The paper aims to elucidate the concept of a "Uniform Civil Code towards Gender Justice." A civil code encompasses laws regulating personal matters such as marriage, divorce, adoption, and inheritance. Article 44 of the Indian Constitution calls for establishing uniform civil laws to govern these personal laws. However, implementing this uniform civil code faces challenges.

It remains a non-binding Directive Principle of State Policy, and there is strong opposition from critics who argue that it threatens the religious identities of minority groups. This opposition often leads to debates that need more objectivity and pragmatism, overshadowing the actual potential benefits of such a code.

Despite the Constitution's emphasis on equality and justice for all, true equality for women remains elusive in India. Women constitute nearly half of the population but continue to grapple with the pervasive effects of a patriarchal society reinforced by tradition, religion, and culture. Historically, these societal pillars have placed women in a subordinate position to men, forcing them to fight for their rights to equality, liberty, and justice.

Women frequently face victimisation and neglect, and religious doctrines often serve as significant barriers to recognising women's rights within both the family and society. This gender bias leads to the marginalisation of women. While the Constitution upholds gender equality and envisions it through affirmative measures, the reality often falls short of this ideal.

This paper explores the relationship between gender justice and equality and the adoption of a Uniform Civil Code (UCC). It examines the necessity and relevance of implementing such a code across India. The discussion focuses on how a UCC could address gender disparities and promote equality, particularly in personal matters such as marriage, divorce, adoption, and inheritance.

These are currently governed by a patchwork of laws influenced by various religious and cultural practices. By analysing the potential impact of a UCC, the paper highlights its importance in advancing gender justice throughout the country.

Introduction
The Indian Constitution enshrines the principle of Fundamental Rights, including the right to equality. This principle ensures that all citizens are treated equally under the law and are entitled to equal protection, irrespective of their caste, creed, religion, race, sex, or any other attribute.[1]. Yet, a significant disparity exists in the legal rights granted to men and women under personal laws. Despite the government's commitment to secularism, this issue remains unresolved.

"Achieving gender equality is not just a mere objective, but rather a necessary condition to effectively address poverty reduction, encourage personal growth, and establish effective governance." – Kofi Annan.

Women face numerous challenges and risks solely due to their gender, even within the framework of humanity's core values. These difficulties persist despite constitutional and legal protections, and significant progress needs to be made to ensure their safety and rights.[2]Although the Indian judiciary has made significant efforts, its jurisdiction is limited and cannot fulfil the roles of other government branches. In this context, the Uniform Civil Code (UCC), a constitutional requirement, has yet to be enacted by the Indian Legislature.

The UCC aims to ensure equal status for women, who often face inequalities under existing personal laws. In India, women are primarily identified and governed according to their religion and personal law—be it Hindu, Muslim, Christian, Jewish, or Parsi. This mindset contributes to underdevelopment, prejudice, and numerous societal issues. Understanding the importance of a Uniform Civil Code is crucial, as it seeks to unify various personal laws to achieve gender justice.[3] In today's world, ensuring women have equal rights, independence, and the ability to make their own life decisions is more crucial than ever.

As society progresses in various domains, modernising our views on gender equality is essential, and we must avoid imposing individual beliefs and traditions on others. The pursuit of justice and equality for women often intersects with contemporary issues of freedom, secularism, and religion. Empowering women in all aspects-including social status, gender bias, health, and security-is imperative. Article 44 of the Indian Constitution mandates that the state establish a Uniform Civil Code for all citizens to achieve this goal.

The Uniform Civil Code (UCC) clause in the Indian Constitution aims to create a unified body of law that can harmonise various personal laws and promote gender equality for women. The criminal code is the only legislation uniformly applicable to everyone, regardless of religion. In contrast, personal matters such as marriage and succession are governed by different rules based on religion and gender.

For instance, distinct laws regulate marriage, divorce, succession, adoption, and maintenance for Hindus, Muslims, Christians, Parsis, Jews, and others. This lack of uniformity has been a contentious issue for many years, with some political parties advocating for legislation to address it.

Concept Of Uniform Civil Code

In India, different religious communities follow distinct personal laws, primarily focusing on matters like marriage, divorce, child custody, maintenance for divorced women, guardianship, adoption, succession, and inheritance. While religion delves into concepts such as spirituality and salvation, personal laws deal with practical, everyday matters.

The Uniform Civil Code seeks to standardise secular laws governing these areas, ensuring equal treatment for all individuals regardless of religion, caste, or tribe. It aims to restore the rights of citizens currently subject to different personal laws based on their religious or caste affiliations.

The civil code covers critical aspects such as property ownership and management, marriage, divorce, and adoption. Although the Uniform Civil Code is enshrined in the Directive Principles of State Policy under Article 44 of the Indian Constitution, its implementation remains debated and discussed.[4] It's indeed regrettable that the courts cannot enforce the Uniform Civil Code since it's considered a non-justiciable right, fraught with various challenges.

The term "Uniform Civil Code."[5] Comprises three key elements. "Uniform" denotes consistency and stability across all circumstances or something that conforms to a standard or norm. "Civil" originates from the Latin word "Civilis," which pertains to citizenship or being a community member. Lastly, "Code" is derived from the Latin term "codex," representing a compilation of laws. Initially, these laws were inscribed on wooden tablets coated with wax, later transitioning to parchment or papyrus sheets.

Implementing the Uniform Civil Code is perceived as a stride towards secularising personal laws devoid of religious affiliations. In India, the concept of a Uniform Civil Code entails the establishment of a comprehensive Civil Law Code applicable to all citizens, irrespective of their religious background. Essentially, the idea of the UCC encompasses two key components.[6]

1. The first component of the Uniform Civil Code aims to establish consistency and equality in the laws governing different communities, irrespective of gender.
2. The second component strives to ensure equality and gender justice between men and women within these communities.

Uniform civil laws, akin to uniform criminal laws, are envisioned to eliminate disparities based on gender and uphold the principles of equality and justice. The success of the Uniform Civil Code in Goa serves as a beacon of progressive change, reinforcing its significance in promoting equality and justice.

Concept Of Gender Justice

Gender justice involves taking deliberate actions to ensure women's autonomy and freedom while advocating for their rights through legal reforms and the integration of women into social and economic policies. Practical definitions of gender equity are context-dependent and necessitate an inclusive approach. Political ideology encompasses beliefs about what constitutes justice and goodness in human interactions and how to achieve these desired outcomes.[7]

Gender justice goes beyond just understanding the interactions between men and women. It envisions a society where both genders are treated as complete human beings, and concerted efforts are made to transform the entire societal structure to ensure fairness and equality.

Moreover, it shifts from arbitrary to well-founded, balanced, and fair social relationships. Gender justice serves as a mechanism to diminish the disparities arising from the subordination of women to men. It not only represents the outcome of achieving gender justice but also aids in discerning what needs to be done and how to accomplish it.

UCC Historical Development

In the Middle period[8]During the medieval period, Hindus followed the shastras, whose interpretations were typically carried out by Brahmins and enforced by the king. Sharia law governed Muslims, interpreted by Kazis and enforced by Nawabs. When the East India Company arrived, they implemented English Common Law for their English subjects, but determining which law should apply to Indian subjects posed a challenge. Brahmins and Kazis were often consulted to interpret shastras and Sharia law.

In 1840, the British Government introduced uniform laws for crimes, evidence, and contracts based on the Lex Loci report, excluding the personal laws of Hindus and Muslims. However, the British Indian Judiciary allowed judges to apply Hindu, Muslim, and English law. Reformers of the time advocated against discriminatory practices like Sati that curtailed women's rights under religious laws.

The Hindu personal laws were codified by Parliament in 1956 despite facing significant opposition. This code was divided into four parts:

1. The Hindu Marriage Act, 1955
2. The Hindu Succession Act, 1956
3. The Hindu Adoption and Maintenance Act, 1965
4. The Hindu Minority and Guardianship Act, 1956

Despite the persistent efforts of Prime Minister Nehru, his supporters, and women's activists to implement a uniform civil code, strong opposition prevailed. Ultimately, they had to concede and include it in the Directive Principles. Meanwhile, the Indian Penal Code and Criminal Procedure Code comprised comprehensive criminal laws in effect nationwide.

Gender Injustice And Uniform Civil Code Conflict

The historical development of our nation reflects the discrimination inherent in personal laws. These laws dictate various aspects such as marriage, divorce, maintenance, succession, minority, and guardianship, establishing norms and regulations governing personal relations within families. However, the individual laws applicable to Hindus, Muslims, Christians, and other communities often reflect patriarchal norms, resulting in unjust and discriminatory treatment of women.

Hindu Laws
In the case of Gita Hariharan[9], Section 6 of the Hindu Minority and Guardianship Act was challenged due to its discriminatory language, which placed mothers in a subordinate position as guardians.

In the case of Sarala Mudgal v. Union of India[10], the Supreme Court of India addressed the issue of the Uniform Civil Code. It ruled that marriages conducted by Hindu men who converted to Islam to practice polygamy were not valid. If a Hindu man converted to Islam while his first marriage was still valid, his second marriage would be considered void, as it would be unjust to his first wife.

According to the CARA Guidelines on the Adoption Regulations Act of 2017, a single male does not have the authority to adopt a girl child independently. Conversely, a single female has the authority to adopt a male child independently. However, there must be a 25-year age difference between the child and the parent.[11]

Muslim Laws
In the case of marriage under Muslim law, a guardian has the authority to arrange a marriage for their minor ward. However, there is a remedy known as the "option of puberty," which allows the ward to repudiate the marriage upon reaching puberty. This option, however, is more restricted for females, limiting their ability to reject the marriage arranged by their guardians.[12].

Additionally, Shia Muslim men can enter Muta marriages, temporary marriages for a predetermined period. There is no limit to the number of Muta marriages a Shia Muslim man can have. However, this practice is not recognised under Sunni law.[13].

In terms of inheritance under Shia law, if a wife dies and leaves behind direct descendants, her husband is entitled to receive one-fourth of her estate[14]. However, without lineal descendants, the husband inherits half of the wife's property. In contrast, in a similar situation, the wife would only receive one-eighth of her husband's property. When dealing with intestate property, a daughter inherits half of the estate.

If there is also a son, the daughter becomes a residuary heir, with the son receiving twice the amount given to the daughter. Before implementing the Muslim Personal Law (Shariat) Application Act in 1937, women had no inheritance rights.

Regarding maintenance, the Shah Bano case marked a pivotal shift in Muslim personal laws. The Supreme Court ruled that divorced Muslim women are entitled to maintenance under Section 125 of the Code of Criminal Procedure. Before this landmark decision, divorced Muslim women were not entitled to financial support from their ex-husbands.

Regarding polygamy: Although it is illegal in India for most citizens, Muslim men are permitted to have multiple wives. However, this right does not apply to Muslim women.

Particular Marriage Act, 1954: The supposedly secular Special Marriage Act of 1954 also exhibits gender bias, similar to other personal laws. After entering into a civil marriage under this act, Muslims, Christians, Parsis, and Jews lose access to their respective succession laws. In contrast, Hindus, Buddhists, Jains, and Sikhs must adhere to their succession laws even after a civil marriage under the Special Marriage Act of 1954[15].

Indian Constitution And Uniform Civil Code
As we know, Article 15[16] The Constitution prohibits discrimination based on race, religion, caste, sex, and place of birth. Article 25 grants every individual the right to freely practice and propagate their faith, subject to public order, health, and morality, while Article 26 allows religious denominations to manage their religious affairs.

Citizens are granted fundamental rights that ensure their freedom, which some argue would be violated if a Uniform Civil Code (UCC) were implemented. However, it is essential to question whether religion and personal laws are interchangeable. These two aspects are distinct and separate. Religion pertains to practices within religious communities, such as spirituality, worship, and rituals. On the other hand, personal laws govern matters such as marriage, divorce, adoption, succession, and inheritance, which are not inherently connected to religious practices.

In What Areas Do We Need Uniformity
There are specific areas where uniformity in our laws is needed. These include:[17]

First, In Section 494 of the Indian Penal Code (IPC), it is stipulated that marrying another person while still having a living spouse constitutes a criminal offence.[18] There is only one exception to this uniform law: if a man is Muslim, he can have up to four marriages. However, this exception contradicts the principle of uniformity in our penal laws. The progressive trend in the world leans towards monogamy, so uniformity should align with this principle.

Second, Hindu women inherit an equal share of property, while Muslim women, in comparison to their male relatives, can inherit less than half of the share.[19]

Third: Unlike Hindu women, Muslim women do not have the same ability to claim maintenance for an extended period.[20]

Fourth: Indian law mandates a uniform minimum age for marriage across all religions, set at 18 years for females and 21 years for males. Marriages below this age are deemed child marriages and are prohibited. However, there is an exception in Muslim law, where the marriage of a minor who has reached puberty is considered valid. Each religion in India has its unique rules and regulations concerning marriage.[21]

Need For Uniform Civil Code

It Will Integrate India
Implementing a uniform civil code in India holds the potential to foster greater integration than ever since independence. The current biased treatment of specific religious communities by the law fuels hostility, which could be mitigated with a uniform civil code. This would ensure that every Indian, irrespective of caste, religion, or tribe, adheres to the same national civil code of conduct.[22]

It Will Help in Reducing Plebiscite Bank Politics
Enforcing a uniform civil code could help diminish the practice of vote bank politics, often observed during elections by political parties. If the same laws govern all religions, public officials cannot offer special favours to specific minorities in exchange for their votes. The lack of a uniform civil code undermines true democracy and warrants reevaluation.[23]

Personal Laws are a Loophole
The various personal laws often serve as a tool for those in power to exploit. Our traditional panchayats sometimes make decisions that contradict our constitution, yet we usually fail to take action to address these issues. Human rights violations such as honour killings and female feticide continue to occur across our country.[24]

Every contemporary Nation has it
A contemporary and progressive nation is marked by a uniform civil code, signalling a departure from caste and religious politics. Despite being a top performer in economic growth, India still needs to catch up in social progress. Culturally and socially, there has been regression, blending modern and traditional values. Implementing a uniform civil code can propel society forward, bringing India closer to its goal of becoming a developed nation.[25]

It will give women more rights
Implementing a uniform civil code can potentially elevate women's status in India. Our society exhibits a strong bias towards men, and by persisting with outdated traditions, we perpetuate oppression and abuse against Indian women. A uniform civil code can catalyse a transformation in these antiquated customs that no longer hold relevance in today's society, where we acknowledge the significance of treating women equitably and affording them equal rights.[26]

All Indians Should be Treated equally
The existing personal laws in India favour certain religions, permitting Muslims to engage in multiple marriages, while Hindus or Christians would face legal repercussions for the same actions. This discrepancy does not reflect fair and equal treatment of all citizens. All laws about marriage, inheritance, family, and land must be uniform for every Indian citizen to ensure equal treatment for all.[27]

It Promotes Real Secularism
Selective secularism is evident in India, with some areas being secular while others are not. A uniform civil code is essential to uphold equality, where all citizens abide by the same laws irrespective of their religion. This approach is fair and impartial. Implementing a uniform standard code does not restrict an individual's freedom to practice religion; it guarantees equal treatment under the law.[28]

Advantages [29]:
Gender equality
Implementing a uniform civil code nationwide could facilitate the eradication of gender discrimination. Presently, numerous religions and customs exhibit bias towards men despite women's ongoing struggle for equality since independence. The laws of various religions often disadvantage women, particularly concerning inheritance and succession. A uniform code would guarantee equal treatment for both genders.[30]

A lift to national integrity
Implementing a Uniform Civil Code (UCC) would foster integrity at a national level. Despite diverse cultural values, having a standardised set of laws applicable to all individuals, irrespective of gender, social status, religion, and so forth, would enhance national unity.[31]

Foundation of Secularism
The preamble of our constitution explicitly declares India as a socialist, secular, democratic country. However, despite several years of independence, India maintains separate personal laws for different religions, such as for Hindus, Muslims, and Christians. This raises doubts about whether genuine secularism can be attained without implementing a Uniform Civil Code.[32]

Social changes
The anticipated implementation of the Uniform Civil Code (UCC) across India promises a significant social transformation in this century. Presently, Muslim women in India lack individual rights regarding marriage and divorce, unlike their counterparts in other Muslim-majority countries such as Pakistan, Bangladesh, Turkey, and Morocco, where women have structured individual laws.

With the introduction of the UCC, Indian women, including those from Muslim and Christian communities, will gain access to a structured individual law. This development could catalyse sweeping social change across the nation.[33]

Uniform Civil Code- Challenges In Its Implementation[34]

• Access to Essential Medicines: One of the primary ethical concerns in biotechnology lies in ensuring affordable access to essential medicines. Patents on life-saving drugs can create barriers, limiting access for those who cannot afford high prices. Striking a balance between incentivizing pharmaceutical innovation and ensuring public health is a delicate task.
• Global Health Disparities: The global nature of intellectual property rights raises concerns about exacerbating health disparities between developed and developing nations. Developing countries may struggle to afford patented biotechnological advancements, leading to a divide in healthcare accessibility.
• Agricultural Biotechnology and Food Security: Patents on genetically modified organisms (GMOs) and other agricultural biotechnologies raise ethical questions about food security. While these technologies can increase crop yields, the concentration of patents in the hands of a few companies may limit access for small-scale farmers.
• Informed Consent and Genetic Information: Biotechnology often involves the collection and analysis of genetic information. Ethical considerations arise regarding informed consent, privacy, and the potential misuse of genetic data. Striking a balance between advancing genetic research and protecting individual rights is crucial.

Landmark Cases:
Mohd. Ahmed Khan v. Shah Bano Begum[38]
In 1985, the Shah Bano case questioned fundamental principles when a Muslim woman named Shah Bano, married to Mohammed Ahmad Khan, filed a petition at the local court in Indore under Section 125 of the Code of Criminal Procedure. She sought maintenance for herself and her children. Her husband exercised his right under Islamic law, giving her an irreversible divorce.

He argued that since she was no longer his wife, he was not obligated to provide maintenance, except as prescribed by Islamic law, which amounted to Rs. 5400. The Supreme Court ruled in favour of Shah Bano, who had suffered despite her faith, settling the matter under the Criminal Procedure Code. However, this decision stirred unrest within the Muslim community.

Consequently, the Muslim Women (Protection of Rights on Divorce) Act, 1986, was enacted, mandating husbands to provide maintenance to their wives during the iddat period. In Shah Bano's case, the court awarded her maintenance, highlighting that laws apply uniformly across all religions.

Smt. Sarla Mudgal v. Union of India[39]
In the Sarla Mudgal case, the central issue revolved around a husband contracting a second marriage upon converting to Islam without dissolving his first marriage. An examination of sections 5 and 11 of the Hindu Marriage Act, 1955, reveals that he cannot be held accountable under the Hindu Marriage Act for polygamy, as section 5 pertains to marriages solemnised between two Hindus. The Supreme Court addressed this by asserting that the law that best serves the purpose in conflict between personal laws should prevail. Therefore, the Court ruled that conversion to Islam does not automatically dissolve a marriage conducted under Hindu law.

Danial Latifi v. Union of India[40]
The Supreme Court of India issued a landmark ruling in the case of Daniel Latifi, affirming that a Muslim husband is obligated to provide maintenance for his divorced wife even after the Iddat period. This interpretation is based on Section 3 of the Muslim Women (Protection of Rights on Divorce) Act, 1986.

While recognising the complexity of formulating a uniform code for individuals of diverse faiths, the Court expressed disappointment over the non-implementation of Article 44, which calls for a Uniform Civil Code (UCC). The Court urged the State to take legislative action in enacting a UCC, emphasising the importance of addressing loopholes in personal laws that allow some individuals to exploit them. Specifically, the Court highlighted instances where individuals convert to Islam to contract second marriages while still legally married under Hindu personal law.

The Court declared such marriages invalid under Section 494 of the Indian Penal Code if the first marriage had not been dissolved. However, it refrained from declaring polygamy or specific aspects of Muslim personal law as void under Articles 14 and 15 of the Constitution of India. Nonetheless, the Court emphasised the urgent need for a UCC to safeguard the rights of the oppressed and promote national unity and solidarity.

Lily Thomas and Others v. Union of India[41]
The court dismissed the argument that the Sarla Mudgal vs. Union of India decision violates rights protected under Article 21 of the constitution. The verdict in the Sarla Mudgal case neither altered the procedure nor created any law for prosecuting individuals accused of offences under Section 494 of the Indian Penal Code. Therefore, if a Uniform Civil Code had been provided as mandated by the constitution, the issues that arose in cases such as Mohamed Ahmed Khan v. Shah Bano and Daniel Latifi & others v. Union of India would not have occurred.

Conclusion
Despite considerable discourse on women's rights and empowerment, there has yet to be much tangible progress. The treatment of women within personal laws is a pressing concern that demands attention. While the Hindu legal framework has undergone substantial reforms, Muslim laws remain stringent and outdated, exposing women to vulnerability and dependence on men's discretion.

Hence, it is imperative to enact a Uniform Civil Code that ensures equal treatment for all genders, devoid of prejudice. Justice Kuldeep Singh's assertion that personal laws and religion are distinct is valid. Marriage and succession are secular and should not be subject to religious interpretation.

End Notes:

1. The Constitution of India, arts.14,15.
2. Leila Seth, "A Uniform Civil Code: towards gender justice" 5 Journal of India International Centre 49 (2005).
3. Dani Nath Raina, "Uniform Civil Code and Gender Justice" 1-10 (Reliance Publishing House 1996).
4. Dr Saroj Bohra, "Uniform Civil Code, Women Empowerment and Gender Justice" 3 Journal of South-Asian Multidisciplinary Studies 1 (2013).
5. P. K. Pandey (ed.), Human Rights and Gender Justice, 17 (APH Publishing Corporation, New Delhi, 2012), Available at SSRN: https://ssrn.com/abstract=2485380 (last visited on MAY 14, 2024).
6. Uniform Civil Code Towards Gender Justice, available at: https://lawcorner.in/uniform-civil-code-towardsgender-justice/ (last visited on MAY 14, 2024).
7. P.K. Pandey (ed.), Gender Justice and Uniform Civil Code: An Overview: 19 (APH Publishing Corporation, New Delhi, 2012), Available at SSRN: https://ssrn.com/abstract=2485380 (last visited on MAY 14, 2024).
8. M.S. Ratnaparkhi, Uniform Civil Code: An ignored Constitutional Imperative 20-30 (Atlantic Publishers and Distributors, 1997).
9. AIR 1999 SC 228.
10. AIR 1995 SC 569.
11. iCARA Guidelines Adoption Regulations Act, 2017, s.5.
12. Tahir Mahmood, Outlines of Muhammadan Law 73 (Oxford University Press, New Delhi, 5th ed., 2008).
13. Sir Dinshaw Fardunji Mulla, Mulla Principles of Mahomedan Law 353-354 (Lexis Nexis Haryana, 22nd edn., 2017).
14. Maheema Rai and Salvin Paul, "Women and Uniform Civil Code in India" in W. Leal Filho et al. (eds.), Gender Equality, Encyclopaedia of the UN Sustainable Development Goal, 4 (Springer, 2020), available at: https://doi.org/10.1007/978-3-319-70060-1_71-1 (last visited on MAY 14, 2024).
15. The Special Marriage, 1954 (Act 43 of 1954), s.19,20,21.
16. The Constitution of India, arts.15, 25, 26.
17. Priya Jain, One Nation One Law/Uniform Civil Code, available at: https://youtu.be/gTCB6-m065s (last visited on MAY 14, 2024).
18. The Indian Penal Code, 1860 (Act 45 of 1860), s.494.
19. Inheritance rights of Hindu, Muslim, and Christian women are not the same, available at: https://economictimes.indiatimes.com/wealth/legal/will/inheritance-rights-of-hindu-muslim-christian-womenare-not-the-same/articleshow/90067981.cms?from=mdr (last visited on MAY 14, 2024).
20. The Muslim Women (Protection of Rights On Divorce) 1986 (Act no.25 of 1986), s.3,4.
21. Raising Legal Age for Marriage, available at: https://www.drishtiias.com/daily-news-editorials/raising-legal-age-for-marriage (last visited on MAY 14, 2024).
22. Uniform Civil Code- Indian Polity, available at: https://byjus.com/free-ias-prep/need-for-a-uniform-civil-code-in-a-secular-india/ (last visited on MAY 14, 2024).
23. Ibid.
24. D.C. Manooja, "Uniform Civil Code: A Suggestion" 42 Journal of Indian Law Institute 448-457 (2000).
25. Ibid.
26. Ibid.
27. Ibid.
28. Ibid.
29. Uniform Civil Code in India, available at: https://blog.finology.in/Legal-news/uniform-civil-code-india (last visited on MAY 14, 2024).
30. Ibid.
31. Ibid.
32. Ibid.
33. Ibid.
34. Tanya Sharma, "Uniform Civil Code: A Detailed Analysis" 5 Journal of India International Centre 12 (2020).
35. Ibid.
36. Ibid.
37. Muslim organisations divided on Uniform Civil code, available at: https://www.thehindu.com/news/national/muslim-organisations-divided-on-uniform-civil-code/article67042429.ece (last visited on MAY 14, 2024).
38. AIR 1985 SC 556.
39. AIR 1995 SC 569.
40. AIR 1985 SC 740.
41. AIR 2000 SC 1650.