YOUTH

PARLIAMENT
STUDY GUIDE
 INDEX
1. About the Committee and its Scope
2. What is a Uniform Civil Code?
3. Introduction to the Agenda
4. Important articles of the Constitution in relation to the
UCC
5. Government’s POV
6. Opposition’s POV
7. Merits of UCC
8. Criticism of UCC
9. Potential Moderated Caucus Topics
10. Further Reading and Research
 ABOUT THE COMMITTEE AND ITS SCOPE

With more than 2000 registered political parties in India, the politics of the nation
has been constantly changing. Typically called before the session of the parliament
or introduction of a bill, the All India Political Party Meets are conventions that
allow the diverse political groups of India to reach a consensus on decisions of
national importance, before sessions begin. With the absence of legislative power
of the parliament, the initial purpose of the forum was for unrestricted political
debate, discussion and deliberation which may not be allowed in parliament due to
time constraints. However, this body now aids in providing a better insight into
national issues. The agenda of such a meeting can vary depending on the purpose
and objectives of the event. Some of the topics that could be discussed in an All
India Political Parties Meet are issues pertaining to National Security, Economic
development, Social Issues and Political Reforms.
The AIPPM committee in MUN aims to mimic this reality by reproducing the
stages of policies and jurisdiction, with delegates representing personalities from
the divergent group of Indian political parties. While stepping into the shoes of
assigned politicians, the AIPPM committee expects its representatives to be well
versed with their political party’s ideology, manifesto and beliefs which helps the
representatives grasp the multi-layered processes that go behind policy-making and
governance in India, providing them with an explicit experience to the hitches and
hurdles that political parties accost in modern times. The AIPPM committee is
unlike any other conventional MUN committee and is characterized by heated
debates, cross talks, high levels of negotiations and political democracy that echoes
hopes of change and evolution!

WHAT IS A UNIFORM CIVIL CODE?

To put it in the easiest terms, a UCC is a term generally used to refer to the
proposal to replace the personal laws based on scriptures and practices of each
major religious community in India with a common set governing every citizen. As
of now, these personal laws still apply in a number of fields, including marriage,
inheritance, divorce, adoption, and maintenance. It is the embodiment of an
aspirational legal system of UNIFORMITY with the undertaking of every
communities’ personal interest.

INTRODUCTION TO THE AGENDA

India might have achieved its true Independence in 1947, however the foundation
of it began in 1935, provided to us via the Government of India Act, 1935. Later
On, in 1942, when a mission headed by Sir Stafford Cripps was sent to India with
Constitutional proposals, the entire thought around UCC and Communal Laws
began in India, with the British having an obdurate term for Minority Rights to be
protected by the Legislations (Laws) of the country. To
provide them with equality, the concept of equity was
used.

As you can see in the adjoined image, the concept of

Equality and Equity is differentiated upon in a simple way. To put in simple words.
Equality is like giving everyone the same-sized slice of cake, even if some people
are bigger than others. Everyone gets the same amount, but some people might not
get as much as they need.

Equity is like giving everyone the amount of cake they need, based on their size.
Some people might get a bigger slice, and some people might get a smaller slice,
but everyone will have enough to eat. Which is why, provisions and procedures
exist to protect minority rights and interests. Hence, specific laws were created for
specific communities to protect their rights and interests.

The UCC was proposed as Article 35 of the Draft Constitution - the strongest, most
vocal opposition was from Muslim leaders. Mohammad Ismail, member of the
Indian Union Muslim League, pushed for an addition that provided that “any
group, section or community of people shall not be obliged to give up its own
personal law in case it has such a law”. Nazir Ahmed argued that the very concept
of Uniform Civil Code clashed with the religious and cultural freedom guaranteed
to every citizen. A number of Hindu members of parliament expressed their
opinions to the contrary. KM Munshi argued that “Religion must be restricted to
spheres which legitimately appertain to religion, and the rest of life must be
regulated, unified and modified in such a manner that we may evolve, as early as
possible into a strong and consolidated nation.” He also added that a Uniform Civil
Code could be enacted by the state even in the absence of Article 35, as Article 25
of the Constitution (guaranteeing religious freedom) also gave the state the power
to secularize practices. The Assembly, however, finally passed Article 44 in the
Directive Principles of the Constitution. The Directive Principles are not
conventional laws in the sense that they are not enforceable by any court, but are
seen as fundamental in the governance of the country, making it the duty of the
state to apply these principles while making laws to ensure a just society.

Article 44. Uniform civil code for the citizens —The State shall
endeavor to secure for the citizens a Uniform Civil Code
throughout the territory of India.
Muslim leaders were particularly worried about this, seeing it as dangerous to their
freedoms in the future as a minority. B.R. Ambedkar, addressing their concerns,
said that this created a “power” and not an “obligation”. He added that
“Sovereignty is always limited, no matter even if you assert that it is unlimited,
because sovereignty in the exercise of power must reconcile itself to the sentiments
of different communities.”

Prominent women leaders criticized the move, seeing it as insufficient. By making

it a Directive Principle rather than a law in itself, it seemed to them that the state
was leaving the state with an option not to enforce it at all.

But, what would a UCC even look like? For Example,

IPC Section 494 - Marrying again during the lifetime of husband or wife. —
Whoever, having a husband or wife living, marries in any case in which such
marriage is void by reason of its taking place during the life of such husband or
wife, shall be punished with imprisonment of either description for a term which
may extend to seven years, and shall also be liable to fine.

Basically a person can only marry once in their lifetime, unless

1. They get divorced
2. Their Husband/ Wife dies
If you remarry without satisfying any of the above mentioned provisions, you shall

face prison for up to 7 years and/or will be subjected to a certain amount of fine.

However, it is not the same for everyone.

The aforementioned law is applicable to Hindus, Sikhs and Christians but not to
Muslim men who have the right to marry four times under the Muslim Personal
Law (Shariat) Application Act, 1937.

Section 2 of the Muslim Personal Law (Shariat) Application Act, 1937 says-

2. Application of Personal Law to Muslims. —Notwithstanding any custom or

usage to the contrary, in all questions (save questions relating to agricultural land)
regarding intestate succession, special property of females, including personal
property inherited or obtained under contract or gift or any other provision of
Personal Law. marriage, dissolution of marriage, including talaq, ila, zihar, lian,
khula and mubaraat, maintenance, dower, guardianship, gifts, trusts and trust
properties, and wakfs (other than charities and charitable institutions and
charitable and religious endowments) the rule of decision in cases where the
parties are Muslims shall be the Muslim Personal Law (Shariat).
In simple words, the common laws of the nation, except for the constitution, are
not applicable to the Muslims, as they follow their own legal system enshrined in
various acts, the major one being, MUSLIM PERSONAL LAW (SHARIAT)
APPLICATION ACT, 1937.

Note- If the aforementioned text scared/intimidated you, don’t worry, these are
mere examples of what the actual thing looks like, every complex concept shall be
explained to you in the simplest manner by this guide. We intend to provide you
with the highest of knowledge without making it complicated for you.
IMPORTANT ARTICLES OF THE CONSTITUTION IN RELATION TO
THE UCC

Article 13 - is about the supremacy of fundamental rights. It says that no law can take
away or abridge any of the fundamental rights that are listed in Part III of the
Constitution. This means that if a law is passed that goes against one of the fundamental
rights, then that law is invalid.
Article 14 - is about the right to equality. It says that everyone is equal before the law and
has equal protection of the laws. This means that no one can be discriminated against on
the basis of their religion, race, caste, sex, place of birth, or any other ground. Article 14
also says that the government can make special provisions for certain groups of people,
but these provisions must be reasonable and must not be discriminatory.
Article 15 - The State cannot discriminate against anyone on the basis of their religion,
race, caste, sex, or place of birth. This means that everyone has the same rights and
opportunities, regardless of their background. The State can make special provisions for
women and children, but these provisions must be reasonable and must not be
discriminatory.
Article 16 - Everyone has the same right to get a government job, regardless of their
background or circumstances. The government can make reservations in public
employment for certain groups of people, but these reservations must be reasonable and
must not be discriminatory.
Article 25 - Everyone in India has the right to choose their own religion, to practice their
religion freely, and to share their religion with others. However, this right is not absolute.
The government can restrict the freedom of religion if it is necessary to protect public
order, morality, or health. For example, the government can ban a religious practice that
is harmful to people's health, such as snake charming. The government can also ban a
religious practice that is disruptive to public order, such as a religious procession that is
blocking traffic.
Article 26 - every religious group in India has the right to manage its own affairs in
matters of religion. This means that religious groups can decide how they want to
worship, who they want to be a part of their group, and what property they want to own.
The government cannot interfere with these decisions.
Article 29 - people who belong to minority groups have the right to protect their culture
and language. This means that they can start their own schools and teach their children
their own language and culture. The government cannot stop them from doing this.

IMPORTANT CASES IN RELATION TO THE AGENDA

MOHAMMAD AHMED KHAN V. SHAH BANO BEGUM

The Supreme Court for the first time, directed the Parliament to frame a Uniform
Civil Code in the year 1985, in the case popularly known as the Shah Bano case. In
this case, a penurious Muslim woman claimed for maintenance from her husband
under Section 125 of the Code of Criminal Procedure after she was given triple
talaq from him. The Supreme Court held that the Muslim woman has a right to get
maintenance from her husband under Section 125. The Court also held that Article
44 of the Constitution has remained a dead letter. The then Chief Justice of India
Y. V. Chandrachud observed that, "A common civil code will help the cause of
national integration by removing disparate loyalties to law which have conflicting
ideologies''. After this decision, nationwide discussions, meetings, and agitation
were held. The then Rajiv Gandhi led Government overturned the Shah Bano case
decision by way of Muslim Women (Right to Protection on Divorce) Act, 1986
which curtailed the right of a Muslim woman for maintenance under Section 125
of the Code of criminal Procedure. The explanation given for implementing this
Act was that the Supreme Court had merely made an observation for enacting the
UCC; not binding on the government or the Parliament and that there should be no
interference with the personal laws unless the demand comes from within.

BUJOE EMMANUEL VS. STATE OF KERALA

Controversy: The children in this story belong to a religion that doesn't allow
them to sing songs that aren't about God. One day, the school played the national
anthem and the children didn't sing it. The school thought this was disrespectful
and kicked the kids out. The kids' parents sued the school and the Supreme Court
said that the kids had a right to not sing the national anthem.

Held: The children in this story didn't sing the national anthem because it's against
their religion. The school thought they were being disrespectful, but the Supreme
Court said they weren't. The Court said that everyone has the right to follow their
religion, and that refusing to sing the national anthem doesn't mean you're being
disrespectful.
Notes: The basic inference which comes up via this case is the importance of
religious freedom provided to the citizens of India via the fundamental right. In
this case, one may understand that the rights provided to the citizens supersede
their fundamental duties, to protect the interests and traditions of our citizens,
albeit on the cost of some moral concepts.
SARLA MUDGAL VS. UOI

Controversy: The personal laws of the Muslim Religion permits men to marry up
to four times without divorcing others. The same is not allowed by the personal
laws of other religions. A practicing and married Hindu converted into Islam and
took another wife. He thereafter reconverted into Hinduism and divorced. As a
result, his wife could neither avail maintenance either under Hindu or Muslim law.

Held: Conversion only for such base purposes is not allowed and does not amount
to practicing religion as guaranteed by Article 19(1) (a) and Article 25. This case
also highlighted the desirability of a Uniform Civil Code

Notes: The case highlights a classic example of how citizens exploit laws upon
their own benefit. In this case, the man didn’t use his rights to profess his belief, or
to practice his religion or to worship his god, but to cheat on his lawfully wedded
wife and to avoid the punishment of law. Although the courts made sure he wasn’t
able to do so, it still poses a question of the exceptionalism provided to certain
communities via the law and how it is open to a ridiculous amount of exploitation
harming social and gender justice.

GOVERNMENT’S POV
The Uniform Civil Code is subject to the central government’s policy framework
as it enshrines the equalitarian concepts of social and gender justice. It takes upon
the idea to have a common set of laws governing personal matters such as
marriage, divorce, inheritance, and adoption for all citizens, irrespective of their
religious affiliations.
According to a paper on the BJP’s e-library titled “Bharatiya Janata Party and the
Uniform Civil Code”, the UCC first made an appearance in the party’s election
manifesto in 1996. Since then, it’s been a constant promise in manifestos, with the
BJP government constantly raising voice around the agenda, without any
significant progress upon it.

However, as it can be seen in the picture, for a lot of

states, even the ones under the regime of BJP government
do not have a specified data about their belief regarding
the Uniform Civil Code.

But, it can be said that a huge part of the North-India and

states of the Hindi Linguistic Belt (UP, Bihar, MP,
Uttarakhand, Jharkhand) welcome the UCC.
This support is garnered by the faith of conservative communalist right wingers
upon the BJP government and their malevolent policies around creating policies
excluding minorities, hence providing a major confidence boost to Right Wing
extremist groups that the UCC shall be a more helpful method to oppress more
minorities, by excluding their interests, hence promoting a majoritarian purview.
However, it is not to be presumed that the UCC is something which shall be of a
malicious nature, as the government has not put out a draft yet, but it is also to be
kept in mind that discriminatory politics is not new to the current regime.

Note - Goa is the only state with an active UCC, called the Goa Civil Code, given
to them by the Portuguese in 1867
 OPPOSITION’S POV
The Congress and a number of other parties have opposed the BJP’s proposal,
arguing that the version of a Code that the party wishes to oppose is
“communalized” and simply a way of restricting the freedom of Muslims to
practice their religion. Even parties traditionally supportive of a Uniform Civil
Code have opposed the BJP’s suggestion as they are of the opinion that it is
inherently discriminatory in nature- the All-India Muslim Personal Law Board
accusing the government of attempting to sneak it in under the garb of promoting
gender equality through its opposition to triple talaq in the Supreme Court. The
BJP has rejected such claims, and has declared its intent to go through with its
original plans.
Unlike the older times of Atal Bihari Vajpayee’s BJP and PV Narsimha Rao’s
Congress, the government and the opposition today have an extensively bitter
relationship with the latter opposing anything and everything the former does.

However, the major points arising are:

1. The Governments Anti-Muslim Policies

2. The Governments disregard of the Judiciary
3. The Right Wing extremist propaganda on the rise
4. The practice of divisive religious politics being played out by the top BJP
folks
5. The practice of Majoritarian politics
All in all, the opposition has only opposed the UCC, not using the mentioned

points but rather in a bid to defend “Minorities and their interests.” Let’s

have a look at the interests of minorities:

Muslim Personal Laws - The Muslims are obdurate upon their wish for the laws
to be inclusive of the Sharia Law and for the principles of the Quran, Sunnah,
Hanafi’s and Fatwa-E-Alamgiri to be kept in consideration. However, the acts, the
powers and the rights enshrined to the Muslim Community of India, is rather, as
cited in an earlier example, not a mere right but rather a privilege open to
exploitation. The crux of it is that the laws provided to the Muslim community of
India, to a certain extent, are violating the non-Muslim citizens of India, and even
are a hindrance to gender and social justice. However, they have the right to do so,
not only because the constitution allows them, but because it has become or was
dictated to be an integral part of the structure upon which their community exists.
To abolish it, or to maintain it, is a big question which is yet to be answered. On
the other hand, some parts of the Community are not opposed to the idea of a
common code since they can very well accept any law, provided it does not
prohibit them from doing what is fard (compulsory) or forces them to do what is
haram (prohibited) in the religion. As per Sharia law, legal adoption is prohibited
in Islam as is explicitly stated in the Quran (33:4), “...neither has He made your
adopted sons as your own sons”. Now it should be realized that though Islam gives
permission for polygamy it does not hold it to be a fard. So even if a Muslim is
made to live under a law that established monogamy, he could abide by the law as
polygamy is not a fard. However, when given an option they would certainly
prefer Sharia Law over other laws.

Christian Personal Laws: The Christians in India have expressed varied opinions
with regard to different aspects of the personal laws. A part of the Christian
community believes that Section 10 of the Divorce Act is discriminatory against
women, since much is expected by way of proof from them as against men. Most
Christians (both Catholics and Protestants) support the introduction of a uniform
civil code though with some reservations. For example, the Catholics prefer
annulment of marriage over divorce. On the point of adoption, the Christians want
full adoption to be legalized. Now there is a prohibition in Christian law; they
cannot adopt and hence Christians are sent abroad for adoption. All of them are of
the uniform view that all aspects of Christian personal law are negotiable. On the
point of succession, they believe that though the Indian Succession Act is quite
satisfactory, in case of intestacy, the Christian customary laws that are
discriminatory must go.
Parsis: Parsis do not believe in conversion as conversion to Zoroatrianism is
prohibited by religion. In case of adoption, Parsis do not like to adopt a non-Parsi
child because it is only a Parsi who is entitled to visit the fire temple and to get the
benefits from the private Parsi trust. They would want full adoption but, in that
case, the adopted child must necessarily be a Parsi, and adoption must be by Parsi
parents. Parsis are supportive of a uniform civil code on the condition that their
rituals in marriage are preserved. Polygamy was and is non-existent in Parsis, in
fact, it is a ground for divorce under the Parsi law.
Tribal Communities: India is a diverse nation, but not just limited to religions.
There are multiple tribes living in the territory of India and their interests need to
be protected. In order to do so, the Government of India had provided them with
special immunities, like those under Art 26 of the Constitution. In fact, one might
know that the legal age of marriage in India is 18 years of age, however there are
certain customs within tribal communities, which do not recognize these laws as
valid and follow their own customs as laws. These are called Customary Laws,
which are legally recognized by the Government of India, in order to accommodate
interests of these communities, which is why, the UCC is being opposed by many
tribal communities in Jharkhand and Meghalaya. However, it is to be noted that
these laws are restricted to the usage of the members of the respective
communities. An outsider is not subject to these laws.

Feminists and UCC: From the outset, the problem with the uniform civil code
debate was its gratuitous emphasis on uniformity. Both judicial pronouncements
and public debate justified it as essential for national integrity. For a long time, it
was rarely articulated in the public consciousness as a feminist issue. It became a
debate about uniformity versus minority rights, secularism versus religious laws
and modernisation versus tradition in the context of the new nation state. As Tahir
Mahmood, an expert in personal law, points out, the ultimate object of Article 44
(which enjoins the state to move forward towards a uniform civil code) is
secularity in family law: ‘the call for uniformity is merely the means’. Over the
years, consensus has emerged among feminists that all religious personal laws are
discriminatory and must therefore change. There are, however, disagreements over
the means to achieve this objective, whether through a state- sponsored civil code
or internal reform. Aware that legal change cannot be isolated from wider political
conflicts and majoritarian politics, women’s groups made an attempt to distance
feminist positions from the Hindu right’s demand for a uniform civil code. The
women’s movement has since moved to a more nuanced position which combines
the options of reform from within personal laws, with the formulation of gender-
just laws deriving from the concept of a common civil code. The All-India
Democratic Women's Association, which has a leftist leaning, supports a two-
pronged strategy to achieve reconciliation between gender-just laws as well as
reforms from within. It has actively engaged in mobilizing Muslim women and
encouraging community initiatives for legal reform, codification of personal laws,
and at the same time demanding legislation with regard to matrimonial property
and the custody of children, among other issues.

Special Marriages Act and Indian Succession Act

It can be argued that a uniform civil code is not a necessity since we already have
non-religion-specific legislation, such as the Special Marriage Act, 1954. However,
the first Special Marriage Act was enacted not in 1954 but in 1872. It required the
parties marrying under it to renounce their religions. It is only when the Special
Marriage Act was re-enacted in 1954 that it permitted interreligious marriages
without the couple having to renounce their religion. Parties marrying under this
Act were governed by the Indian Succession Act, 1926 for purposes of inheritance.
Subsequently in 1976, Hindu couples marrying under the Special Marriage Act of
1954 were taken out of its ambit, and could inherit under the Hindu Succession
Act, 1956. This was a retrograde step, because for a Hindu wife her inheritance
was depleted due to the coparcenary system.

MERITS OF UCC
Firstly, proponents of a Uniform Civil Code argue that the Common Civil Code
will bring all the personal laws governing matters which includes: marriage,
divorce, adoption, inheritance, succession to property, adoption, guardianship and
child custody under a single roof and create a space for the practices of all
communities in a just manner, while ensuring that everyone is treated equally
under the law.
Secondly, the one common argument given by all the political parties highlighting
their reluctance to implement the Uniform Civil Code is that implementing Article
44 violates the rights of Indians provided under Article 25 i.e., "Freedom of
conscience and free profession, practice and propagation of religion." The counter
argument that can be cited is present in the same Article 25 itself under Clause 2,
where it is clearly indicated that:
This article shall not affect the operation of any existing law or prevent the State
from making any new 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.
Thirdly, with the non-implementation of Article 44 of the constitution, Articles 14
to 18 are being violated which provide for Right to Equality before Law and
prohibition of discrimination on the grounds of sex and religion. Many personal
laws relating to marriage, inheritance, guardianship, divorce, adoption and
property relations in all communities are unjust, especially to women.
Fourthly, ambiguity is created due to the presence of different laws governing a
social institution such as marriage, particularly in the case of polygamy and
divorce; both within a religion as well as amongst different religions. Fifthly,
misapprehension prevails about polygamy in Islam. Ironically, Islamic countries
like Syria, Tunisia, Morocco, Pakistan, Iran et cetera have codified the personal
law where in the practice of polygamy has been either totally prohibited or
severely curtailed to check the misuse and abuse of this obnoxious practice.
Lastly, one of the advantages of a uniform civil code will be a proper notice
period and registration of the marriage.
In addition, a uniform civil code will also help in reducing vote bank politics that
most political parties indulge in during every election. If all religions are covered
under the same laws, the political actors will have less to offer to certain minorities
in exchange of their vote.

CRITICISM OF UCC
The objections raised for implementations of a Uniform Civil Code in India by
communities show that the imposition of such a code can pose a serious threat to
the sexual social fabric of the country and the minority community in general and
the minority communities in particular. Support for a uniform civil code from the
Sangh Parivar has led minority communities to fear the imposition of the religious
customs and rituals of the majority community under the garb of a uniform civil
code. A common civil code is also seen as an infringement on the Fundamental
Rights enshrined in the Constitution of India which guarantee the right to freedom
of conscience and free profession, practice and propagation of religion (Article 25)
and freedom to manage religious affairs (Article 26). Most religious scholars
consider their scriptures and personal laws to be of Divine origin and ergo show
strong resentment towards any sort of interference with the same. They believe
personal laws are sacrosanct and immutable and no legislature can amend it. In
addition, most religious practices have been carried out in conformity with these
personal laws since times immemorial and any attempt to alter them can hurt
religious sentiments and sow the seeds of mistrust among communities. The
unfavorable response in the idea of the code makes it very likely that protest would
occur, if the code is shoved down the throats of the Indian public. Given the
strained ethnic and religious fabric of this country, it is better to leave things that
may cause tensions.

POTENTIAL MODERATED CAUCUS TOPICS

1) Deliberation upon the practicalities and considerations for the actual

implementation of the UCC
2) Discussing the constitutional validity of the UCC in India
3) Suitability to implement the UCC in a country as religiously and culturally
diverse as India
4) Discussing measures that the administration could take to control the spread
of false rumors and propaganda to prevent any possible negative after
effects if the UCC were to be implemented
FURTHER READING & RESEARCH

1. https://youtu.be/FbVw7EZZ0UE- One Country, One Law: Time For

A Uniform Civil Code? | Arth - A Culture Fest 2023.
2. https://www.livemint.com/news/india/ucc-row-centre-opposition-
lockedhorns-at-uniform-civil-code-check-top-updates-here-
11688616049122.ht ml
3. https://www.thehindu.com/opinion/lead/india-needs-a-uniform-civil-
code /article67050330.ece
4. https://economictimes.indiatimes.com/news/how-to/what-is-uniform-
civil -code-what-does-constitution-say-about-it-why-its-such-a-
controversial-t opics-in-india/articleshow/101348565.cms
5. https://www.ndtv.com/opinion/why-india-needs-a-uniform-civil-code-
416 1333
6. https://www.legalservicesindia.com/article/394/Should-India-have-a-
Unif orm-Civil-Code?.html
7. https://theprint.in/opinion/uniform-civil-code-can-be-the-real-
unifying-fo rce-in-india-critics-must-think-again/953898/
8. https://www.livemint.com/news/india/uniform-civil-code-ucc-
karnatakabjp-elections-states-which-want-to-implement-ucc-
11683109712072.htm l
9. https://www.hindustantimes.com/india-news/sec-494-discriminatory-
high -court-issues-notice-101677953907548.html
10. https://thewire.in/politics/election-rhetoric-or-real-plan-opposition-rais
es-questions-as-bjp-broaches-ucc-yet-again
11. https://www.legalserviceindia.com/legal/article-5493-muslim-personal
-laws-in-india.html