Uniform Civil Code - One Nation, One Law (Research Paper)
Uniform Civil Code - One Nation, One Law (Research Paper)
Uniform Civil Code - One Nation, One Law (Research Paper)
On
By:
[Chandigarh University]
Page | 1
ACKNOWLEDGEMENT
In the present competitive world, the one who have a will to come forward succeeds. With
this will I came forward to carry out this research. Firstly, I would thank the Supreme
Almighty without whose grace this research couldn’t be possible that too in the times of this
pandemic where no one knows how much life one has. I am greatly indebted to My Parents
also who have brought me up to this stage with sheer encouragement. Also, I am highly
obliged to THELAWSEEKERS for providing me this opportunity and my sincere thanks for
their generous attitude and friendly behaviour. Last but not the least I am thankful to my all
friends and each and every person who have helped me and guided me in all this research
work.
Page | 2
DECLARATION
I hereby declare that this research work entitled “UNIFORM CIVIL CODE – One Nation,
One Law” is my own work and to the best of my knowledge and belief it contains no material
previously published or presented by any other person/party in any form except where due
acknowledgement is made in the text. This information is purely of academic interest.
{Chandigarh University}
Page | 3
Page | 4
TABLE OF CONTENTS
Index of Authorities 5
List of Abbreviations 6
Scope 7
Limitations 8
Literature Survey 9
Research Questionnaire 10
Chapterization 12
Abstract 13
Introduction 14
Chapter:1 (What is Uniform Civil Code) 16
Chapter:2 (UCC under British Raj) 18
Chapter:3 (UCC during the time of 21
Independence)
Chapter:4 (Current Scenario of UCC) 24
Chapter:5 (Importance of UCC) 26
Chapter:6 (Political Debates over UCC) 27
Author’s View 29
Conclusion 30
Bibliography 31
Page | 5
INDEX OF AUTHORITIES
Table of Cases:
Books Referrd:
Lawmann’s Constitution Of India, 1950
Websites:
https://indiankanoon.org
https://.indiatvnews.com
https://www.timesnownews.com
https://www.newindianexpress.com
https://www.thehindu.com
https://mea.gov.in
Page | 6
LIST OF ABBREVATIONS
& And
Vs. Versus
SEC. Section
ART. Article
i.e. That is
W/O Without
SC Supreme Court
Page | 7
SCOPE
The issue of UCC has always been in headlines since India got its independence. During that
time founding fathers of Indian Constitution believed that Indian people were not in that state
to accept Uniform Civil Code. But with the modernization, our people tend to think vast and
above the level of traditional customs & beliefs. That’s the reason I believe that now it has
started been included in the election manifestos as well. The present ruling party aims at
implementing Uniform Civil Code for the better & progressive society.
Page | 8
LIMITATIONS
These lies no doubt when we say that Uniform Civil Code is a sensitive issue which needs to
be dealt very carefully without being too diplomatic keeping in mind that India is a secular
country with the diverse culture and religious sentiments. UCC should be implemented in
such a way that no group/community feels that they have been neglected or misguided.
Page | 9
LITERATURE SURVEY
The concept of Uniform Civil Code has earlier many times been researched & discussed by
various persons, scholars, activists etc. with different perspectives and with the help of
those previous researches this research paper is made by properly acknowledging their
work as well wherever required and also stating my own viewpoints at various dimensions.
This research paper covers the topic of UCC from each and every aspect. It also talks about
whether UCC has become a political weapon for politicians or is it really in the best
interests of the society itself.
Page | 10
RESEARCH QUESTIONNAIRE
1. Do you think Uniform Civil Code is beneficial for a diverse country like India?
(YES/NO)
2. Will the people of other states too follow UCC like in Goa? (YES/NO)
3. Do you think that Uniform Civil Code if implemented will be a threat to the minority
communities? (YES/NO)
4. Will UCC be able to curb the differences between diverse personal laws? (YES/NO)
6. Do you think a diverse nation like India be fully free from religious discrimination
ever? (YES/NO)
8. Will this new social reform definitely bring diverse religious cultures together?
(YES/NO)
9. Is Uniform Civil Code better than all other personal laws? (YES/NO)
Page | 11
10. Will the implementation of Uniform Civil Code be violation Article 25 1 and Article
262? (YES/NO)
1
25. Freedom of conscience and free profession, practice and propagation of religion
(1) Subject to public order, morality and health and to the other provisions of this Part, all persons are equally
entitled to freedom of conscience and the right freely to profess, practise and propagate religion
(2) Nothing in this article shall affect the operation of any existing law or prevent the State from making any
law
(a) regulating or restricting any economic, financial, political or other secular activity which may be associated
with religious practice;
(b) providing for social welfare and reform or the throwing open of Hindu religious institutions of a public
character to all classes and sections of Hindus Explanation I The wearing and carrying of kirpans shall be
deemed to be included in the profession of the Sikh religion Explanation II In sub clause (b) of clause reference
to Hindus shall be construed as including a reference to persons professing the Sikh, Jaina or Buddhist religion,
and the reference to Hindu religious institutions shall be construed accordingly
2
26. Freedom to manage religious affairs Subject to public order, morality and health, every religious
denomination or any section thereof shall have the right
(a) to establish and maintain institutions for religious and charitable purposes;
Page | 12
CHAPTERIZATION
Abstract
Introduction
Author’s view
Conclusion
Bibliography
Page | 13
ABSTRACT
Though there are multiple views on this topic of such social reform, Uniform Civil Code but
still I feel that it should be analyzed to find its true meaning, its origin and how it should be
implemented in our country. I also feel that Indian government and its citizens should pay
more attention to it as it was our founding fathers dream to implement one civil law for all
and they added it to our constitution under Article 443.
3
44. Uniform civil code for the citizens The State shall endeavour to secure for the citizens a uniform civil code
throughout the territory of India.
Page | 14
INTRODUCTION
Uniform Civil Code connotes the idea of one nation one law, governing everyone under same
civil law regardless of their religion, caste, sex, etc. Uniform civil law is a great solution to
eradicate all the flaws of personals laws. The feeling of oneness and brotherhood will boost
up the integrity of nation will also stronger the judicial system.
The idea of bringing uniform civil code is not new, in pre-independence era the founding
fathers of the constitution were debating over the uniform set of laws to govern everyone.
Some great leaders who were in favor were Pt. Jawaharlal Nehru, Dr. B.R. Ambedkar and
other women activists, while some Muslim politicians and high officials of some other
religions were strictly opposing it. Many committees were formed but was put down by the
opposition every time. Thus the dream of unifying the nation under one set of laws was not
fulfilled.
Even after 73 years of independence, India still hasn’t been able to make one set of civil laws.
But the topic of Uniform Civil Code has currently come into limelight, Bharatiya Janata Party
the ruling party is trying to bring UCC into action. BJP is the first political party to promise
in their manifesto to implement Uniform civil law if they come in power. In the past two
years the bill has been brought up twice in parliament but rejected even before introducing
both time. BJP is still trying to bring set of civil laws that will govern everyone.
The biggest plus point of implementing UCC is that it will bring gender biasness and
eliminate discrimination. The diversity of culture in India has been the reason for personal
laws for every religion. Even though the personal laws are based on the traditions, customs
and rituals; we cannot ignore the fact that women are still discriminated and exploited in the
name of their religious personal laws. Many people take advantage of the loop holes on the
personal laws and disturb the peace of other communities (women and children). Uniform
Civil Code has other advantages like ease on governance, boost in the integrity of nation,
brotherhood and unified set of laws will remove religious discrimination. Thus the true
essence of law will be followed, to view everyone with the same eye and keeping everyone
on the same platform.
Page | 15
Uniform Civil Code is not only about integrity and brotherhood , since every coin has two
sides UCC has its drawbacks also. It might pose a threat to minorities, that they will have to
discontinue their old beliefs and rituals, and follow the codified laws. It may also raise a
sense of inter religion rivalry, as Muslims and other religions might think that they are being
forced to follow and pursue Hindu religion. This might result in riots and strikes all over
nation.
Page | 16
Chapter: 1
UCC i.e. Uniform Civil Code is expressed as one country with one set of laws which is to be
applied to all religious communities. It is a proposal to govern every citizen under one code
of law irrespective of their religion. India being a mixture of a very diverse culture, requires a
uniform civil law which contains laws regarding marriage, divorce, guardianship, adoption
and succession. Since many religions preside over India it gets very difficult for law officials
to govern them and give justice to each and every one. UCC brings integrity and oneness to
the table. Different religions have different cultures and rituals which they follow, and that’s
the problem which UCC will solve. It will remove all the inter-religious differences and unit
them as one.
The code comes under Article 44 of the Indian constitution, which reads that;
“The state shall endeavor to secure for the citizens a uniform civil code
This means that it is the duty of the state to create one unified law which is applicable to all.
This has been the center of many political debates and is also mentioned in the 2019
Page | 17
manifesto of Bharatiya Janata Party4. Its origin starts way before independence in the British
era and has faced many hurdles over the years.
4
http://library.bjp.org
Page | 18
Chapter: 2
All the idea of uniform civil law started when Lord William Bentinck, by passing a social
reform abolished sati,
5
The Bengal Sati Regulation, or Regulation XVII, in India under East India Company rule, by the Governor-
General Lord William Bentinck, which made the practice of sati or suttee illegal in all jurisdictions of India and
subject to prosecution.
Page | 19
In 1835: it was in this year when 2nd Law Commission report6 was filed in which it was
suggested that there should be uniformity in the civil laws for whom, who had no laws of
their own. But it was mentioned that there will be no attempts made to make one codified law
for Hindus and mohammadeans, because it might portray as a threat to their religious beliefs.
In 1840: The lex loci report was published, it laid stress on the uniformity in the criminal,
contract and contract laws without the religious interference. But they stayed away from the
personal laws as they don’t want to hinder with their beliefs, customs and religious rituals.
In 1858: The Queen Victoria’s Proclamation. After EIC gave the power in Queen’s hands to
govern and rule over India, this proclamation was signed in which it was particularly
mentioned that there will be no interference of any kind and will provide a benefit of self-
governing in their domestic and religious matters. But all the criminal cases will be governed
by them regardless of their religion. In the proclamation it was said that;
https://lawcommissionofindia.nic.in
7
The Hindu Widows' Remarriage Act, 1856, also Act XV, 1856, enacted on 26 July 1856, legalised the
remarriage of Hindu widows in all jurisdictions of India under East India Company rule. It was drafted by Lord
Dalhousie and passed by Lord Canning before the Indian Rebellion of 1857. It was the first major social reform
legislation after the abolition of sati by Lord William Bentinck.
8
The Indian Christian Marriage Act of 1872 is an act of the Parliament of India regulating the legal marriage of
Indian Christians. It was enacted on July 18, 1872, and applies throughout India, excluding territories such as
Cochin, Manipur and Jammu and Kashmir.
Page | 20
In 1874: Married Women’s Property Act9
These reforms not only helped in codifying the law but also empowered women community
and ensured their economic safety.
In 1933: In the All India Women’s Conference11 (AIWC), the officials were demanding equal
rights and uniformity in civil laws which can be done by replacing the current laws for
women upliftment and gender equality. It was starting of a women’s revolutionary
community.
In 1937: Pressure from the Muslim elites was building up, due to which the Sharia Law 12was
passed and all the Indian Muslims were to be governed under this law. This law was highly
inspired by their beliefs, customs and rituals. The Sharia Law contains law regarding
marriage, divorce, maintenance, succession and inheritance.
In 1941: Many arguments and debates were going on due to the increase in personal laws.
And due to which a committee was formed called the B.N. Rao Committee13. It’s goal was to
codify and reform the Hindu personal law. This committee after months of research
concluded that there should be codified Hindu law which would give equal rights to all Hindu
men and women irrespective of their castes. Discussions were made and many Hindu
9
The Married Women's Property Act 1870 was an Act of Parliament of the United Kingdom that allowed
married women to be the legal owners of the money they earned and to inherit property.
10
The Hindu Succession Act, 1956 is an Act of the Parliament of India enacted to amend and codify the law
relating to intestate or unwilled succession, among Hindus, Buddhists, Jains, and Sikhs. The Act lays down a
uniform and comprehensive system of inheritance and succession into one Act. The Hindu woman's limited
estate is abolished by the Act. Any property possessed by a Hindu female is to be held by her absolute
property and she is given full power to deal with it and dispose it of by will as she likes. Parts of this Act was
amended in 2005 by the Hindu Succession Act, 2005.
11
The All India Women's Conference is a non-governmental organisation based in Delhi. It was founded in
1927 by Margaret Cousins in order to improve educational efforts for women and children and has expanded
its scope to also tackle other women's rights issues. The organisation is one of the oldest women's groups in
India and has branches throughout the country.
12
Sharia is a religious law forming part of the Islamic tradition. It is derived from the religious precepts of Islam,
particularly the Quran and the hadith. In Arabic, the term sharīʿah refers to God's immutable divine law and is
contrasted with fiqh, which refers to its human scholarly interpretations. The manner of its application in
modern times has been a subject of dispute between Muslim fundamentalists and modernists.
13
The Constitutional Adviser, B.N Rau compiled reports of various committees to prepare a Draft Constitution
which he submitted to the Drafting Committee. Decision making in the committees was on the basis of a
majority vote and members could record their dissents to decisions taken if they wished.
Page | 21
conservatives, politicians, organizations and devotees were opposing it which resulted in
lapsing of the draft
Chapter: 3
After India got independence and British gave all the control of governance back in Indian
hands, it was the first duty of the government to establish rules and regulation for proper
working of the country. So,
In 1947: India got Independence and the first Prime Minister Pt. Jawaharlal Nehru and other
members wanted to have a Uniform civil code. While the first President Dr. Rajendra Prasad
opposed the reform. And thus this bill was denied again.
Page | 22
In 1949: The constitution of India was enacted and Article 44 was added as Uniform Civil
Code under Directive Principles of State Policy14 i.e. as a duty for the government to make a
unified set of civil laws when the time is right and when the society demands for it. Many
criticism was faced by the founding fathers, that why it has been put under DPSPs and not
under Fundamental Rights.
In 1949-1951: The B.N. Rao committee’s draft was resubmitted and was put into
consideration. A new committee was formed under the chairmanship of Dr. B.R. Ambedkar,
and this committee made a number of changes in the previous draft. He mentioned Hindu
laws regarding maintenance, succession, adoption, inheritance, marriage, divorce and
guardianship in his draft. He also added laws regarding joint-family property, property rights
of women, which led to rise of a new wave of women rights in society. This draft was called
the Dr. Ambedkar Draft but besides having things altered it faced criticism and people were
opposing it.
In 1951-1952: First-general Elections were held in which Indians National Congress won as
Jawaharlal Nehru as their Prime Minister. Nehru being a supporter of UCC made Hindu Bill
Code (B.N. Rao Draft) as their campaign’s initiative.
In 1952-1956: Dr. Ambedkar’s draft was still facing opposition. So Nehru decided to divide
the draft into four parts and he get it passed having lesser criticism than the previous draft.
The Four Acts Passed were:
14
Part IV of the Constitution of India (Article 36–51) contains the Directive Principles of State Policy (DPSP)
15
The Hindu marriage Act is an Act of the Parliament of India enacted in 1955. Three other important acts
were also enacted as part of the Hindu Code Bills during this time: the Hindu Succession Act, the Hindu
Minority and Guardianship Act, the Hindu Adoptions and Maintenance Act.
16
The Hindu Minority and Guardianship Act was established in 1956 as part of the Hindu Code Bills. Three
other important acts were also created during this time and they include the Hindu Marriage Act, the Hindu
Succession Act, and the Hindu Adoptions and Maintenance Act. All of these acts were put forth under the
leadership of Jawaharlal Nehru, and were meant to modernize the then current Hindu legal tradition. The
Hindu Minority and Guardianship Act of 1956 was meant to enhance the Guardians and Wards Act of 1890,
not serve as its replacement. This act specifically serves to define guardianship relationships between adults
and minors, as well as between people of all ages and their respective property.
Page | 23
The Hindu Adoption and Maintenance Act, 195617
In 1954: With the dream to govern India under one law, a big step was taken towards unified
civil law by making and passing of The Special Marriage Act18. By this act, a person who has
renounce their religion can legimatise their marriage and will be governed under this law.
Any person can marry under this law irrespective of their religion. Many flaws were there in
the beginning but with time amendments were made.
In 1985: In this year a landmarks case was made namely Muhammad Ahmed Khan vs.
Shah Bano Begum, 198519. This case put the light on the lack of attention given to reform on
Muslim law. This case got caught up in the limelight by the media. The judgment was passed
in favor of Shah Bano, accepting her plea of maintenance. The Supreme Court asked for a
uniform civil law from the parliament but no response was given in such matter.
In 1986: Due to Shah Bano case, Muslim officials were demanding for their own personal
law on maintenance which resulted in passing of Muslim Women (Protection on Rights of
Divorce) Act20. This act forbids the applicability of section 125 of CrPC 21 about maintenance.
Many female activists were opposing this but with judgments the true meaning of the act was
delivered.
17
The Hindu Adoptions and Maintenance Act was enacted in India in 1956 as part of the Hindu Code Bills. The
other legislations enacted during this time include the Hindu Marriage Act, the Hindu Succession Act, and the
Hindu Minority and Guardianship Act. All of these acts were put forth under the leadership of Jawaharlal
Nehru, and were meant to codify and standardise the current Hindu legal tradition. The Adoptions and
Maintenance Act of 1956 dealt specifically with the legal process of adopting children by a Hindu adult, and
with the legal obligations of a Hindu to provide "maintenance" to various family members including their wife
or parents, and in-laws.
18
The Special Marriage Act, 1954 is an Act of the Parliament of India with provision for civil marriage for
people of India and all Indian nationals in foreign countries, irrespective of the religion or faith followed by
either party. The Act originated from a piece of legislation proposed during the late 19th century. Marriages
solemnized under Special Marriage Act are not governed by personal laws.
19
[(1985) 2 SCC 556 : 1985 SCC (Cri) 245]
20
The Muslim Women Act was a controversially named landmark legislation passed by the parliament of India
in 1986 to allegedly protect the rights of Muslim women who have been divorced by, or have obtained divorce
from, their husbands and to provide for matters connected therewith or incidental thereto. The Act was
passed by the Rajiv Gandhi government to nullify the decision in Shah Bano case. This case caused the Rajiv
Gandhi government, with its absolute majority, to pass the Muslim Women Act, 1986 which diluted the secular
judgment of the Supreme Court and, in reality, denied even utterly destitute Muslim divorcees the right to
alimony from their former husbands. The law applies to the whole of India except Jammu and Kashmir. It is
administered by any magistrate of the first class exercising jurisdiction under the Code of Criminal Procedure,
1973. As per the Act, a divorced Muslim woman is entitled to reasonable and fair provision and maintenance
from her former husband and this should be paid within the period of iddah. The Statement of Objects and
Reasons of this Act needs a mention.
21
Section 125 of CrPC is meant to achieve a social purpose that is to prevent vagrancy, destitution, and
poverty. It provides a speedy remedy for the supply of food, clothing, and shelter to the deserted wife.
Page | 24
Page | 25
Chapter: 4
In 2015: Delhi High Court in Satprakash Meena vs. Alka Meena22 case urges to law ministry
to bring Uniform Civil Code to govern everyone under one law. The Diversity of India is our
pride but they should be governed under one law like other criminal laws. High Court said
that UCC shouldn’t remain a mere hope in constitutional and has remained an unaddressed
expectation.
In 2018: The Law commission of India in their 21st law Commission Report stated that;
They said in the report that UCC is not the need of the time but to review and recodify the
current existing personal laws is important.
In 2019-2020: In these years UCC bill was proposed twice in 2019 and 2020 but was soon
put down without being introduced due political difference between BJP and RSS.
BJP the ruling party has promised in their manifesto to bring Uniform Civil Code of law. By
bringing UCC in India it will provide easy governance, equality for women of every
community. The gender inequality will be eliminated as well.
22
C.R.P.1/2021 and CM APPL. 332/2021
Page | 26
Page | 27
Chapter: 5
IMPORTANCE OF UCC
The main objective of Article 44 of the Directive Principles of State Policy in the Indian
Constitution was to address the discrimination against minority communities and harmonise
diverse cultural groups across the nation. Dr. B R Ambedkar, while formulating the
Constitution had said that a UCC is desirable but for the moment it should remain voluntary,
and thus the Article 35 of the draft Constitution was added as a part of the Directive
Principles of the State Policy in Part IV of the Constitution of India as Article 44. It was
embedded in the Constitution as a task that would be fulfilled when the nation would be
ready to accept it and the social acceptance to the UCC could be made.
Dr. Ambedkar in his speech in the Constituent Assembly said that, "No one need be
apprehensive that if the State has the power, the State will immediately proceed to execute…
that power in a manner may be found to be objectionable by the Muslims or by the Christians
or by any other community. I think it would be a mad government if it did so."
Page | 28
Chapter: 6
This chapter highlights the controversial statements over the topic of Uniform Civil Code by
various political leaders which leads to political debates over such a sensitive national issue.
Uniform Civil Code is always highlighted as a controversial topic. The reactions of different
political leaders and ministers often clash among themselves over the issue of UCC. Several
political parties oppose the uniform civil code whereas some of them do favor it.
Many Muslim bodies opposed Uniform Civil Code while congress party said,
Whereas the ruling party asserted that UCC will be a good move towards a progressive
society. But the opposition accused that BJP is just trying to polarize the people in the name
of ahead of assembly polls in several states.
Earlier, AIMPLB opposed the law commission’s questionnaire on UCC, and also boycotted
the abolition of Triple Talaq. The former law minister and congress leader Verrappa Moiley
reacted to the same and said that,
personal laws”
But the ruling party BJP has always said that the aim of UCC is t build a progressive society.
BJP leader Sidharth Nath Singh even refers to some international declarations and countries
like Turkey, Iran and Indonesia who changed their law to ensure gender equality.
BJP ally Shiv Sena too opined over the UCC topic. Shiv Sena stressed that UCC should be
viewed as a National Issue rather than a Religious one. Shiv Sena leader Sanjay Raut said
Page | 29
that the Muslim law board should support the UCC as it will keep the whole community
especially women out of misery.
With debates over the subject widening, All India Majlis-e-Ittehadul Muslimeen (AIMIM)
leader Akbaruddin Owaisi added that bringing will kill the diversity of India.
Whereas union law minister, Ravi Shankar Prasad discussed the opposition’s claim of
polarisation in connection with UCC & stated that the Muslim law board must attend the
meeting of the law commissioner to discuss the meeting further.
Observing a diplomatic stand on the subject, NCP has stated the every community must get
equal treatment, but that the discussion should take place on a broader canvas, so that people
do not think of the UCC as an ‘onslaught on their rights.’ The implementation of UCC gained
momentum after the law commissioner sought public review on the subject to review and
reform personal laws. The debate over UCC turned extremely political with each passing day
several leaders representing their respective parties or religious bodies strongly voiced either
their opposition or support for the UCC.
Page | 30
AUTHOR’S VIEW
My personal view on UCC is that, it is a great step that can be taken for unifying the country
and embracing the feeling of brotherhood and oneness in the citizens. The UCC is the only
solution to the different judicial problems of separate personal laws, no proper governance,
gender biasness and inter-gender discrimination.
UCC helps in viewing the current judicial system with a different angle, it brings new
perspective that will eliminate all the loop holes and combine the best of all the personal
laws. The set of rules that will govern all the citizens irrespective of their religion, is the
Uniform Civil Code.
Currently many debates are going on whether UCC should be implemented or not. But the
main question that arises is that how it should be implemented. The way it should be
established and presented to general public is the main concern. I think India is not yet ready
to be governed under one codified civil law.
Page | 31
CONCLUSION
At the end it can be concluded that the Uniform civil code has its merits. The gender equality,
united India and the wholeness in its citizens. But what are those merits for if the society
doesn’t accept it. General public have to broaden their mind-set to completely use the
benefits of UCC. No one can say that it will be a perfect law, at first there will be ups &
downs but with time and patience everything will be on track. There is no doubt it will be a
great social reform if implemented, but the current position of India is not suitable for Unified
Civil Code.
Page | 32
BIBLIOGRAPHY
C. Lawmann’s. The Constitution Of India, 1950. 2017 edition. Kamal Publishers; 2017
D. https://lawcommissionofindia.nic.in
E. https://iascurrent.com/wp-content/uploads/
2020/10/2e07dbc9743dc0cd58fb37a5a4b7d424.jpg
F. https://img.jagranjosh.com/imported/images/E/GK/What%20is%20Uniform%20Civil
%20Code.png
G. https://thedispatch.blob.core.windows.net/thedispatchimages/
2021/07/2_05_38_02_ucc_1_H@@IGHT_330_W@@IDTH_745.jpg
H. https://img.freepik.com/free-vector/realistic-india-independence-day-illustration_23-
2148994902.jpg?size=338&ext=jpg
I. https://indiankanoon.org/doc/823221/
J. https://indiankanoon.org/doc/127592460/
K. https://www.legalservicesindia.com
Page | 33