“LILY THOMAS V.

UNION OF INDIA”
[AIR 2000 SC 1650]

A Project submitted in partial fulfillment of the course FAMILY LAW-I,

3rd SEMESTER during the Academic Year 2019-2020

SUBMITTED BY:
KUMAR SHASWAT
Roll No. – 1929
B.A. LL.B. (Hons.)

SUBMITTED TO:
MRS. POOJA SHRIVASTAVA
FACULTY OF FAMILY LAW-I

AUGUST, 2019
CHANAKYA NATIONAL LAW UNIVERSITY, NAYAYA NAGAR,
MITHAPUR, PATNA-800001

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 DECLARATION BY THE CANDIDATE

I hereby declare that the work reported in the B.A. LL.B (Hons.) Project Report Entitled
“LILY THOMAS V UNION OF INDIA” submitted at Chanakya National Law University,
Patna is an authentic record of my work carried out under the supervision of Mrs. Pooja . I
have not submitted this work elsewhere for any other degree or diploma. I am fully
responsible for the contents of my Project Report.

(Signature of the Candidate)

KUMAR SHASWAT
Chanakya National Law University, Patna

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 ACKNOWLEDGEMENT

Firstly, I would like to thank my faculty of Family Law-I Mrs. Pooja Shrivastva for providing
me an opportunity to make my project on such an interesting topic which is also a
contemporary issue as for now.
Secondly, I would like to thank all my colleagues and friends for helping me out in arranging
of the accumulated collected study material.
Lastly, special thanks to my parents for guiding me in giving the final touch to this project
and helping me out throughout this project.

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 TABLE OF CONTENT

INTRODUCTION………………………………………………………………. 5-6

1. FACTS OF THE CASE……………………………………………….... 8-11

2. LAWS RELATING TO THE CASE…………………………………... 12-14
3. CASE ANALYSIS………………………………………………………. 15-18
4. CONCLUSION………………………………………………………….. 19

BIBLIOGRAPHY………………………………………………………………..20

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 INTRODUCTION

The Supreme Court through its recent judgment in Lily Thomas v. Union of India 1 has held
that charge sheeted Members of Parliaments , Members of Legislative Assemblies and
Members of Legislative Councils on being convicted of offences must be immediately
disqualified from holding membership of their respective House. In holding Section 8(4) 2of
the Representative of People‟s Act( hereinafter „RPA‟) unconstitutional, the Court asserted
that Articles 1023 and 1904 of the Constitution did not empower the Parliament to
discriminate between sitting legislators and other citizens.
This ruling comes against the backdrop of mounting public upheaval against criminalization
of politics in India which has been accentuated by increasing calls for the recognition of the
right to reject and recall elected representatives. With over 30 % of the MP‟s in both the
houses of the Parliament having serious criminal cases against them and the number
increasing manifold since the last election3, constant efforts were being made by the anti-
corruption activists to cleanse the politics of the country. Taking cognizance of the situation
through public interest litigation, the

apex court, swayed by the general perception, came out with a populist ruling which struck
immediate chord with the activists and the self-styled conscientious media who hailed it as a
stepping stone towards cleansing Indian politics of its vices. However, the judgment did not
receive unanimous support from the populace, with many meticulous observers pointing out
that this populist approach of the court was clearly a classic case of judicial overreach, as it
was not supported by sound legal reasoning. In fact such obnoxious was the reasoning of the
court and such obstinate its stance in not permitting a review petition, that the government
was left with no other alternative but to negate the judgment through an ordinance.
The authors essentially agree with the opinions of these legal luminaries and take issue with
the approach adopted by the court in this particular case. While considering the
constitutionality of Section 8(4) of the RPA, the authors believe, it was the duty of the
division bench to consider the
1
Writ Petition (Civil) No. 490 Of 2005
2
See § 8(4) of theRepresentative of People‟s
3
See Art. 102 of the Constitution of India
1950. 4 See Art. 190 of the Constitution of
India 1950.
3
Association for Democratic Reforms, Lok Sabha 2009:Election Watch, available at http://adrindia.org/researchand-reports/lok-
sabha/2009/pdf-full-book-lok-sabha-2009-election-watch-compedium-state-election-watch-reports, last visited on September 29, 2013

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 previous rulings of the court. These decisions had clearly stated that striking down of a
statute was a grave step and one which should be resorted to if no other way existed. 4
However in this case, since this basic presumption of constitutionality of a statute was
ignored by the Court, its assessment of the situation was bound to falter.

The authors vide this paper, thus seek to highlight the fact that though the Court came out
with a ruling whose ends were unquestionably noble, its means of doing so were most
certainly not. For the purpose of discussion, the paper will be essentially divided into three
sections. In section I the authors would first examine the various reactions to the judgment
including the sharp criticisms which have branded it as a case of „judicial overreach‟. In
section II, the authors will seek to analyze the judgment in light of established principles of
constitutional law and showcase how all of them have been willfully ignored by the court in
this case. Later on in Section III the authors would then seek to highlight the fact that such a
populist approach of the court does more than harm than good as it directly strikes at the very
core of separation of powers. It would ultimately be concluded that contrary to general
perception, the judgment, no matter what it seeks to achieve is based on an erroneous
interpretation of the law. The Hindu law of guardianship of minor children has been codified
and reformed by the Hindu Minority and Guardianship Act, 1956.

4
Government of Andhra Pradesh v. P. Laxmi Devi, AIR 2008 SC 1640 7 N
Gopalswami, Of Politicians and Verdicts, The Hindu (September 28, 2013) 8
See Art. 145(3) of the Constitution of India 1950.

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 RESEARCH QUESTIONS
1. Does India need a Uniform Civil Code for all its citizens?
2. Whether a Hindu husband, married under Hindu law, by embracing Islam, can
solemnize second marriage?
3. Whether the apostate husband would be guilty of the offence under Section 494 of the
Indian Penal Code (IPC)?

RESEARCH METHODOLOGY
The researcher has adopted the doctrinal method of the research.

SOURCES OF DATA
In order to complete the research study, the researcher will collect the material through
various primary and secondary sources of data.

PRIMARY SOURCES such as legislations and cases.

SECONDARY SOURCES reviewing the internet and different websites which preserve
historical documents and put them up for knowledge distribution.

LIMITATION OF THE STUDY

Since the researcher is a student of law, he has access to a limited area and knowledge. The
researcher having only a preliminary knowledge of the subject could understand the problem
clearly but was faced with constraints.

The researcher has limited time for the project. The need and background is also necessary
for having a bird’s eye view of the particular topic and it gets developed only by effective and
extended reading over a long period of time. However, the researcher only has access to
limited amount of work that is available in the library. The researcher has a restricted access
to information and sources for reasons beyond her control. But the researcher will still
attempt to take out the best possible work.

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 I.FACTS OF THE CASE

Mrs. Sushmita Gosh was married to Mr. Gyan Chand Ghosh, who to take benefit of a second
marriage with one Ms. Vinita Gupta (divorcee with 2 children) had converted to Islam as the
Hindu Marriage Act which provides the Punishment for Bigamy to be the same as under s.5
read with s.11 of the Hindu Marriage Act and further substantiated under s.17 of the Hindu
Marriage Act which provides the Punishment for Bigamy to be the same as under s.474 and
475, IPC

The three petitions:

1. Mrs. Sushmita Ghosh v. Union of India and Ors.

2. Smt. SarlaMudgal, President , Kalyani and others v. Union of India and Ors.
3. SunitaFatima v. Union of India and Ors.
Here they had been tagged together and SC made the law that “marriage resulting from from
religious conversion to Islam for taking second wife is void when ducting the existence of the
first marriage under The Hindu Marriage Act because such conversion of faith is feigned
rather than exercise of freedom of conscience.”

The case Lily Thomas v. Union of India is where various persons and jamiatUlema Hind
&Anr., have filed review petition under Art.1436 of the Constitution of India to review law
laid down by SarlaMudgal Case in 1995 and which was upheld through the Lily Thomas case
before in the criminal proceeding. Over writ petitions for breach of Fundamental Rights (Art.
20, 21,25,26) due to the law set by SarlaMudgal case was also filed. Lily Thomas is the
lawyer of the distressed, Mrs. Sushmita Ghosh and other such women who have been a
victim to bigamous marriage through religion conversion.. This case is resided by the two
Judges benchof S Saghir Ahmed, J. and R.P. Sethi, J

From this case the vital issue that arises on Art.21:

 Whether religious conversion for the purpose of committing bigamy and polygamy is
violation of Art.21 as long as Muslim Personal laws or any other marriage law allows
polygamy?

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  whether apprehension of a person for charges of bigamy after religious conversion to
Islam is breach of the fundamental right to life and liberty due to the judgment passed
by a Court of law or not?

CONTENTION FROM PARTIES

The first issue has been raised by Lily Thomas on behalf of the women wronged, the
argument was that marriage is a sacred institutions and resorting to the act of religious
conversion to Muslim so as to commit the act of bigamy as Muslim Personal Law allows it, is
a feigned attempt where freedom of conscience is not at stake but the women's freedom of
facing such

conditions of bigamous marriage and this betrayal is violate of A1.21 right to life and liberty

Further, Lily Thomas urged the court to declare polygamy in the Muslim law to be
Unconstitutional This was one of the most profound arguments placed before the
SupremeCourt for adopting a

Uniform Civil Code to absolve vast majority of socio-legal issues that were being uncovered
due to Religious Personal Laws. The few were 1) Many Muslim women had filed writ
petition before the Supreme Court and other high courts to declare polygamy in Muslim law
to be unconstitutional. 3) To reframe Muslim personal law in the likes as present in Tunisia
where polygamy is disallowed as the custom and usage of polygamy is disrespectful to the
liberty and integrity of women who have to face and live within bigamous and polygamous
marriages. 3) To have a Uniform Civil Code so that no Personal Religious laws makes
fundamental rights violation

The latter issue has been raised from the petitioners side as some of them have been
apprehended under .475, TPC due to the law made by the Supreme Court in the Sarla Mudgal
Case: hence review of the same has been raised against the Court's previous judgment. The
counsel for the petitioners have argued that the aggrieved parties while exercising their
freedom of conscience and to profess any religion have sought conversion to Islam and due to
such reasons they are allowed to commit Bigamy. The judgment in SarlaMudgal Case have
laid down the law that such marriage done after conversion to Islam is cold as under the
Hindu Law before conversion their exists the previous marriage and hence, due to such
voidness of marriage, some have been apprehended under 75. IPC. This is a violation of

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right to life and liberty due to the contention that the Muslim Personal Law Shariat) Act
allows bigamy and hence the apprehended have not committed any offence of IPC

Judgment
The Supreme Court bench of Sagir Ahmed, J. and Sethi, J. has upheld the decision of the
Sarla Mudgal case and further has enforced the same. Marriage resulting from conversion to
Muslim from any other faith during the existence of previous marriage before conversion is
deemed void even when Muslim Personal Law (Shariat) Act allows polygamy because such
conversion is not exercise of freedom of conscience but rather feigned and fraudulent without
the change of faith. The reason derived from the facts that lead to this judgment was due to
the practice of the husband who had converted to Islam but had not registered his new name
or faith as recognition for the child born out of the second wedlock. Even bank accounts hold
identification of the husband to have been Hindu. All these were seen as evidence to justify
that the conversion was feigned and solely for bigamous marriage rather than any changes in
neither faith nor practice of faith. Hence, marriage resulting from such conversion is void also
due to violation of Art.21. The violation of Article 21 on behalf of those apprehended under
the law laid down in Sarla Mudgal is being seen as no violation at all but the Court speaking
from Sethi J. have contended that Article 21 states no person shall be derived of his right of
life and personal liberty except as per procedure establish by law. Here the persons are
apprehended for offences under s.474 and 475, IPC therefore no right has been violated
because such apprehension has been laid down by law. The Court has said that alleged
violation of Article 21 is misconceived

This law as laid down in Sarla Mudgal v. Union of India and upheld in Lily Thomas v. Union
of India has raised issues for having a Uniform Civil Code for India (such though has been
laid down in Lily Thomas case) and also the 227th Report of The 18th Law Commission of
India in August 2009 have made this issue of preventing Bigamous marriage though
Conversion to Islam it’s subject and the commission headed by Dr. Justice A.R. Lakshmanan
have provided sound measures to keep this rampant practice of fraudulent conversion for
benefits of bigamy/polygamy under strict constrains so as to prevent such atrocities from ever
occurring. Though such implementation of the report in Indian Statutory law is yet to be seen.
The law exists in judicial precedent and the ratio decidendi is applicable to all religious laws

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and not confined to prevention under Hindu Marriage law.8 The order dismissed the review
petition and other petition due to no substance but also assured the Jamiat Ulema Hind and
the Muslim Personal Law Board that the Judiciary or the Union have not thought of making a
Uniform Civil code. All interim orders passed including stay of the Criminal Case in
subordinate Courts shall stand vacated. Both judges have given a concurring opinion.
Henceforth, the law on this issue reads: Any Marriage instituted after conversion to
Muslim while a marriage already remains from before conversion, will be void.

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 II. LAWS RELATING TO THE CASE

India Penal Code, 1860:

Section 494: Marrying again during 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.

EXCEPTION —This section does not extend to any person whose marriage with such
husband or wife has been declared void by a Court of competent jurisdiction, nor to any
person who contracts a marriage during the life of a former husband or wife, if such husband
or wife, at the time of the subsequent marriage, shall have been continually absent from such
person for the space of seven years, and shall not have been heard of by such person as being
alive within that time provided the person contracting such subsequent marriage shall, before
such marriage takes place, inform the person with whom such marriage is contracted of the
real state of facts so far as the same are within his or her knowledge.

Classification of Offence

Punishment- Imprisonment for 7 years and fine- Non-cognizable-Bailable-Triable by

Magistrate of the first class-Compoundable by the husband or wife of the person so marrying
with the permission of the court.5

Hindu Marriage Act, 1955:

Section 11: Void Marriages. Any marriage solemnized after the commencement of this Act
shall be null and void and my, on a petition presented by either party thereto [against the

5
Indian Penal Code, 1860, Section 494.

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other party], be so declared by a decree of nullity if it contravenes any one of the conditions
specified in clauses (i), (iv) and (v) of section 5. 6

Section 13: Divorce.

1. Any marriage solemnized, whether before or after the commencement of this Act,
may, on a petition presented by either the husband or the wife, be dissolved by a
decree of divorce on the ground that the other party-
(i) has, after the solemnization of the marriage, had voluntary sexual
intercourse with any person other than his or her spouse; or]

(ia) has, after the solemnization of the marriage, treated the petitioner with
cruelty; or]

(ib) has deserted the petitioner for a continuous period of not less than two
years immediately preceding the presentation of the petition; or]

(ii) has ceased to be a Hindu by conversion to another religion; or

(iii) has been incurably of unsound mind, or has been suffering continuously
or intermittently from mental disorder of such a kind and to such an extent
that the petitioner cannot reasonably be expected to live with the respondent.7

Section 15:

Divorced persons when may marry again. When a marriage has been

dissolved by a decree of divorce an either there is no right of appeal against the decree

or, if there is such right of appeal, the time for appealing has expired without an

appeal having been presented, or an appeal has been presented but has been dismissed

it shall be lawful for either party to the marriage to marry again.8

Constitution of India:

6
Hindu Marriage Act, 1955
7
Hindu Marriage Act, 1956, 13
8
Hindu Marriage Act, 1956, Section 15.

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Article 14: Equality before law the state shall not deny to any person equality before the law
or the equal protection of the laws within the territory of India Prohibition of discrimination
on grounds of religion, race, caste, sex or place of birth.9

Article 25: Freedom of conscience and free profession, practice and protection and
propagation of religion.10

Article 26: Freedom to manage religious affairs subject to public order, morality and health.11

Article 27: Freedom as to payment of taxes for promotion of any particular religion.12

Article 28: Freedom as to attendance at religious instruction or religious worship in certain

education institution. 13

Article 32: Remedies for enforcement of rights conferred by this Part

(1)The right to move the Supreme Court by appropriate proceedings for the enforcement
of the rights conferred by this Part is guaranteed

(2) The Supreme Court shall have power to issue directions or orders or writs, including writs
in the nature of habeas corpus, mandamus, prohibition, quo warranto and certiorari,
whichever may be appropriate, for the enforcement of any of the rights conferred by this Part

(3) Without prejudice to the powers conferred on the Supreme Court by clause (1) and ( 2 ),
Parliament may by law empower any other court to exercise within the local limits of its
jurisdiction all or any of the powers exercisable by the Supreme Court under clause ( 2 )

(4) The right guaranteed by this article shall not be suspended except as otherwise provided
for by this Constitution14

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.15

9
Constitution of India, Article 14
10
Constitution of India, Article 25
11
Constitution of India, Article 26
12
Constitution of India, Article 27
13
Constitution of India, Article 28
14
Constitution of India, Article 32
15
Constitution of India, Article 44

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 III.CASE ANALYSIS

The constitution of India provides for a uniform civil code for its citizens under Article 44 in
the Directive Principles. It is a goal, which is yet to be achieved by the democracy of India. In
the present case, the honorable court took steps to resolve the “inter personal conflict of
laws”, which is a product of the absence of a “Uniform Civil Code” 16

“The state shall endeavor to secure for the citizens a uniform civil code throughout the
territory of India”. Justice Kuldip Singh, in Sarla Mdghul case was of the view that there is
no reason for delay of UCC so that all the citizens of India can be governed uniformly. Pandit
Jawahar Lal Nehru, while defending the introduction of Hindu Code Bill instead of a uniform
civil code, in the Parliament in 1954, said “ I do not think that at the present moment the time
is ripe in India for me to try to push it through”. It appears that even 41 years thereafter, rhe
Rulers of the days are not in a mood to retrieve Article 44 from the cold storage where it is
lying since 1949. The Governments- which have come and gone- have so far failed to make
any effort towards “unified personal law for all Indians”. 17 The reasons are too obvious to be
stated. The utmost that has been done is to codify the Hindu Minority and Guardianship Act,
1956 and the Hindu Adoptions and Maintenance Act,1956 which have replaced the
traditional Hindu law based on different schools of thought and scriptural laws into one
unified code. When more that 80% of the citizens have already been brought under the
codified personal law there is no justification whatsoever to keep in abeyance, any more, the
introduction of “uniform civil code” for all citizens in the territory of India. 18

Until the Government enforces a uniform civil code for the country, a Non Islamic husband,
who wants enter into a second marriage while still in the first marriage can be allured to
convert into Islam as it provides room for bigamy and allows a Muslim husband to have four
wives at a time. Nonetheless Himdu law only permits monogamy, Hindu husband embraces
Islam to evade the provision of Hindu law and flight from penal consequences.

The doctrine of indissolubility of marriage, under the traditional Hindu law, did not

16
Praveen Dalal, Insight of Sarla Mudgal, (6/7/05)
http://india.indymedia.org/en/2005/06/210648.shtml.
17
Sarla Mudgal v. UOI,AIR 1995 SC 1531
18
Id.

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recognize that conversion would have the effect of dissolving a Hindu marriage.

Marriage will not be dissolved by converting to another religion by one or both

Spouses.19In the case Re Ram Kumari20, where a Hindu wife converted to Islam to marry a
muslim was charged with bigamy under Section 494 of IPC. It was held that there was no
authority under Hindu law for the proposition that an apostate is absolved from all civil
obligations and that so far as the matrimonial bond was concerned, suck view was contrary to
the spirit of the Hindu law.

InNandi alias Zainabv.The Crown21Nandi, the wife of the complainant, changed

her religion and became a Mussalman and thereafter married a Mussalman named

Rukan Din. She was charged with an offence under Section 494 of the Indian Penal

Code. It was held that the mere fact of her conversion to Islam did not dissolve the

marriage which could only be dissolved by a decree of court.

In India, there have never been marital laws. which have uniform application. A marriage
happens under one individual law and can't be broken down because of another individual
law simply due to the change of the gatherings

InSayeda Khatoon’s22 caseMuslim laws were not favored over Jews laws. They were

both declared equal. A marriage solemnized according to one personal law can be

dissolved according to another personal law simply because one of the two parties has

changed his or her religion.

InAndal Vaidyanathanvs Abdul Allam Vaidya23a Division Bench of the High Court

dealing with a marriage under the Special Marriage Act 1872 held that

19
Supra note 13.

20
(1891) ILR 18 Cal 264.

21
ILR 1920 Lahore 440.

22
49 CWN 745.

23
(1946) 1 MLJ 402

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“The SpecialMarriage Act clearly only contemplates monogamy and a person married under
theAct cannot escape from its provisions by merely changing his religion. Such a
personcommits bigamy if he marries again during the lifetime of his spouse, and it mattersnot
what religion he professes at the time of the second marriage. Section 17 providesthe only
means for the dissolution of a marriage or a declaration of its nullity. Consequently, where
two persons married under the Act subsequently becomeconverted to Islam, the marriage can
only be dissolved under the provisions of theDivorce Act and the same would apply even if
only one of them becomes convertedto Islam. Such a marriage is not a marriage in the
Mahomedan sense, which can bedissolved in a Mahomedan manner. It is a statutory marriage
and can only bedissolved in accordance with the Statute.24”

The dreary proclamations and choices have made it clear now that a marriage that has
occurred in less than one individual law can't be disintegrated regardless of the possibility
that one mate has changed over to another religion and alternate declines to do as such. At the
point when a marriage happens under Hindu individual law, a few rights and obligations are
made by method for it and the gatherings obtain certain status under the laws representing the
Hindu Marriage. In the event that one life partner tries to end the marriage by changing over
to another religion without dissolving the marriage then it will sum to devastation of the
rights and status of the other life partner who is still a Hindu. It is, in this manner, kept up that
hold that under the Hindu Personal Law as it existed before its codification in 1955, a Hindu
marriage kept on subsisting even after one of the life partners changed over to Islam. There
was no programmed disintegration of the marriage. The position has not changed in the wake
of coming into power of the Hindu Marriage Act, 1955 (the Act) rather it has turned out to be
more terrible for the backslider. The Act applies to Hindus by religion in any of its structures
or advancements. It additionally connected to Buddhists, Jains and Sikhs. It has no
application to Muslims, Christians and Parsees. One of the primary standards of Hindu law is
monogamy which it entirely holds fast to. A marriage can't be broken down aside from under
the procurements set down in Section 13 of Hindu Marriage Act. In that circumstance, parties
who have hitched under the Act stay wedded notwithstanding when the spouse believers to
Islam with the end goal of other marriage. A second marriage by a defector under the asylum
of transformation to Islam would by the by be a marriage disregarding the procurements of
the Act by which he would be keeping on being administered so far as his first marriage
under the Act is concerned in spite of his change to Islam. The second marriage of a renegade

24
Supra note 19

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would, hence, be illicit marriage as his wife who wedded him under the Act and keeps on
being a Hindu. Between the backslider and his Hindu wife the second marriage is
disregarding the provisions of the Act and as such would be under Section 494 of IPC.

Also, the second marriage of an apostate husband would be in violation of the rules of natural
justice. It is opposed to the principles of justice equity and good conscience. Even if the
spouse converts to islam, he has no right to solemnize the second marriage unless his first
marriage dissolves and, thus, be in violation of the rules of natural justice and as such would
be void.25

IV.CONCLUSION

25
http://lawcommissionofindia.nic.in/reports/report227.pdf

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The personal laws should be permitted to be controlled and free to be interpreted in new ways
for common additions and carnal delights. Accordingly, if a man wishes to enter into a
second marriage, subsequent to changing over to another personal law and without dissolving
his/her first marriage, such second marriage must be held to be substantial just if his/her
unique personal law permits such second marriage. Case in point, if a Hindu goes into a
second marriage in the wake of changing over to Islam, however without dissolving his first
marriage, the he ought to be held obligated for plural marriage in light of the fact that his
unique individual law does not permit polygamy. Essentially, if a wedded Muslim believers
to Hindu religion, without dissolving his first marriage, and goes into a second marriage he
ought not be held at risk for plural marriage on the grounds that his unique individual law
permits polygamy, however ability to do equity between co-wives is the condition point of
reference.

The Supreme Court has emphasized that the second marriage of a Hindu man after change to
Islam without having his first marriage disintegrated under the law would be invalid.

"The second marriage would be void as far as the procurements of Section 494 of the Indian
Penal Code (IPC) and the backslider spouse would be blameworthy of the offense of
polygamy under area 494 IPC", the court included. This choice of the court in Sarla Mudgal
case was maintained in Lily Thomas v. Union of India, the present case.

BIBLIOGRAPHY

BOOKS

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  Hindu Laws Bare Act With Short Notes  (Paperback, Universal's)

 Family Law Paperback – 2018 by Paras Diwan,Peeyushi Diwan (Author)

 Hindu Marriage Act (Paperback, Kant Mani)

WEBSITES

 https://indiankanoon.org/doc/80351/Lily Thomas, Etc. Etc. vs Union Of India & Ors.

on 5 April, 2000

 https://www.academia.edu › CaseSummaryLilyThomasv.UnionOf India

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