NATIONAL LAW UNIVERSITY ODISHA, CUTTACK

A PROJECT WORK ON PERSONAL LAW - 2

TOPIC: INTERSECTIONALITY IN SUCCESSION LAW: EXAMINING

THE INTERPLAY OF RELIGION, GENDER, AND UNIFORM CIVIL
CODE

UNDER THE GUIDANCE OF:

DR. AKSHAY VERMA

SUBMITTED BY:
AADRIKA GOEL (2021/BBALLB/002)
VATSALA TR(2021/BBALLB/053)
B.B.A. L.L.B | SEMESTER 6
BATCH 2021-2026
Contents
INTRODUCTION......................................................................................................................3
OVERVIEW OF SUCCESSION LAWS...................................................................................5
INTERSECTIONALITY AND GENDER DYNAMICS IN SUCCESSION LAW UNDER
UCC............................................................................................................................................7
RELIGIOUS INLFUENCE ON SUCCESSION LAWS.........................................................10
ANALYSING THE UTTARAKHAND UNIFORM CIVIL CODE BILL 2024.....................12
INTEREST OF THE QUEER COMMUNITIES IN THE UTTARAKHAND UCC BILL......................13
UTTARAKHAND UCC BILL V CENTRAL LAWS.....................................................................13
CONCLUSION........................................................................................................................14
 INTRODUCTION

The Indian Supreme Court's landmark judgment in the Shayara Bano1 case, which
invalidated the Muslim practice of divorce through triple talaq, reignited debates around
personal laws in India. Initiated by five Muslim women and supported by various women's
rights organizations, the case raised several pertinent questions. 2 Despite the significant
ruling, many questions remained unanswered, highlighting the contested nature of personal
laws. These debates intersect not only with religious freedom and gender equality but also
with broader discussions around identity, nationalism, modernity, and secularism. “The UCC
is favored by a large segment of the feminist discourse, which claims it has the ability to
rectify systemic gender prejudice in personal laws. Systemic discrimination occurs, for
instance, when women are not always granted the same rights to ancestral property as males.
By establishing a uniform legal framework, the UCC can assist in redressing these
differences.”3

Scholars examining the Indian personal law system through a gender lens evaluates how
family and property matters are governed by religious laws for Hindus, Muslims, Parsis,
Christians, and Jews. Despite longstanding discussions about replacing this system with a
Uniform Civil Code, the directive principle in the Constitution (Article 44) 4 advocating for a
uniform civil code remains unfulfilled. The current system operates as a "shared
adjudication," where the State shares its adjudicative authority with religious and societal
actors and organizations.

“In the complex tapestry of Indian law, succession laws play a vital role in determining social
structures and family relationships. These laws, which frequently reflect deeply ingrained
patriarchal attitudes and religious concepts, define an individual's inheritance rights at the
crossroads of gender and religion. The debate in India on succession rules is complex,
entwining issues of religious freedom, gender parity, and the need for a Uniform Civil Code

1
Shayara Bano vs. Union of India [(2017) 9 SCC 1]
2
Tanja Herklotz, ‘Law, religion and gender equality: literature on the Indianpersonal law system from a
women’s rights perspective’ (TandFonline, 14 March 2018)
<https://www.tandfonline.com/doi/epdf/10.1080/24730580.2018.1453750?needAccess=true> accessed on 4th
March 2024
3
Aditya Sinha, ‘Breaking Barriers: How Uniform Civil Code can be a catalyst for equality and inclusion’
(FirstPost , 1 July 2023) <https://www.firstpost.com/opinion/breaking-barriers-how-uniform-civil-code-can-be-
a-catalyst-for-equality-and-inclusion-12812322.html > accessed on 2nd March 2024
4
The Constitution Of India, Art. 44,1947
(UCC).”5 India, a secular democracy, struggles to find common ground with the various
religious sects that follow different personal laws concerning inheritance. These laws, which
have their roots in religious traditions and customs, frequently maintain gender inequality by
marginalizing women in matters on succession. Achieving gender equality and justice in
inheritance rights is severely hampered by the societal norms and the ingrained biases in
these laws.6

Moreover, the argument over the adoption of a Uniform Civil Code becomes crucial to
debates on succession laws. Advocates contend that a UCC would provide equality before the
law and offer a cohesive legal framework that cuts across religious lines. Critics, however,
express worries about the possible loss of cultural identities and the violation of religious
freedoms.

This research paper aims to delve into the complex interplay between gender, religion, and
the quest for a Uniform Civil Code within India's succession laws. By critically examining
the existing legal frameworks governing inheritance, we seek to uncover the systemic
inequalities perpetuated by religious personal laws and assess the feasibility and implications
of transitioning towards a uniform legal code. Through an intersectional lens, we endeavor to
shed light on the nuanced dynamics shaping inheritance rights, with a focus on gendered
experiences and marginalized voices within India's legal landscape.

5
Tanja Herklotz, ‘Law, religion and gender equality: literature on the Indianpersonal law system from a
women’s rights perspective’ (TandFonline, 14 March 2018)
<https://www.tandfonline.com/doi/epdf/10.1080/24730580.2018.1453750?needAccess=true> accessed on 4th
March 2024
6
Purvika Sanjay Kirmire, ‘UNIFORM CIVIL CODE TOWARDS GENDER JUSTICE’ (LegalVidhiya, 18
August 2023) < https://legalvidhiya.com/uniform-civil-code-towards-gender-justice/> accessed on 2 nd March
2024
 OVERVIEW OF SUCCESSION LAWS
The Indian Constitution enshrines the principle of equality before the law, as articulated in
Article 147, ensuring that no person is denied equal protection of the laws within the territory
of India. However, despite these constitutional guarantees, patterns of inheritance in India
have historically remained unequal, particularly along gender lines.

Succession laws can be categorized into two main parts: when a deceased individual has left
behind a valid and enforceable will, and when they have not.8 A will is a written document
that expresses the desires of a deceased person regarding the distribution of their estate. It can
be made by any person capable of entering into an agreement, provided they are not minors
or under the influence of intoxication, coercion, fraud, or illness affecting their free will.

The Indian Succession Act of 19259, which governs wills, does not prescribe any specific
format or technical requirements. Special provisions exist for soldiers, airmen, and mariners
in specific circumstances, allowing them to make privileged wills orally or in writing without
the usual formalities. These wills become null one month after the testator ceases to be
entitled to make them. In the absence of a will, the distribution of the estate follows certain
rules depending on the religious affiliation of the deceased.

Since 1956, inheritance rights for Hindus, Sikhs, Buddhists, and Jains have been governed by
the Hindu Succession Act (HSA) of 1956. Prior to the enactment of the HSA, Hindu
inheritance was governed by Hindu canonical "Shastric" and customary laws, which varied
across different regions of the country. These regional variations included schools of Hindu
law such as Dayabhaga in Bengal, Mayukha in Bombay, Gujarat, and Konkan, Namudri in
Kerala, and Mitakshara in other parts of India. The HSA follows the Mitakshara tradition,
which distinguishes between individual property and joint family property.

Under the Hindu Succession Act10, when a Hindu male died intestate (without a will),
daughters were granted equal rights to their father's individual property but were excluded
from inheriting joint family or ancestral property, which was reserved for male members
7
The Constitution Of India, Art. 14, 1947
8
Shekhar Aggarwal, ‘India: Succession Laws In India In A Nutshell’ (Mondaq, 24 June 2020) <
https://www.mondaq.com/india/wills-intestacy-estate-planning/957940/succession-laws-in-india-in-a-nutshell>
accessed on 3rd March 2024
9
Indian Succession Act, 1925
10
Hindu Succession Act,1956
known as coparceners. Sons were automatically considered coparceners and thus enjoyed the
right to family property by birth, with the ability to demand division of the property even
when older coparceners were alive. This framework severely limited women's ability to
inherit land, resulting in significantly unequal inheritance compared to men.

To address gender inequalities in inheritance patterns, some states amended the Hindu
Succession Act. These amendments, commonly known as the Hindu Succession Act
Amendments (HSAA), granted daughters of coparceners equal rights by birth, placing them
on equal footing with sons. States such as Kerala (1976), Andhra Pradesh (1986), Tamil Nadu
(1989), Maharashtra, and Karnataka (1994) made substantively similar amendments prior to a
nationwide amendment in 2005.

In Muslim law, Shias and Sunnis have different personal laws, which are not enshrined in any
statute. The personal law of Sunnis who adhere to Hanafi Law, which is the law followed by
the majority of Muslims in India, limits bequests to no more than one-third of the inheritance
after debts, burial costs, and unpaid wages of domestic help are paid.

For Christians, the widow/widower inherits one-third of the estate, with the balance going to
lineal descendants or other relatives known as kindred. Among lineal descendants, each child
or their children collectively receive equal shares, while among kindred, priority is given to
the father, followed by the mother, brother, and sister or their children.11

Overall, the evolution of succession laws in India reflects a shift towards greater gender
equality in inheritance rights, with amendments to the Hindu Succession Act aimed at
rectifying historical disparities and ensuring equal treatment for daughters in matters of
inheritance.

11
Shekhar Aggarwal, ‘India: Succession Laws In India In A Nutshell’ (Mondaq, 24 June 2020) <
https://www.mondaq.com/india/wills-intestacy-estate-planning/957940/succession-laws-in-india-in-a-nutshell>
accessed on 3rd March 2024
 INTERSECTIONALITY AND GENDER DYNAMICS IN SUCCESSION
LAW UNDER UCC

While it's widely recognized that personal laws have gender-related issues, it's important to
note that this perspective hasn't always been prominent. In its 2018 Consultation Paper, the
Law Commission challenged three common assumptions regarding personal laws. The
Commission highlighted positive aspects of Muslim law, such as the concept of mehr and the
limitation on willing away property to ensure inheritance rights for women, including
daughters. It also criticized discriminatory elements within Hindu family law, advocating for
the abolition of the Hindu Undivided Family and the right to ancestral property through
coparcenary.

Contrary to the idea that secularism should override pluralism, the Commission argued that
national integration isn't furthered by a Uniform Civil Code (UCC) when cultural diversity is
integral to people's identities and the nation's territorial integrity. It emphasized promoting
gender equality within each religious community rather than seeking uniformity between
them, identifying discrimination rather than mere difference as the root cause of inequality.

Recognizing the constitutional protection and autonomy of tribal communities in Sixth

Schedule states, the Commission advocated for preserving their distinct family law systems.
It suggested implementing gender-just reforms from within these communities rather than
imposing changes from external sources. In several regions in the northern and western parts
of society, daughters are often pressured into relinquishing their ancestral property rights in
favor of their brothers through documents known as relinquishment deeds, commonly
referred to as 'haq tyaag' in Punjab, Haryana, and Rajasthan. 12These patriarchal social norms
undermine legal provisions guaranteeing equal property rights to daughters.13

Drawing inspiration from Muslim law, which limits the portion of property that can be willed
away to not more than one-third, the Law Commission recommended in 2018 that all family
laws should specify a portion reserved for dependents of the deceased, and prohibit the entire
property from being willed away. The Commission also observed that individuals with
disabilities, particularly women, are often denied their inheritance rights either directly (by
exclusion from wills) or indirectly (by not receiving their rightful share of the property),

12
Saumya Uma, ‘What a Gender-Just Uniform Civil Code Could Look Like’(TheWire, 23 July 2023)
<https://thewire.in/law/what-a-gender-just-uniform-civil-code-could-look-like > accessed on 2 nd March 2024
13
Saumya Uma, ‘What a Gender-Just Uniform Civil Code Could Look Like’(TheWire, 23 July 2023)
<https://thewire.in/law/what-a-gender-just-uniform-civil-code-could-look-like > accessed on 2 nd March 2024
which necessitates legal intervention. Regarding the distribution of property in cases of
intestate succession (when someone dies without a valid will), each family law follows a
distinct scheme. The Law Commission proposed in 2018, based on the principle of proximity
to the deceased, a classification of heirs into three classes:

1. Class 1 - spouse, children, grandchildren of pre-deceased children, and parents of the

deceased.

2. Class 2 - siblings, nieces/nephews (if the sibling is deceased), and grandparents.

3. Class 3 - other relatives.

Under this scheme, all surviving Class 1 heirs would inherit the property equally, with one
share each; property would devolve to Class 2 heirs only if no Class 1 heirs exist, and so
forth. The proposed scheme aims to be gender-neutral, treating biological, adopted, and
surrogate children equally, without distinction between legitimate and illegitimate children.

In an undivided Hindu family, the father is the head of the household; in the event of his
death, his son succeeds him as head of the household; if the son is a minor, the mother takes
on the role of guardian, denying his wife or daughter the opportunity to succeed him as head
of the household. In a society where women are not afforded the same possibilities for
empowerment and education, gender equality is a barrier.

The Hindu Succession Act (HSA) now recognizes the husband's family as the deceased wife's
primary heirs, with the wife's own parents and siblings as her secondary heirs. The Law
Commission addressed the problem of heir equality and a woman's self-acquired property in
its 2008 reports, the 204th and 207th of which called for reforming Hindu inheritance laws.14

While this summary is not exhaustive, it provides an overview of the recommendations put
forth by the Law Commission. For instance, in Uttar Pradesh, the UP Zamindari Abolition
and Land Reforms Act15 governs land rights regardless of the religious affiliation of the
landholder.

In contrast to Hindu law, Muslim law doesn't differentiate between movable and immovable
property and doesn't recognize the concepts of self-acquired and ancestral property.
Additionally, there are variations between Shia and Sunni laws, with inheritance only
14
Aneesha Mathur, ‘From marriage to adoption, how Uniform Civil Code could subsume personal laws across
religions’, (IndiaToday, 29 June 2023) < https://www.indiatoday.in/law/story/uniform-civil-code-subsume-
marriage-divorce-succession-adoption-inheritance-2399376-2023-06-29> accessed on 3 rd March 2023
15
The Land Reforms Act, 1950
applicable upon the death of the property holder. 16 In Sunni law, heirs are categorized into
heirs by affinity (spouse) and heirs by blood relations (parents, children, siblings, etc.), with
inheritance based on predefined shares determined by the law. If these primary heirs are
unavailable, inheritance follows the male line, with brothers and uncles as heirs.

Among Shias, primary heirs include spouses, while other relatives are also designated heirs.
The Law Commission's 2018 recommendation proposed codifying Muslim inheritance law to
clarify and define heirs, as well as to address disparities in the shares of property inheritable
by each type of heir.

RELIGIOUS INLFUENCE ON SUCCESSION LAWS

HINDUS

16
Aneesha Mathur, ‘From marriage to adoption, how Uniform Civil Code could subsume personal laws across
religions’, (IndiaToday, 29 June 2023) < https://www.indiatoday.in/law/story/uniform-civil-code-subsume-
marriage-divorce-succession-adoption-inheritance-2399376-2023-06-29> accessed on 3 rd March 2023
Succession laws for Hindus in India are governed by specific statutes that delineate the
inheritance of assets and the allocation of shares among heirs. Notably, the succession
process varies depending on the gender of the deceased individual.

In the case of a Hindu male who dies intestate (without a will), his assets are typically
inherited by his immediate family members, comprising his mother, wife, son, daughter, and
grandchildren (if the children are deceased). These individuals constitute the first class of
heirs and generally inherit equal shares of the assets. Given any of the heirs in the first group
are unavailable the next option courst will explore is to look for other classes of heirs that
could inherit the assets that are left. The next ones consist of the father of departed, his / her
siblings, and other even more distant relatives, who are to receive inheritance only when there
are no heirs from the above categories.
For the case of married Hindu women, on the other hand, her husband and children are
allotted in receiving her possessions. Heirs of his husband are next (after him) and then
comes the case of her parents. Her father’s and mother’s heirs are next in line
respectively. Inter alia, the property belonging to a wife under the Hindu Succession Act
distinctly varies according to the provisions she is provided by the husband as well as her
father as per the Hindu Succession Act.
The fact that the heirs must be delineated and assets have to be distributed with males and
females treated separately shows that the Hindu Succession Laws are based only on gender
while there are different rules according to gender. It, in this connection, points out the level
of intricacy and complexity which have been positioned in the Indian legal system as
concerns years of inheritance among Hindu families.

MUSLIMS

Under the mastery of succession laws of Muslims, otherwise known as the Sunni Hanafi fiqh,
assets of the decedent ought to be distributed according to a certain structure which is not
open to dispute in the absence of a proper will.
In case a Muslim passes on without a will guiding, his/her inheritance is dispatched in a
specified manner for the heirs. These heirs are categorized into distinct groups: "nations,"
"incestuous and less-confident neighbors," and "mysterious and weak kinfolk." Advisers in
the role of trust executors are primarily family members, who include parents, spouse and
grandparents, and in that order, they inherit the property, while disproportionately so
depending on the specific situation. They ought to receive a part of the divide prior to the
others can have.
Because starting with the deceased sharers who are the possible sharers, the next inheritors of
the remaining assets are the residaries, another group of heirs. Along with these proximity
respite areas, there could be residuaries composed of other relatives or people who are not
part of the primary group. However, if any surviving heirs in either the sharers or the
residuaries are missing, the assets will be transmitted to distant relative (not blood) kindreds
and they are then inheriting as a result of the laws applicable in Muslim succession. The most
important factor to consider in making decisions on entitlement is to know all the possible
heirs of the person who passed on. This includes listing down their exact entitlements. This
structure is guarantee as it is creating order in the logic of asset distribution among the
beneficiaries by the means of Islamic principals of inheritance.

CHRISTIANS

The Indian inheritance Act (ISA), with respect to the Christians, states the dispersal of the
assets among the heirs, in case where an individual is passed away without leaving a
will. After the death of the testator, the heirs can only inherent upon the fulfillment of the
prerequisites implied in the will, such as spouse, children, grandchildren, parents, and other
relatives.
It is the usual practice that the surviving spouse inherits one-third of the property, while the
rest two-thirds are equally devised among children. If no one is there to raise children, people
cannot pass the inheritance down to them. Nevertheless, in the situation when the survivor
bears all the inheritance assets alone, the law regulates who will take possession of the
property.
In alignments where there are no children or future generations to succeed, one surviving
spouse gets fifty percent from the property and the other half is given to the surviving person
who is related and is from what is commonly called "kindred." This person being related to
the predecessor through a common ancestor or through the fact that they have a similar
lineage. The giving of this half- share all among kindred groups also varies the other clans
that are directly involved. However, the deceased's father will inherit his share plus the shares
designated to the kindreds (i.e. half of the kindredit share). Should the father be dead, and the
mother, however, together with the siblings survive, they will share the share exactly equally.
These regulations bears the testimony of how intricate the inheritance issues is for Christians
in India that were enshrined to give a level play ground to any of the living heirs regardless of
their own personal familial situation.

ANALYSING THE UTTARAKHAND UNIFORM CIVIL CODE BILL

2024

The implementation of the Uniform Civil Code (UCC) in Uttarakhand is a considerable

change from the traditional personal rules controlling marriage, divorce, and inheritance for
Hindus, Muslims, and Christians.17 Its effect on inheritance rules, in particular, is significant,
with consequences for gender equality and legal uniformity.18

The Uniform Civil Code (UCC) implemented in Uttarakhand makes significant modifications
to inheritance laws for religious communities, including Hindus, Muslims, and Christians.
Here's a quick breakdown of how the UCC affects each group:

TO HINDUS

1. The Elimination of Property Distinction- The UCC eliminates the conventional distinction
between ancestral and self-acquired property, guaranteeing equal rights to both types of
assets to all legal heirs.
2. Revisions to Intestate Succession- In circumstances of intestate succession, both parents
are promoted to Class-I heirs, providing gender-neutral inheritance rules and supporting
equitable inheritance distribution.19

TO MUSLIMS

1. Eliminating Fixed Shares- The UCC abolishes old Islamic law's set shares, allowing for
equal property distribution among successors and giving Muslim women equal inheritance
rights.
2. Introduction to New Succession Rules- The UCC establishes a fundamental framework for
intestate succession within the Muslim community, moving away from rigid adherence to
fixed shares and attempting to remedy past imbalances in inheritance.20

TO CHRISTIANS

1. Equal Treatment of Widows- Widows are designated as Class-I heirs, with an equal part of

17
Economic Times Wealth, “Uttarakhand’s UCC Changes Inheritance Laws: Who Is Covered and How It
Impacts Individuals Living in Other Parts of India” (2024) Economic Times.
18
LiveLaw, “How Uttarakhand Uniform Civil Code Impacts Hindu, Muslim, and Christian Succession Laws”
(2024) LiveLaw.
19
Rakshita Goyal, Surbhi Sachdeva, “Uttarakhand Civil Code: The Key Changes for Hindus and Muslims in
Marriage & Inheritance” (February 7, 2024) The Indian Express.
20
Rakshita Goyal, Surbhi Sachdeva, “Uttarakhand’s Landmark Move: Decoding the Uniform Civil Code
(UCC)” (February 28, 2024) King Stubb & Kasiva Regulatory.
the deceased's property as other heirs, providing fairness and equity in inheritance
distribution.
2. Recognition of Parental Rights- Parents are awarded Class-I legal heir status, which
recognises their right to a share of the deceased's property and promotes familial equity in the
Christian society.

INTEREST OF THE QUEER COMMUNITIES IN THE UTTARAKHAND UCC BILL

The UCC Bill appears to accommodate the interests of the queer community in some way by
recognising transgender people as the "third gender" under the law. However, there are
ongoing concerns over how inheritance provisions apply to transgender people. The bill's
ongoing use of gendered terms such as "husbands," "wives," "fathers," and "mothers" may
fail to adequately accommodate the gay community's multiple identities.21

Transgender people may encounter difficulties inheriting property under the UCC Bill if they
are obliged to conform to the gender given to them at birth, whether male or female. This
approach overlooks transgender people's unique experiences and identities, and it may fail to
appropriately protect their inheritance rights. There is a need for clearer measures in the UCC
Bill to ensure that transgender people are treated equally in inheritance concerns, regardless
of gender identification.

UTTARAKHAND UCC BILL V CENTRAL LAWS

In the event of a discrepancy between provisions of the Uttarakhand Uniform Civil Code
(UCC) and central government legislation on inheritance, the question of which law takes
precedence is determined by many factors:

1. Concurrent List of the Constitution- The concurrent list of the Constitution includes issues
such as marriage, divorce, adoption, wills, intestacy, and succession. This means that both
state and federal governments can pass legislation on these issues. As long as there is no
direct conflict between the provisions of state and central laws, state law will take
precedence.

2. Article 254 of the Constitution22- Article 254 of the Constitution provides the primacy of
central laws in situations when state and central legislation conflict in areas mentioned in the
concurrent list. For Hindus and Christians whose inheritance rules are established in central
laws such as the Hindu Succession Act and the Indian Succession Act, central laws shall take
precedence over UCC provisions that clash. This is because codified laws are supreme in
their respective professions, providing legal uniformity and consistency.

3. Muslim Intestate Succession-In the lack of a central codified law governing Muslim
inheritance, the rules of the UCC will apply. There is no unique national regulation
concerning Muslim inheritance, hence the UCC laws would prevail
21
Rakshita Goyal, Surbhi Sachdeva, “Inheritance in Uttarakhand UCC: What do Hindus, Muslims, and
Christians gain or lose?” (February 8, 2024) The Indian Express.
22
Constitution of India, art 254 (1950).
 CONCLUSION

A consideration of intersectionality in succession law, namely the interaction of religion,

gender, and the Uniform Civil Code (UCC), demonstrates the complex processes that shape
inheritance rights in India. Personal rules governing succession have historically mirrored
strongly ingrained patriarchal attitudes and religious rituals, leading in systemic disparities
that disproportionately affect women.23 However, recent developments, such as the
implementation of the UCC in Uttarakhand, represent a considerable divergence from
traditional inheritance norms, with the goal of promoting gender equality and legal
uniformity among religious communities.
The Uttarakhand Uniform Civil Code (UCC) makes significant modifications to inheritance
laws for Hindus, Muslims, and Christians. This provision demarcates no such a distinction
between ancestral and individually owned property and dictates the inheritance rules to be
gender-neutral. Therefore, one gets the evenly distributed share of the assets the deceased has
left behind.
On the contrary, the chance of having a mismatch between the UCC needs and the inheritance
law of the central government brings the question of legal precedence that needs to be clear to
all parties. Hence, it is indispensable that clearly authorized legislation discloses conflicting
issues.

Though giving a ground for the UCC in achieving the gobl of gender equality and justice in
the context of inheritance rights, there are concerns about the possibility of converting
ancestors from various religious practices and beliefs. Controversy on the UCC open a door
to many debates which involve various questions like these: about secularism, cultural
pluralism and individual rights.24

More so, UCC Bill in its attempt to serve and protect the whole LGBTI community should be
more inclusive and accepting of transgender people, thus equality and fairness in inheritance
matters are upheld. For instance, the language and lexicon may be altered by being more
gender-neutral and its role could be inclusive not only to those of the opposite-sex but also to
gender identities. In addition, the inheritance can be administered fairly and equitably among
individuals regardless of their gender identity or expression.

Here coming, of course, there is a need to remain careful while legal reforms are
implemented, being aware of constitutional matters of equal treatment, preserving freedoms
of various religions and being sensitive towards cultural and philosophical values.

23
Meyers, Diana Tietjens, 'Gender Identity and Women's Agency: Culture, Norms, and Internalized Oppression
Revisited', Gender in the Mirror: Cultural Imagery and Women's Agency (New York, 2002; online edn, Oxford
Academic, 1 Nov. 2003)
24
Puniyani, Riya, Uniform Civil Code and Conflicts of Personal Laws (July 4, 2020).