RAM CHARAN v. SUKHRAM
Discusses constitutional principles, statutory interpretation, and application of justice, equity, and good conscience in property disputes.
Court: Supreme Court of India
Citation: 2025 INSC 865
Decision Date: 17-07-2025
List of Laws
Hindu Succession Act, 1956; Code of Civil Procedure, 1908; Constitution of India, 1949; Central Provinces Laws Act, 1875; General Principles of Law
- Hindu Succession Act, 1956: The judgment discusses Section 2(2) of the Act, which excludes members of any Scheduled Tribe from the application of the Act, unless the Central Government directs otherwise by notification. The court notes that the plaintiffs are telling themselves Hindu and claiming that they are governed under the Hindu Succession Act, which is a specific provision in sub-section 2 of section 2 of the Hindu Succession Act, 1956 that the member of the Scheduled Tribe shall not be governed by this Act.
- Code of Civil Procedure, 1908: The judgment mentions Section 100 of the Code, stating that an appeal was admitted under this section based on a substantial question of law regarding the justification of the lower courts in dismissing the suit.
- Constitution of India, 1949: The judgment extensively discusses Article 14, emphasizing equality before the law and equal protection of the laws. It cites several cases, including Maneka Gandhi v. Union of India and Shayara Bano v. Union of India, to elaborate on the scope and application of Article 14, particularly in the context of gender equality. The judgment also refers to Article 15(1), which prohibits discrimination on grounds of religion, race, caste, sex, or place of birth, and its relevance to ensuring no discrimination against women. The judgment also mentions clause (25) of Article 366 of the Constitution in relation to Section 2(2) of the Hindu Succession Act, 1956.
- Central Provinces Laws Act, 1875: The judgment discusses Section 6 of the Act, which states that in cases not provided for by other laws, courts shall act according to justice, equity, and good conscience. The court notes that the impugned judgment incorrectly stated that the 1875 Act had been repealed. The court clarifies that the Repeal Act No.4 of 2018 contains a saving clause (Section 4) that preserves rights accrued prior to the repeal. The court states that Section 4 is clear that no right having been accrued prior to the repeal of the Act shall be affected thereby.
- General Principles of Law: The judgment extensively discusses the principles of justice, equity, and good conscience, particularly in the context of inheritance rights for tribal women. It emphasizes that these principles can be applied when there is a void in the law or in the absence of any law governing a specific aspect. The judgment cites Niemla Textile Finishing Mills Ltd. v. 2nd Punjab Tribunal and M. Siddiq v. Suresh Das (Ram Janmabhoomi Temple) to illustrate the application of these principles. The court also discusses the importance of custom and how it should be applied in conjunction with these principles.
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