gender discriminatory practices in all forms and often is biased towards males
than that of females. This paper aims at achieving a balance between Right to Freedom of
Religion and Right to Equality by segregating the ‘essential religious practices’ and ‘secular
activities’. Thus one can say that the need of the hour is to enact a Uniform Civil Code but
that needs to be done slowly and gradually after making the people especially the minorities,
aware about its scope and extent as well as their rights

INTRODUCTION

Uniform civil code traces its origin from the concept of a civil law code. It envisages
administering the same set of secular civil laws to govern different people belonging to
different religions and regions. This supersedes the right of citizens to subject themselves to
different personal laws based on their religion or ethnicity.[ii] The common areas that stand
covered by a civil code include personal status, rights related to acquisition and
administration of property and marriage, divorce and adoption.

India being a diverse land with large religious and social diversities, it is highly essential to
have a Uniform Civil Code at the earliest to bridge the gap created by various personal laws
which have crept in through the years. Such a uniform law is necessary to not only promote
legal uniformity but also it would do justice to the diversities that are present in our country
by bridging the unintentional discrimination that the personal law brings forth among the
citizens.

The constitution has a provision for Uniform Civil Code under Article 44 as a Directive
Principle of State Policy which states that “The State shall endeavour to secure for the
citizens a uniform civil code throughout the territory of India.”[iii] Since it has been a part of

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Directive Principles which is nothing but unenforceable guidelines hence it still has not been
implemented and such cases of paper protection is not an adequate ground to move the Court
of Law.

The Uniform Civil Code is not included in Fundamental Rights, but in post modern India,
quick footed thinking of this kind has now resulted in well considered production of a mirror
image of the desired object of the uniform civil code in the form of harmonised personal law
system. The demand for a uniform civil code essentially means unifying all these personal
laws to have one set of secular laws dealing with these aspects that will apply to all citizens
of India irrespective of the community to which they belong. Though the exact basis on
which such a uniform code is to be framed have not been spelt out, it should presumably
incorporate the most modern and progressive aspects of all existing personal laws while
discarding those which are retrograde. [iv] The main cause of controversy pertaining to the
Uniform Civil Code has been secularism and the freedom of religion enumerated in the
Constitution of India. The preamble of the Constitution states that India is a Secular
Democratic Republic and thereby it means that the State does not endorse any specific
religion. A secular State is one which shall not discriminate against anyone on the ground of
religion. It means that religion should not interfere with the life of an individual. The Indian
Constitution contains articles mandating equality and non discrimination on the grounds of
sex (Articles 14-18). However, several laws exist that apparently violate these principles and
continue to be there especially in personal laws of certain communities which contain
provisions that are deemed to be highly discriminatory against women.

The Indian Constitution expressly stands for gender equality. However, even after half a
century from the framing of the Constitution, the ideal of Uniform Civil Code is yet to be
achieved. Women, who make up nearly a half of India, continue to demand for a gender just
code to enjoy equality and justice irrespective of the community to which they belong. The
Uniform Civil Code is thus required not only to ensure (a) uniformity of laws between
communities, but also (b) uniformity of laws within communities ensuring equalities between
the rights of men and women.[v]

It is neither time-bound nor carries a compulsive urgency. But the Hindu fundamentalists
make it a militant demand that the Hindu law should be made the national family law. There
is apprehension in the mind of the Muslim minority that the Quran’ is in danger, that its
sacred family law will be ineffective if the former is brought into force. The Supreme Court
has often expressed displeasure at the delay in framing a uniform civil code, which was
regarded as a secular imperative. Raging controversy demanding the uniform code followed
and was resisted in full fury by the Muslim minority, with distinguished exceptions whenever
an attempt had been made at enacting of such a code.

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Attempts have been made from time to time for enacting a Uniform Civil Code after
independence and the Supreme Court in various cases has been giving directions to the
government for implementing Article 44 of the Constitution and to reform the personal laws
specially those relating to the minorities and to remove gender bias as well as laws that
disfavour women therein. While a uniform civil code is not particularly high on the national
agenda, value-based progressive changes, preserving the separate identity of each religious
group, is a feasible project avoiding insult and injury to any minority. This may be a
preliminary step to pave the way for a common code. Mobilization of Muslim, Christian and
Parsi opinion in this direction is sure to yield results and reduce fundamentalist resistance
across the country. Maybe, to facilitate a national debate, a facultative common code may be
drawn up at a non-governmental level and that it will be purely optional for minorities to
accept or reject those provisions.

Initially the idea of Uniform Civil Code was raised in the Constituent Assembly in 1947 and
it was incorporated as one of the directive principles of the State policy by the sub-committee
on Fundamental Rights and clause 39 of the draft directive principles of the state policy
provided that the State shall endeavour to secure for the citizen a Uniform Civil Code. The
arguments put forward was that different personal laws of communities based on religion,
crippled India in its progress and it was suggested that a Uniform Civil Code should be in
place at the soonest possible juncture to promote the development of the newly independent
nation. Since the Uniform Civil Code was a politically sensitive issue, the founding fathers of
the Constitution arrived at a compromise by placing it under Article 44 as a directive
principle of state policy.

Research Methodology

The researcher has used doctrinal method and relied only upon secondary sources of data to
prepare this project.

OBJECTIVE

 The objective to accomplish this project is:-

 To know the working frame work of UCC.
 To understand the acceptability of the law in homogenous society.

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HYPOTHESIS

 A common law which will cover the entire nation under one shade.
 Can be chaotic in nature, because some people may not tolerate the tempering of their
personal laws.

SYNOPSIS

This project is divided into three Chapters. The first chapters contains the introduction to the
research topic, second chapter of this research topic deals with the judicial approach for UCC
and the third chapter deals with the conclusion of this research topic.

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CHAPTER 2

UNDERSTANDING THE JUDICIAL APPROACH

JUDICIAL APPROACH THROUGH THE YEARS

The Judiciary through its various judgements time and again has always upheld gender
justice in cases pertaining to the Uniform Civil Code.

In the case of Mohammad Ahmed Khan v. Shah Bano Begum (1985) 2 SCC 556 popularly
known as Shah Bano case, the Supreme Court held that “It is also a matter of regret that
Article 44 of our Constitution has remained a dead letter.” Though this decision was highly
criticized by the Muslim Fundamentalists, yet it was considered as a liberal interpretation of
law as required by gender justice. Later on, under pressure from Muslim Fundamentalists, the
central Government passed the Muslim Women’s (Protection of rights on Divorce) Act 1986,
which denied right of maintenance to Muslim women under section 125 Cr.P.C. The activist
rightly denounced that it “was doubtless a retrograde step. That also showed how women’s
rights have a low priority even for the secular state of India. Autonomy of a religious
establishment was thus made to prevail over women’s rights.”

In Sarla Mudgal (Smt.), President, Kalyani and others v. Union of India and Others AIR 1995
SC 1531 the Apex Court while delivering the judgment directed the Government to
implement the directive of Article 44 and to file affidavit indicating the steps taken in the
matter and held that, “Successive governments have been wholly remiss in their duty of
implementing the Constitutional mandate under Article 44, Therefore the Supreme Court
requested the Government of India, through the Prime Minister of the country to have a fresh
look at Article 44 of the Constitution of India and endeavour to secure for its citizens a
uniform civil code throughout the territory of India.”

However, in Ahmadabad Women’s Action Group (AWAG) v. Union of India, AIR 1997 SC
3614 a PIL was filed challenging gender discriminatory provisions in Hindu, Muslim and
Christian statutory and non-statutory law. In this case the Supreme Court became a bit
reserved and held that the matter of removal of gender discrimination in personal laws
involves issues of State polices with which the court will not ordinarily have any concern.
The decision was criticized that the apex court had virtually abdicated its role as a sentinel in

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protecting the principles of equality regarding gender related issues of personal laws of
various communities in India.[vi]

The Apex Court pursued the same line in Lily Thomas etc. v. Union of India and others AIR
2000 SC 1650 and held that the desirability of Uniform Civil Code can hardly be doubted.
But it can concretize only when social climate is properly built up by the society, statesmen
amongst leaders who instead of gaining personal mileage rise above and awaken the masses
to accept the change for the betterment of the nation at large.

The situation regarding the personal laws for Christians in India was different. In their case,
the courts seemed to be bolder and took a progressive stand in terms of gender equality. For
instance when the case of Swapana Ghosh v. Sadananda Ghosh AIR 1989 Cal. 1 the Calcutta
High Court expressed the view that sections 10 and 17 of the Indian Divorce Act, 1869,
should be declared unconstitutional but nothing happened till 1995. Again in yet another
case, the Kerela High Court in Ammini E.J. v. Union of India AIR 1995 Ker.252 and
Bombay High Court in Pragati Verghese v. Cyrill George Verghese AIR 1997 Bom. 349
have categorically struck down the section 10 of Indian Divorce Act, 1869 as being violative
of gender equality.

In September 2001, a poor Muslim woman, Julekhabhai, sought changes in the divorce
provisions in Muslim law as well as that of polygamy. The Supreme Court asked her to
approach the Parliament, who refused to entertain the petition. Julekhabhai had sought
equality with Muslim men, requesting court to declare that “dissolution of marriage under
Muslim Marriage Act, 1939, can be invoked equally by either spouse”. It also requested the
court to strike down provisions relating to “talaq, ila, zihar, lian, khula etc”, which allowed
extra-judicial divorce in Muslim personal law.[vii]

Mohammed Abdul Rahim Quraishi, the then Secretary of All India Muslim Personal Law
Board said that it needs to be seen that the subjects pertaining to that of marriage and divorce,
infants and minors, wills, intestacy and succession, partition etc, are enumerated in the
concurrent list of 7th Schedule of the Constitution and these being concurrent subjects both
the central and state governments have the power to make laws. As a result, we find many
regional variations affected by the state legislatures in the Hindu Laws. Bigamy is punishable
by law in all communities under the I.P.C except the Muslims, who are governed by the
Sharia law. The Muslim Personal Law (Shariat) Application Act 1937 was passed by the
British government to ensure that the Muslims were insulated from common law and that
only their personal law would be applicable to them. Bigamous marriages are illegal among
Christians (Act XV of 1872), Parsis (Act II of 1936) and Hindus, Buddhists, Sikhs and Jains
(Act XXV of 1955). Enactment of a Uniform Civil Code would abolish the Muslim rights to

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polygamy. In almost all recent cases where the need for a Uniform Civil Code has been
emphasised women were always found to be at the receiving end of torture in the garb of
religious immunity ultimately causing them to suffer irreparable loss and injuries at all cases.
Apart from the famous Shah Bano (1986) and Sarla Mudgal (1995) cases, there has been
numerous other pleas by Hindu wives whose husbands converted to Islam only in order to get
married again without divorcing the first wife. To conserve the cohesion of Hindu society, the
Hindu laws made allowances for customs and usages. The imposition of uniformity would
have undermined Hindu social cohesion. If matters relating to family laws and customs fall
under the jurisdiction of Parliament and state legislatures, the country will have a variety of
regulations thus leading to unnecessary and undue advantage to some while depriving many
other people who will be left to their fate to suffer. The State amendments have made many
in-roads in the Hindu laws damaging the uniformity of these laws, affecting many substantive
rules as well.

In a Uniform Civil Code which is the cherished constitutional goal, if we have a single
ground of divorce viz. that the marriage has broken down irretrievably, the scope of any
controversy is ruled out.[viii] Where factually marriage has broken down irretrievably, no
useful purpose will be served in finding out the guilt or innocence of the parties and in such
cases law proceeds to cut off the tie.[ix]

Analytical discussion on these issues shows that there should be one single ground of
divorce, viz. irretrievable breakdown of marriage.[x]

Irretrievable breakdown of marriage and divorce by mutual consent should be made

uniformly a ground to dissolve the marriage of spouses irrespective of their religious faiths.
The critical analysis of different existing grounds of divorce contained under various divorce
laws shows more uniformity and less contrast in them. Therefore, the conceptual analysis of
the different existing ground of divorce paves the way to push up the matter of uniformity in
them legislatively.

In Naveen Kohli v. Neelu Kohli 2006 (4) SCC 558 the Supreme Court, boldly laid down that
while permitting dissolution of thirty year old mismatch, urged the Government of India to
amend Hindu Marriage Act in order to make Irretrievable break down of marriage a valid
ground for divorce. The court held that irretrievable break down of marriage was prevalent as
a ground for divorce in many other countries and recommended the Union of India to
seriously consider bringing an amendment in Hindu Marriage Act, 1955 to incorporate
irretrievable break down of marriage as a ground for the grant of divorce. The court ordered
to send a copy of the judgment to the Secretary, Ministry of law and justice, Department of

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legal affairs, Government of India for taking appropriate steps and to accommodate such
demands that arose before the Court in the instant case.

The express introduction of the principle of irretrievable break which has been in place
already in England will be much more conducive and functional than merely relying on the
implied principle. Besides, the administration of justice on the basis of clearly codified law is
superior to the adjudication from case to case. For this, Parliament could reintroduce the
Marriage Laws (Amendment) Bill, 1981 (No.23 of 1981), which earlier did not fructify into
law for expressly introducing irretrievable break down of marriage as the singular ground for
divorce, as the bill was allowed to lapse.[xi]

Recently in Ramesh Jangid v. Sunita 2008 (1) HLR 8 (Raj.), the wife wanted her husband to
leave his parents and live separately. The Court held that the demand of the wife was
unreasonable and as wife was living separately for 13 years and denying physical
relationship, so divorce was granted on the aforesaid grounds. The court observed that the
differences that have grown up between the parties, the distance which has widened for over
a decade cannot be brushed aside lightly. Thus irreparable break down of marriage is obvious
so a divorce in such a case is the only way available to the parties as well as for the court.

In Prabhakar v. Shanti Bai 2008 HLR 250 (Nagpur), parties were married in 1955 however
they have not stayed together since 1958, and no cohabitation was there since last 49 years.
The court granted the decree of Divorce as the marriage between the parties was irretrievably
broken and it was no use to continue with such a marriage any longer.

The Law Commission of India and the Supreme Court have recommended that the
irretrievable break down of marriage should be made a separate ground of divorce by the
legislature. No useful purpose would be served by keeping alive de jure what is dead de facto.
It is possible that if Parliament does not act on this recommendation the legislature of some
states of India may take the lead, exercising power under entry 5 of the concurrent list of the
7th schedule.[xii]

The Law Commission has suggested that immediate action needs to be taken to introduce an
amendment in the Hindu Marriage Act, 1955 and the Special Marriage Act, 1954 for
inclusion of irretrievable breakdown of marriage as another ground for grant of divorce.[xiii]

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For long Christian women too had the law loaded against them. A Christian man could obtain
a divorce on the basis of adultery; a woman had to establish an additional charge like
desertion or cruelty under the Indian Divorce Act 1869 as well. But in 1997, cruelty, physical
and mental torture were made ground enough for a Christian woman to obtain a divorce, with
the Bombay High Court recognizing cruelty and desertion as independent grounds for the
dissolution of a Christian marriage. Divorce under the Hindu Marriage Act 1955 can be
obtained on the grounds of adultery, cruelty, desertion for two years, conversion in religion,
an unsound mind, suffering from venereal disease or leprosy or if the spouse has renounced
the world and has not been heard from for seven years. Also no resumption of co-habitation
for one year after the decree of judicial separation, no restitution of conjugal rights for one
year after decree for restitution of conjugal rights, or if the husband is guilty of rape, sodomy
or bestiality.[xiv]All major religions thus have their own laws that govern divorces within
their own community, and there are separate regulations under the Special Marriage Act,
1954 regarding divorce in interfaith marriages. Under a common civil code, one law would
govern all divorces for all communities based on religion. One should not forget that
nationhood is symbolized by one Constitution, a single citizenship, one flag and a common
law applicable to all citizens and India’s obligations under international law and requirements
of various international instruments relating to the human rights of women such as Universal
declaration of Human Rights, 1948 and the Convention on the Elimination of all forms of
Discrimination Against Women, 1979 also demand that even if one rules out Article 44 the
Union of India cannot evade its international obligation to make laws to remove
discrimination against women.[xv]

The Article 44 of the Constitution of India requires the state to secure for the citizens of India
a Uniform Civil Code throughout the territory of India. As has been stated above, India is a
unique blend and merger of codified personal laws of Hindus, Christians, Parsis and to some
extent the laws of Muslims. However, there exists no uniform family law in a single statute
which is applicable for all Indians which are universally acceptable to all religious
communities who co-exist in India.

As discussed above, the Supreme Court of India for the first time directed the

Indian Parliament to frame a Uniform Civil Code in 1985 in the case of Mohammad Ahmed
Khan v. Shah Bano Begum AIR 1985 SC 945. In this case a penurious Muslim woman
claimed maintenance from her husband under Section 125 of the Code of Criminal Procedure
after her husband pronounced triple Talaq. The Apex Court held that the Muslim woman had
a right to get maintenance under Section 125 of the Code and also held that Article 44 of the
Constitution had remained a dead letter. To undo the above decision, the Muslim Women
(Right to Protection on Divorce) Act, 1986 which curtailed the right of a Muslim Woman for
maintenance under Section 125 of the Court was enacted by the Indian Parliament.

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Thereafter, in the case of Sarla Mudgal Vs. Union of India AIR 1995 SC 1531, the question
which was raised was whether a Hindu husband married under Hindu law can, by embracing
Islamic religion, solemnize a second marriage. The Supreme Court held that a Hindu
marriage solemnized under Hindu Law can only be dissolved under the Hindu Marriage Act
and conversion to Islam and marrying again would not by itself dissolve the Hindu marriage.
Further, it was held that a second marriage solemnized after converting to Islam would be an
offence of bigamy under Section 494 of the Indian Penal Code.

The Supreme Court has always put forth the need for Parliament to frame a common civil
code which will help the cause of national integration by removing contradictions based on
ideologies. The Directive Principle of enacting a uniform civil code has been urged by the
Apex Court repeatedly in a number of decisions as a matter of urgency and top priority to
stop the unevenness and often inequalities and immunities that such personal laws have
continued to offer over the years. Unfortunately, in a subsequent decision of Lily Thomas
v.Union of India 2000 (6) SCC 224, the Apex Court, dealing with the validity of a second
marriage contracted by a Hindu husband after his conversion to Islam, clarified that the court
had not issued any directions for the codification of a common civil code and that the judges
constituting the different benches had only expressed their views in the facts and the
circumstances of those cases. Even the lack of will to do so by the Indian government can be
deciphered from the recent stand stated in the Indian press that the Indian government does
not intend to bring legislation to ensure a uniform civil code because it does not want to
initiate changes in the personal laws of minority communities. However, this ought not to
deter the efforts of the Supreme Court of India in issuing mandatory directions to the central
government to bring a common civil code applicable to all communities irrespective of their
religion and practices in a secular India. Hopefully, the Apex Court may review its findings
in some other case and issue mandatory directions to the central government to bring a
common civil code applicable to all communities irrespective of their religion.

The Preamble of the Indian Constitution resolves to constitute a Secular Democratic Republic
as stated earlier and this means that there is no State religion and that the state shall not
discriminate on the ground of religion. Articles 25 and 26 of the Constitution of India
guarantee the citizens the freedom of religion and freedom to manage religious affairs. At the
same time Article 44 which is not enforceable in a Court of Law states that the state shall
endeavour to secure a uniform civil code in India. The ingredients of a Uniform Civil Code is
indeed a difficult task to determine since the personal laws of each religion contain separate
ingredients, the uniform civil code will need to strike a balance between protection of
fundamental rights and religious principles of different communities and most importantly
not harm the sentiments of the communities that coexist in our country. Marriage, divorce,
succession, inheritance and maintenance can be matters of a secular nature and law can
regulate them. India needs a codified law which will cover all religions in relation to the
personal laws of different communities.

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Critics of the uniform civil code think that the true principles of Muslim law remain eclipsed
by its extensive alleged misreading over the years. It is suggested by Prof. Tahir Mahmood,
an eminent scholar in his article that “An Indian Code of Muslim Law based on an eclectic
selection of principles from the various schools of Shariat is the ideal solution to all the
contemporary problems of Muslim Law.”[xvi] It has been reported that the Supreme Court of
India dismissed a public interest litigation petition challenging the legality of the customs of
polygamy, talaq and divorce practiced by Muslims under the personal laws. The plea for a
direction to the Central Government to make Uniform Marriage Laws for all communities
was rejected on the ground that it is for the Parliament to change or amend the law. Thus, the
debate is endless and the issue has continued to remain unresolved even till the present day.

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CHAPTER 3

CONCLUSION

Thus to conclude we need to understand the importance and the need the urgent enactment of
the uniform civil code. The time has come to place all personal laws of all religions under a
stringent check and discard all laws that are found to violate the Constitution. Personal laws
of all religions discriminate against women on matters of marriage, divorce, inheritance and
so on. There is an urgent need to carve out the just and equitable laws of all religions and
form a blueprint for a uniform civil code based on gender justice and to ensure the principle
of equality enshrined by our Constitution and to alter laws which are discriminatory and
biased. The Hindu code cannot be applied uniformly to all religions. On the other hand, triple
talaq would have to go, as would polygamy and all the advantages that accrue to Hindu
undivided families in matters of property and inheritance.[xvii]

In this backdrop, one can say that in our country, personal laws continuously affect the lives
and rights of a large number of women of all most all the communities and most importantly
leave them in a very deprived position. Although various efforts are being initiated and taken
by means of introducing international instruments, reforms of national laws, changing
judicial trends, recommendations of Law Commissions and other social elite groups to ensure
gender equality but still women in our country are not treated equally and discriminated in
the field of family law especially in cases of marriage, divorce, maintenance, inheritance etc.
In these situations, a gender-just code is the need of the hour for long. So a Uniform Civil
Code is a very important step towards the protection of oppressed women, to protect their
human rights, to remove discrimination against them irrespective of their religion or
community to which they belong to and lastly to make our national laws in accordance with
the international instruments which are legally binding on India through various international
conventions and international Human Rights instruments which are ratified by India. The
present time is ripe for us to try to bring into light the idea of having a Uniform Civil Code
through. To sum up at last, it can be said for citizens belonging to different religions; it is
imperative that for promotion of national unity and solidarity and to promote national
integration a unified code is an absolute necessity on which there can be no compromise that
one can afford to make. Different streams of religion have to merge to a common destination
and some unified principles must emerge in the true spirit of Secularism. India needs a
unified family law code under an umbrella of all its constituent religions. Whether it is the
endeavour of the State, the mandate of the court or the Will of the people it is an issue which
time only can decide.

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BIBLIOGRAPHY

1. http://india.wikia.com/wiki/Uniform_civil_code
2. http://www.clearias.com/uniform-civil-code-ucc/
3. http://economictimes.indiatimes.com/cms.dll/html/uncomp/articleshow?m
sid=98057,
4. F. Agnes, “Hindu Men Monogamy and Uniform Civil Code” XXX (50)
Economic and Political Weekly 32 (1995); B. Karat, “Uniformity v.
Equality” Frontline 17 Nov, 1995.
5. Rajeev Dhawan, “The Apex Court and Personal Law” The Hindu, 14
March 1997
6. Nilanjana Bhaduri Jha, “Does India really need a Uniform Civil Code?”
from website of Times of India,
7. Paras Diwan and Peeyushi Diwan,; Law of Marriage and Divorce, 47
(Lexis Nexis, Gurgaon 1997 edition).
8. Shiv Sahai Singh, ; Unification of Divorce Laws in India, 376 (Lexis
Nexis Gurgaon 1993edition ).
9. Virender Kumar, “See the Rift, not the Fault” 12, The Tribune, 21 May,
2006.
10. Ramesh Chander Nagpal, Modern Hindu Law, 182 (2008 Butterworths
Wadhwa Publications, Nagpur)
11. 217th Indian Law Commission Report was forwarded on 30 March 2009.
12. B.M Gandhi, Hindu Law 376 (Eastern Book Company,Lucknow,4th
edition,2016)
13. Jyoti Rattan, “Uniform Civil Code in India: A Binding Obligation Under
International And Domestic Law” 46 JILI 577 (2004).
14. “Muslim Personal Law: Clearing The Cobwebs”, The Hindu, July 30,
2006.
15. Shabana Azmi, Women, Stand Up For Your Rights, The Times of India, 7
July 2005
16.

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