THAKUR RAMNARAYAN COLLEGE OF LAW

FARHAN HAMEED KHAN

TYBLS/LLB

SEM- VI SEMESTER

SUB:- FAMILY LAW – I

TOPIC:- INTESTATE SUCCESSION OF PARSIS: A CRITCAL

ANALYSIS

A/23

APRIL 20, 2022

PROFESSOR; Ms. Munmun Tyagi
 INDEX

Sr. No. Content Pg. No.

1. INTRODUCTION. 3

2. AIMS & OBJECTIVES. 4

3. SCOPE AND LIMITATION & RESEARCH 5

QUESTION.

4. THE PARSI COMMUNITY AND THEIR PERSONAL LAWS. 6-9

5. LAWS RELATING TO INTESTATE SUCCESSION AMONG 10 - 16

PARSIS.

6. INHERITANCE RIGHTS OF PARSI WOMEN UNDER 17

INTESTATE SUCCESSION LAWS (ISA, AMENDED ACT OF
1991)

7. CONCLUSION 18

8. BIBLOGRAPHY 19
 INTRODUCTION

The Parsi community in India initially had no law of their own. The Parsi immigrants came to
settle in India to escape religious persecution by the Arab conquerors of Persia and brought
with them Zoroastrianism and at the same time they adopted the customs of the place where
they had first taken shelter in India.

While preserving their separate identity they had adopted the customs of residents of the area
they had first taken shelter. Their customary laws mainly influenced by the Hindu and
Muslim communities, underwent various modifications following a series of enactments like
Parsi Chattels Real Act 1837; The Parsi Marriage and Divorce Act 1865; The Parsi Intestate
Succession Act 1865; The Indian Succession Act 1925 passed for Parsis by the British Indian
Legislature.

Until 1925, the Parsi Intestate Succession Act was still in force. While the Act was in effect,
on its implementation, the many significant decisions were made in order to give different
judicial interpretations to the legal provisions enacted in this statute. However, when the
Indian Succession Act 1925 was enacted, the Parsi Intestate Succession Act was incorporated
verbatim into Chapter III of that Act and was completely repealed by Schedule IX of that
Act.

Laws of succession applicable to Parsis; for the intestate succession the governing law is the
Indian Succession Act, 1925 specifically under section 50 to 56 of the Indian Succession Act,
1925.

The present law which is governing them is quite different now. It has adopted the
progressive social changes very well. This law manages to stand out at it gives both men and
women equal importance and is very gender neutral. Under the Indian Succession Act, 1925
males and females inherit equally.

This research project thereby seeks to study the laws relating to intestate succession in the
Parsi community and highlight a detailed and structured analysis of the provisions mentioned
in Indian Succession Act, 1925. A chapter on rights of Parsi women under intestate
succession laws is included in a detailed manner concerning the amendment of Indian
Succession Act in 1991.
AIM(S)

The aim of this research is to explore the laws of intestate succession in Parsis and also to
discuss and examine the rights given to women in inheritance as per different legislations and
personal laws concerning the Parsi community as well as the historical evolution of Parsi
Laws and this community in India.

OBJECTIVE(S)

Following are the objectives of this research project:

1. To define who is a ‘Parsi’.

2. To explore the establishment of Parsi Laws in India and their development over time.

3. To understand the concept of ‘intestate succession’ and discuss the Parsi laws of intestate
succession through case laws.

4. To discuss the legal provisions for Parsi intestate succession mentioned in Indian
Succession Act, 1925.

5. To understand how changes were brought in the Amendment of 1991 with respect to
giving rights to Parsi women in regards of intestate succession and heritance.
SCOPE AND LIMITATION(S)

The scope of this research project is limited to the in-depth discussion of the provisions of the
Indian Succession Act, 1925 (sec.50-sec.56) for intestate succession in Parsis. The researcher
shall limit the study of changes to amended inheritance laws for women in the Indian
Succession Act in 1991 with respect to evolution in the said law and also referring to various
previous Acts and case laws.

RESEARCH QUESTIONS

Following are the research questions to this project:

1. Who is a Parsi? How did their personal laws evolve in time?

2. What is the concept of intestate succession?

3. What are the legal provisions concerning intestate succession in Parsi personal laws as
mentioned in Indian Succession Act, 1925?

4. How has the amendment in 1991 to Indian Succession Act, 1925 brought about changes in
inheritance laws and right to succession among Parsi women?
 THE PARSI COMMUNITY AND THEIR PERSONAL LAWS

PARSI COMMUNITY IN INDIA

It is often confused that the Parsis follow ‘Parsi’ religion but that is not true as there is no
such religion. The Parsis follow Zoroastrian faith and in that sense in India the words ‘Parsi’
and ‘Zoroastrian’ are used interchangeably. The Parsis, whose name means "Persians,"
comes from Persian Zoroastrians who immigrated to India in order to avoid Muslims '
religious persecution. They live mainly in Mumbai and in some cities and villages mostly
north of Mumbai, but also in Karachi (Pakistan) and Bengaluru (Karnataka, India). While,
strictly speaking, they are not a caste, as they are not Hindus, they form a well-defined group.

The exact date of the Parsi migration is unknown. According to tradition, the Parsis initially
settled at Hormuz on the Persian Gulf, but finding themselves still persecuted they set sail for
India, arriving in the 8th century. They settled first at Diu in Kathiawar but soon moved to
Gujarat, where they remained for about 800 years as a small agricultural community. With
the establishment of British trading posts at Surat and elsewhere in the early 17th century, the
Parsis circumstances altered radically, for they were in some ways more receptive of
European influence than the Hindus or Muslims and they developed a flair for commerce.
Bombay came under the control of the East India Company in 1668, and, since complete
religious toleration was decreed soon afterward, the Parsis from Gujarat began to settle there.
The expansion of the city in the 18th century owed largely to their industry and ability as
merchants. By the 19th century they were manifestly a wealthy community, and from about
1850 onward they had considerable success in heavy industries, particularly those connected
with railways and shipbuilding.

Due to the existence of a parallel administration structure in the Mofussil and Presidential
regions, Parsis were governed by their customary laws in the former areas, while those in the
latter areas were governed by English laws. Completely contrary to the Mofussil Parsis rule
under which women were originally exempted from inheritance and had only a right of
maintenance under English law, an intestate's widow had a complete share to the extent of
one-third of his property and the daughter was treated on equal terms with the son.
DEVELOPMENT OF PARSI LAWS IN INDIA

The Parsi Intestate Succession Act 1865 established a uniform scheme for all Indian Parsis
and increased a widow's and a daughter's share to a specific absolute ownership rather than a
bare maintenance claim. The said Act was subsequently amended and incorporated into
sec.50-56 and the Schedule II of the Indian Succession Act, 1925. This law was amended in
1937 and then major changes were made in Parsis’ inheritance laws in 1991by amendments
to relevant sections in order to make them fairer and gender just.

Until 1837, the laws applicable to the Parsis and their estate were subject to some exceptions
to the English Common Law. A Parsi man died in 1835 without a will, leaving some
immovable assets in Mumbai behind. His eldest son subsequently filed a lawsuit at Bombay's
Supreme Court (SC) seeking the entire property under the principle of primogeniture
practiced in England. Primogeniture meant that their father's estate would be inherited by the
first-born or eldest male child. This condition worried the Bombay Presidency's Parsis and
Parsis calling on the legislature to amend their personal rule. As a result of this appeal, Parsee
Chattels Real Act 9 of 1837 came into being in which it was proclaimed that, as of 1 June
1837, all immovable property under the jurisdiction of any of the courts created by the
Charter of His Majesty will be transferred on the death and intestation of any Parsi having a
beneficial interest in it, or by virtue of the last will of any such Farsi be taken to be and to
have been of the nature of chattels real and not of freehold. The outcome of this act was that
it relieved the Parsis from English Law of Primogeniture.

A meeting of all the Parsis of Bombay was held on August 20, 1855, to discuss and take
measures for the enactment of laws governing the Parsis, and a committee was also appointed
at this meeting to draft a code of laws and to petition the LC of India to enact them. In 1856,
the Privy Council decided in Ardeseer Cursetjee v. Peerozebai10 ’s case, in which the topic
of the restitution of marital rights was raised in Bombay's court. The defendant had filed a
lawsuit in court's opposition to consider the lawsuit.

The Chief Justice held the court to have jurisdiction, the puine judge found it had not, and the
Chief Justice's decision prevailed. The Privy Council held that the Supreme Court was
incapable of recognizing or applying the English ecclesiastical law to the parties concerned
which was founded exclusively for Christians and all parties professing the religion of the
Parsi. Thus, therefore, a case for the restoration of conjugal rights, purely an ecclesiastical
action, could not be made to parties professing the religion of the Parsi.

On December 5, 1859, a body of rules called' a Draft Code of Inheritance, Succession and
Other Problems' was decided and adopted by the Managing Committee of the Parsi Law
Assn. and the same was submitted to the LC. After many considerations and numerous
measures involved, the result was the passage on 17 February 1865 of two bills in the LC of
India, namely (a) Parsi Marriage and Divorce Bill and (ii) Succession and Inheritance Bill.
The report of the selected committee on the succession bill was submitted on 31 March and
considered on 7 April 1865 of the same year.

In 1867 a significant decision was made in Naoroji Beramji v. Rogers12 regarding the law
governing the Parsis in a district of Bombay. This court had ruled that English Common Law
regulated the Parsis, but not in marriage cases.

Whether the Parsis followed ‘English Common Law’ and they practiced their own traditions
and usages have always been confusing. A lot of cases that posed this issue emerged. E.g in
the case of Mithibai v. Limji N Banaji13, the question was whether the rule should apply to
Parsis in the case of Shelley. It was held that the English law applicable to Parsis could not be
included in the rule in Shelley's case, which is the law of property or tenure based on feudal
considerations and inappropriate to the circumstances in India, and that, in the absence of
evidence of any specific law or use applicable to a particular case, the law applicable to the
Parsis in the mofussil of the Presidency of Bombay is that of justice, equity and good
conscience alone.

In Maneckbai v. Meherbai15, the plaintiff sued the defendant alleging that her husband had
shortly before his death conveyed to the defendant's husband who was the friend of the
plaintiff’s husband an immovable property on trust (which was oral) communicated to the
defendant's husband that he should sell the property and hold the sale-proceeds in trust for the
benefit of the family of the plaintiff. It was held that English law governed the Parsis and the
statute of frauds applied and as the trust was oral and as the statute required writing the
plaintiff’s suit failed.

In Payne & Co v. Pirosijha Pate16, it was held that the common law of England applied to
Parsis in the Island of Bombay under which the wife was entitled to pledge her husband's
credit and defend herself at his costs in any action he may file against her for the dissolution
of his marriage with her. It was not necessary that the wife should be successful in the suit.
In Hirabai v. Dinshai17 the question was whether in an action for slander of woman special
damage must be shown and it was held that the Parsis in the city of Bombay were governed
by the common law of England and special damage must be shown.

The uncertainty did not disappear even in 1921. Once again it was addressed in Kuberdas
Devchand v. Jerkish Navroji19 on the law governing the Parsis in the mofussil. It was held
that, if there is no statutory provision, mofussil's Parsis was governed primarily by use and
secondly by equity rules or general principles of English law applicable only to similar
conditions.

The Parsi Intestate Succession Act remained in force till 1925. The Indian Succession Act
was introduced in 1925 and the Parsi Intestate Succession Act was verbatim included in
Chapter III of Indian Succession Act, 1925.

LAWS RELATING TO INTESTATE SUCCESSION AMONG PARSIS

CONCEPT OF INTESTATE SUCCESSION

Inheritance means succession in the common language. A person's death is preceded by

succession. The Constitution of India through Entry 5 in List III recognizes personal laws
which address areas such as marriage, divorce, adoption, partition, intestation, succession,
etc. In most cases, The Hindu Succession Act prescribes the rules relating to succession
applicable to Hindus, Sikhs, Buddhists, Jains etc. It extends to majority of the Indians. Sharia
Law is applicable to Muslims. The Indian Succession Act applies to Christians, Parsis and
other persons not covered by the Hindu Succession Act and the Sharia Law.

Succession is a very touching topic in a complex and diverse country like India. It can be
either a Testamentary succession–one with a will;

or a succession of Intestate–one without a will. A will is essentially a statement expressing a

person's desires regarding his estate and providing for his transfer upon death. A person is
said to have died intestate in respect of an asset he has not disposed of under a will, or the
disposition under the will is unable to take effect either because of invalid legacy or unlawful
legacy. Intestacy can be partial or complete.

In the event a person dies intestate, his/her assets are distributed as per the mandate of the
Indian Succession Act. The vesting of the assets takes place under the relevant personal laws.
However intense complexities arise when there is more than one heir, given the fact that
some assets are more lucrative than their counterparts.

In order the make a claim, one requires either a letter of administration or succession
certificate issued by the court.

E.g: If A has left no will- He has died intestate in respect of the whole of his property.

A has left a will, whereby he has appointed B his executor; but the will contains no other
provisions- A has died intestate in respect of the distribution of his property.

A has bequeathed his whole property for an illegal purpose - A has died intestate in respect of
the distribution of his property.

When a will is partially incapable of being operative- A has bequeathed RS 1000 to B and Rs.
1000 to the eldest son of C, and has made no other bequest; and has died leaving the sum of
Rs. 2000 and no other property. C died before A without having ever had a son. A has died
intestate in respect of the distribution of Rs.1000.

Parsis is governed by the Parsi intestine rules set out in Chapter III of Part V of the Act.
Pursuant to sections 51-56 of the Act, the property of a Parsi intestate is divided among its
heirs.

PARSI INTESTATE SUCCESSION ACT, 1865

Before 1925, the Parsi Intestate Succession Act 1865 was still in force. While the Act was in
effect, on its application, the following significant decisions were made, in a way to frame a
uniform scheme for Parsis and also increase the share of a widow and daughter to a specific
absolute ownership rather than a bare claim for maintenance-

1. In Mancherji v. Mithibai22 it was held on construction of section 5 that when a child

of a Parsi intestate died in his or her lifetime and left only a window but no issue, such
widow was entitled to a share, e.g; if the intestate Parsee died having a widow, sons,
daughters, children of a predeceased son, and widow of another predeceased son who
has died without issue, and a posthumous daughter was afterwards born to the
intestate, it was held that the widow of the predeceased son was entitled to one moiety
of the share in the intestate's property which her husband would have taken had he
survived the intestate, and that it was not a condition precedent to the application of
section 5 that the predeceased son should have left both a widow and children. The
other moiety of the share of the predeceased son devolved on the surviving issue of
the intestate including the posthumous daughter and the children of his other
predeceased son.
2. In Erasha v. Jerbai24 the question raised was whether Jerbai the daughter of the
intestate Parsi was entitled to grant on letters of administration to the· estate of her
father Ardeshir, who left a will in which he completely disinherited Jerbai and
bequeathed all his property to his brother Ratansha; but Ratansha having predeceased
Ardeshir, the bequest to him lapsed and there was intestacy. It was contended that
Jerbai having been expressly excluded by Ardeshir by his will from taking any share
 in his property, she was not entitled. But it was held that Ardeshir having died
intestate the estate must go according to law notwithstanding the exclusion of her
under the will and .Jerbai was entitled to the grant and the property should be
distributed between the widow and children of Ardeshir.

INDIAN SUCCESSION ACT, 1925

The Indian Succession Act, 1925 governs all the Parsis living in India regarding the matters
of succession. This Act is not retrospective in nature and applies to any Parsi residing in
India. Chapter III of the Act mainly Sec. 50 to Sec. 56 talks about the rules for succession in
case of a Parsi dying intestate.

General Principles relating to intestate succession in Parsis are mentioned in Sec. 50 of the
Act. The following points have to be considered while distributing the property of a Parsi
died without a will:

1. Whoever actually born in the lifetime of the deceased Parsi person or at the date of
his death only conceived in the womb and subsequently born alive is considered (en
ventre sa mere).
2. If a lineal descendant i.e. a child or remoter issue dies before the deceased Parsi
without leaving widow or widower or lineal descendant or widow or widower of
lineal descendant, the share of such child shall not be taken into consideration.
3. Where a widow or widower of any relative marrying again during the lifetime of the
intestate Parsi, such widow or widower is not entitled to receive any share in the
property of the deceased Parsi. However, the intestate's mother and paternal
grandmother would be the exception to this rule, and they would get a share even if
they remarried in the intestate's lifetime.

Summing up, we can say that in case the person dies intestate then:

• Widow & Children: Each of them receive equal shares.

E.g. Son- 1 Widow-1 Daughter-1

• No widow & children: Shared equally among children

E.g. Widow-0 Son-1 Daughter-1

• Parents in addition to widow or widower and children: Father’s share is equal to half the
share of the son and the mother’s share is equal to half the share of the daughter. If one of the
parents survives, he or she gets the same share.

E.g. Widow-1 Son-1 Daughter-1 Father-½ Mother-½

Points to ponder :

1. The parents only receive the share if the son dies without the will and not in the
daughter's case.
2. There is no stepfather & stepmother in the parents.
3. Both sons and daughters can be full blood and half blood.

Sections 51 to 56 lay down the rules of division of the property of an intestate Parsi.
Following provisions are thus discussed in detail-

Section 51: This section addresses the issue of how to distribute the property of an intestate
to his children, parents, widow or widower. There are two sub-sections, the first of which is
the situation in which intestate Parsi leaves children or widow / widower or both. Clause (a)
of sub-section ‘one’ says that the shares will be divided equally if a Parsi dies intestate
leaving widow / widower and children. Clause (b) states that if a Parsi dies intestate without
leaving a widow / widower but children, the shares will be divided equally among the
children. Sub-section (2) sets out the sharing pattern where there are children, widow /
widower and, either or both, parents, parents should receive half of what each child receives.

Section 52: This section was repealed.

Section 53: The section provides us with a situation where there has to be a division of the
shares of a predecessor intestate child leaving behind linear offspring. –

Clause (a) of this section addresses the situation where the intestate's predecessor is a father,
in this case the wife and children of the predecessor will receive the shares as if the son had
died immediately after the death of the intestate. It adds that where such deceased son has left
a widow or a widow of a lineal descendant but no lineal descendant, the remaining or the
residue of such share after the distribution has been made shall be divided according to the
provisions of the ISA as property of which the intestate has died intestate, and in making the
division of such residue the said deceased son of the intestate shall not be taken into account.

- Clause (b) states that in the event that the predecessor is a daughter, the daughter's share
will be shared equally among her children.

- Clause (c) specifies that if a child of a predecessor is also deceased, the proportion of such
predecessor child of a predecessor child shall be allocated as the case may be in accordance
with clauses (a) and (b).

- Clause (d) of the act states that where a remote lineal descendant of the intestate died during
the lifetime of the intestate, the provisions of clause (c) shall apply' mutatis mutandis' to the
division of any share to which he or she would have been entitled if he or she existed at the
death of the intestate due to the predecessor of all lineal descendants of the intestate directly
between him or her.

Section 54: This section provides the rules of division of property in case where the intestate
leaves widow/widower or widow/widower of any lineal descendant but no lineal descendant.
In such case, the following shares will be distributed in such ways:

1. When there is a Widow or Widower but has no widow or widower of a lineal

descendant:
Widow or Widower-1/2 share Relatives- 1/2 share.
2. When there is a Widow or Widower along with the widow or widower of a lineal
descendant:
Widow or Widower-1/3 share Widow of lineal descendant Relatives- 1/3 share.
3. When there is no Widow or Widower but there’s widow(s) of a lineal descendant:
(i) One widow of lineal descendant -1/3 share Relatives- 2/3 share
(ii) More than one widow of lineal descendants -2/3 share Relatives- 1/3 share
4. The residue amongst relatives in Part I of Schedule II:
Father- 2 Mother-1 ·
Brothers-2 Sisters-1
Section 55: This section states that in the event that a Parsi died intestate and left no widow /
widower, linear offspring or widow / widower of such offspring, next-of-kin, the order set
out in Part II of the second schedule shall be entitled to succeed the entire property. Each
male and female will receive equal parts in the same degree of propinquity. In previous laws,
in the same degree of propinity, each male took twice the share of each female standing.

The order in which the share will be distributed as the next -of-kin standing first will be
preferred to those standing second and second to third and so on is discussed (as per Part II of
Second Schedule of the Act).

A. Father and mother.

B. Brothers and sisters (other than half brothers and sisters) and lineal descendants of
such of them as shall have predeceased the intestate.
C. Paternal grandparents.
D. Children of paternal grandparents and the lineal descendants of such of them as have
predeceased the intestate.
E. Paternal grandparents' parents.
F. Paternal grandparents' parents' children and the lineal descendants of such of them as
have predeceased the intestate.
G. Maternal grandparents and their lineal descendant and their children.
H. Half brothers and sisters and the lineal descendants of such of them as have
predeceased the intestate.
I. Widows of brothers or half-brothers and widowers of sisters or half-sisters.
J. Paternal or maternal grandparents' children's widows or widowers.
K. Widows or widowers of deceased lineal descendants of the intestate who have not
married again before death of the intestate.

Section 56: This section discusses a less likely rare situation. This talks about property
division in situations where there is no absolute right under all the provisions of this
particular chapter to succeed. When there is no relative entitled to succeed under the other
provisions of Chapter 3 of Part V, of which a Parsi has died intestate, then in such a case, the
property shall be divided equally among those in the nearest degree of intestate lineage.

After the 1991 Amendments to the Indian Succession Act, 1925;

following 3 rules were laid down:

 1. if a Parsi dies intestate, leaving a widow (or widower) and children, the widow (or
widower) and each child get an equal share.
2. If Parsi has no widow (or widower) but has children each child will get equal share.
3. If Parsi dies leaving either/both of his parents, child and widow or widower then
property will be divided into following manner:

For instance, if A dies intestate leaving his wife B child C and father then B and C
will get equal shares and father will get half the share of the child
i.e.- Wife =2/5 Son =2/5 Father= 1/5

INHERITANCE RIGHTS OF PARSI WOMEN UNDER INTESTATE SUCCESSION

 LAWS (ISA, AMENDED ACT OF 1991)

Under Mofussil Parsis rule, women inherited no assets and were only entitled to maintenance.
When the rules changed until Parsis was regulated by the English Law, an intestate's widow
had a share of one – third of the intestate's land. Not only did this benefit widows, but the
daughters still benefited. The daughters were on par with the son.

Earlier, by the enactment of the Parsi Intestate Succession, 1865; a standardized scheme was
created for all Parsis living in India to increase both widow and daughter's share. They were
then entitled to a specific absolute ownership while they had only a maintenance right in the
past legislations.

This provision was subsequently revised in 1925, 1937, as well as in 1991 following
independence. It brought about a major change in heritage legislation and made these laws
more fair and just in terms of gender. The female shares always took half of their
counterparts before 1991, which is, mother was entitled to half of what father was entitled to.
The amendment of 1991 removed this discrimination and made the shares equal for all the
counterparts. Presently, the spouse and children (son and daughter) are entitled to equal
shares.

The amendment was made in the year 1991 applied to Indian Succession Act (Sec. 51),
which provides equal shares in parental intestate property for both sons and daughters35.
Previously, "the daughters and sons of a female intestate received equal shares in the assets of
the intestate, while the daughters of a male intestate received just half of what the sons
received" (Indian Succession Act, 1991). This amendment of the law provides remedy for
long-standing discrimination against women of Parsi. It has been argued that the laws of
Parsi are obviously very gender-only because the intestate property of the deceased is divided
equally between the widow and each son. If there is no widow, the children will have equal
share. Although Parsi law provides women with equal ownership of the property, but in
reality its rights are reduced to papers only.

CONCLUSION
The Indian Succession Act, 1925, governs the Parsi community in India in matters of
succession. Sections 50 to 56 of that Act provide for male and female intestines to be divided
into property. In the property of the female intestate, daughter and son receive equal shares,
whereas in the property of the male intestate, son receives double the daughter's share.

In its 110th Report, the Law Commission of India reviewed these laws and recommended the
abolition of discrimination between sons and daughters in the case of property of a male
intestate. The Parsi community has proposed amendments to the law to eliminate
discrimination between sons and daughters by providing that both will share equally in the
property of the male intestate as well. These amendments are also made in accordance with
the government's policy of granting women rights in the parental property.

Sections 50 to 56 were previously replaced by Act 17 of 1939 to remove doubts, deficiencies

in supply, incorporate the judicial decisions then accepted by the community as far as
possible. With regard to the constitutional rights of equality between men and women, the
reforms adopted by Act 51 of 1991 take the matter further.

Specific aspects of this Act are that-if there is any pre-deceased wife, her share will be
distributed to her children, and husband or parents of the husband would not get anything.
Another unique provision is that the widow does not receive full share, in the event that there
is no linear descendant, there is always a residue left that is further distributed according to
the schedule mentioned in the ISA.
BIBLOGRAPHY

Articles:

1. Mrs. Aliya Naqvi , WOMEN'S RIGHTS AND PERSONAL LAWS: A

COMPARATIVE STUDY; Department of Political Science, University of Rajasthan,
Jaipur
2. Pandey, Anubhav, 'Everything you need to know about Intestate Succession'
3. ‘Succession in Parsi Community’, Shodhganga article.
4. Bilawala, Marylou, 'SUCCESSION FOR MOHAMMEDANS, PARSIS AND
CHRISTIANS', Bombay Chartered Accountant Journal, December 2018.

Websites:

1. HELPLINE LAW, ‘Inheritance in Absence of A Will under Indian Succession Act’,

(http://www.helplinelaw.com/real-estate-wills-probate-and-trust/IWIS/inheritance-in-
absence-of-awill-under-indian-succession-act.html)
2. ‘INTESTATE SUCCESSION’; https://blog.ipleaders.in/everything-need-know-
intestate-succession/
3. https://shodhganga.inflibnet.ac.in/bitstream/10603/195937/12/12_chapter4.pd