The Primogeniture: The Relevance and Facets- By Shri A.P. Mishra (A.D.J.)

Primogeniture means the state of being the firstborn child.

The Meaning, Introduction and History:

                Etymologically the term primogeniture means the State of being firstborn. The term originated in 17th century from medieval Latin primogenitura, from Latin primo ‘first’ + genitura ‘geniture. ‘Primogeniture’ is a rule of succession. It applies to impartible estates. The custom of Primogeniture was invariably prevalent in the Hindu Sovereign States all across India. This is also proved by the Administrative Reports which indicated that bearing a few exceptions, in cases of Hindu Rulers, the custom of Primogeniture invariably prevailed. It applied to Rulers and Monarchs. By this rule, the eldest son or the firstborn son succeeds to the property of the last holder to the exclusion of his younger brothers. According to the ordinary rule of succession, all the sons of the father are entitled to equal shares in his Estate. The rule of succession by which the firstborn son succeeds to the entire Estate, to the exclusion of the other sons, is called Primogeniture. It denotes a rule of succession by which the eldest among the heirs, male or female, succeeds to the Estate to the exclusion of other heirs. It is a simple Primogeniture in contradistinction to lineal male Primogeniture. Lineal Male Primogeniture means a continual descent to the eldest male member of the eldest branch. If a person died, leaving him surviving a grand-son by a predeceased eldest son and a younger son, the latter would succeed if simple Primogeniture prevailed, but the former would succeed, if the rule of Lineal Male Primogeniture governed succession (Tikka Shatrujit Singh and Ors. Vs. Brig. Sukhjit Singh and Anr. Rfa (OS) No. 23/2004 and CM Nos. 13060/2004 and 4530/2008 Decided On: 19.11.2010(HIGH COURT OF DELHI-DB)(2011) ILR 1Delhi704,MANU/DE/3785/2010).

                Going back into Indian History, long before the British Rule, the best example of authority on the rule of Primogeniture is none other than the decision that Lord Ram would succeed to the kingdom of Ayodhya after the demise of Raja Dashrath in total exclusion of his younger brothers Bharat, Lakshman and Shatrughan. Lord Rama was the eldest son or as the legalistic term goes, the firstborn. Since this was a Ruling Family; they were ruling the Kingdom of Ayodhya; there was no coparcenary, there was no partition.

                Some of the Princely States, before their merger into the Dominion of India, had enacted formal legislation in the name of the Ruler. These ‘Succession Acts’, specifically stated that the Rule of Succession applicable to their respective families would be the Rule of Primogeniture.

                The character of the Estate as a Raj or Principality is one of the factors for concluding that the Estate is impartible, once the Estate is held to be impartible, Primogeniture applied as a consequence.

Constitutional Backdrop:

                In the era before 1947, the term “State” applied to a political community occupying territory in India of defined boundaries and subject to a single Ruler who enjoyed or exercised, as belonging to him, any of the functions and attributes of internal sovereignty duly recognized by the British Crown. There were in India more than 560 States: forty out of those States had treaty relations with the Paramount Power: a larger number of States had some form of engagements or sanads, and the remaining enjoyed in one or the other form recognition of their status by the British Crown. The treaties, engagements and sanads covered a broad field, and the rights and obligations of the States arising out of those agreements varied from State to State. On May 16, 1946, the Cabinet Mission announced its Plan for the entry of the States into the proposed Union of India. They simultaneously declared that the Paramountey of the British Crown could not be retained nor transferred to the new Government. The plea for accession met with a favourable response. Negotiations for the accession of the States were soon completed, and the heads of the Indian States executed instruments of accession. Simultaneously, Standstill Agreements, the acceptance of which was made by the Government of India a condition of accession by the States concerned, were also entered into between the Dominion Government and the acceding States. It was a significant step in the direction of forging a vital constitutional link between the Dominion of India and the States. It was followed by the next phase culminating in integration of some States in the Provinces, consolidation of other States into sizable administrative units, and some other States executing agreements integrating with the Dominion. The instruments of merger provided for the integration of States and transfer of power from the Ruler and guaranteed to the Princes the privy purse, succession to the gaddi, rights and privileges, and full ownership, use and enjoyment of all private properties belonging to them. These instruments were concurred in and guaranteed by the Government of the Dominion of India. To give constitutional sanction to the merger agreements, special provisions were expressly incorporated in the draft Constitution recognizing the status of the Princes, the obligation to pay the privy purse, and the personal rights and privileges guaranteed to them. The territories of the States, after integration, retained no political or legal identity. Special recognition was given to the status of the Princes and their rights and the obligations of the Union, and for that purpose, Articles 366 (15), 366 (22), 291 and 362 were incorporated in the constitution. By Article 362 the Parliament, the State Legislatures and the executive of the Union and the States were enjoined to have “due regard to the guarantees and assurances” under the covenants and agreements between the Government of the Dominion of India and the heads of the former Indian States. The Proclamation and the execution of the merger agreements resulted in the complete extinction of the States and Unions of States as separate units. The princes ceased to retain any vestige of sovereign rights or authority qua their former States. They acquired the status of citizens of India.

Impartibility is an attribute attaching to property which derogates against the standard rule of devolution by survivorship amongst coparceners in the case of joint family property. A partition cannot be claimed in respect of such property. Impartibility is maintained by following rules such as Primogeniture or ultimogeniture. Impartibility and, consequently, the precise rule that is followed Primogeniture, ultimogeniture, or the like are essentially matters of custom. In Shiba Prasad v. Prayag Kumari(MANU/PR/0028/1932 : AIR 1932 PC 216)  which is the leading case on Impartibility, the Privy Council held that: Impartibility is essentially a creature of custom. The Supreme Court, in K.K.Y. Varu and Ors. V. S.K.Y. Varu and Ors. (MANU/SC/0400/1969 : (1969) 3 SCC 281), clearly held that: “The law regarding the nature and incidents of impartible Estate is now well settled. Impartibility is essentially a creature of custom.” Impartibility of an estate, if not established by custom, can only be claimed based on some specific statutory provision.

Right to Transfer:

                While appreciating the concept of Impartibility the issue of sever-ability or transferability of the property has always been a point of discussion and to some extent a gray area and it creates a sense that as if the property is impartible it can’t be transferred or severed with, but it is not the truth. Thakore Shri Vinayasinhji  v. Kumar Shri Natwarsinhji (AIR 1988 SUPREME COURT 247) is a relevant judgement, wherein the Court discussed and relied on Shiba Prasad Singh case. The relevant part of it is as follows:

                “7. At this stage, it will be profitable for us to refer to the illuminating judgment of Sir Dinshah Mulla in the case of Shiba Prasad Singh v. Rani Prayag Kumari Debi, A.I.R. 1932 PC 216. Sir Dinshah Mulla while delivering the judgment of the Judicial Committee of the Privy Council observed as follows:-

     “Impartibility is essentially a creature of custom. In the case of ordinary  joint family property, the members of the family have; (1) the right of partition;  (2) the right to restrain alienations by the head of the family except for necessity;  (3) the right of maintenance; and (4) the right of survivorship. The first of these  rights cannot exist in the case of an impartible estate, though ancestral from the  very nature of the Estate. The second is incompatible with the custom of  Impartibility as laid down in Satraj Kuari’s case (1888) 15 Ind App 51 and Rama Krishna v. Venkata Kumara (1899) 26 Ind App 83 (P.C.), and so also the third as held in Gangadhara v. Rajah of Pittapur, (1918) 45 Ind App 148 : (A.I.R. 1918 P.C. 81). ‘to this extent, the general law of the Mitakshara has been superseded by custom, and  the impartible Estate, though ancestral, is clothed with the  incidents of self-acquired  and separate property.  But the right of survivorship is not inconsistent with the custom of Impartibility.  This right  therefore remains, and this is what was held in Baijnath’s case,  (1921) 48 Ind App, 195 : (A.I.R., 1921 P.C. 62). To this extent, the Estate still retains its  character of joint family property, and its devolution is governed by the general  Mitakshara law is applicable  to such property. Though the other rights which a coparcener acquires by birth in  joint family property no longer exist, the birthright of the senior member to take by survivorship still remains. Nor is this right a mere spes successionis similar to that of a reversioner succeeding on the death of a Hindu widow to her husband’s Estate. It is a right which is capable  of being renounced  and surrendered. Such being their

 Lordships’ view, it follows that in order to establish that a family governed by the  Mitakshara  in which there is an ancestral impartible estate has ceased to be joint,  A. is necessary to prove an intention, express or implied, on the part of the junior  members of the family to renounce their right of succession to the Estate. It is not  sufficient to show a separation merely in food and worship.”

8. The law has been clearly and succinctly stated in the passage extracted above. There is, therefore, no restraint on the power of alienation of the holder of the impartible Estate, as any restraint on the power would be incompatible with the custom of Impartibility. The impartible Estate, though ancestral, is clothed with the incidents of self-acquired and separate property, except as regards the right of survivorship which is not inconsistent with the custom of Impartibility. The right of survivorship has been held to be a birthright and is not a mere spes succession is similar to that of a reversioner succeeding on the death of a Hindu widow to her husband’s Estate.”

Transfer by Will:

                Now another question arises whether the impartible properties can be bequeathed by transferred through a will or not. If a property can be transferred, it can be transferred inter vivos too. On this point relevant judgement is Thakore Shri Vinayasinhji (Supra 2),  wherein the Supreme Court discussed the two judgements Sri Raja Rao and Sartaj Kuari and held as follows:

       “12. We may now consider a later decision of the Privy Council in Sri Raja Rao v. Venkata Kumari, (1899) 26 Ind App 83. In that case, the Privy Council considered the question of extension of the decision in Sartaj Kuari’s case (1888-15 Ind App 51) (supra) to a will, and it was held “If the Rajah had the power to alienate, he might do it by will and the title by the will would have priority to the title by succession.” As the case before the Privy Council related to an impartible Raj Estate, succession to the Estate would be by survivorship. The Privy Council, however, took the view that title by will would have priority to the title by succession. In other words, it follows that the holder of the Raj Estate can defeat the right of survivorship by disposing of the Estate by a will. The learned counsel for the appellants, however, submits that in laying down that an impartible Raj Estate is alienable by a will, the Privy Council proceeded on the basis that there was no right of survivorship by birth. We are afraid we are unable to accept this contention. It is true that the Privy Council in that decision has not referred to the right of survivorship of the junior members of the family, but it should not be assumed that the Privy Council was not aware of the legal position that in an impartible Raj Estate the junior members would succeed to it by survivorship. Raja Rao’s case (supra) is, therefore, an authority for the proposition that a holder of an impartible estate cannot only dispose of the Estate by transfers inter vivos but also by a will and that when such a disposition is made by a will, it defeats the right of survivorship.”

Hindu Succession Act 1956:

                The Hindu Succession Act 1956 provided and changed the law of succession to the Hindus. Section 4 of the Act has an overriding effect, which provides as under:

4.Overriding effect of Act

(1) Save as otherwise expressly provided in this Act,

(a) any text, rule or interpretation of Hindu law or any custom or usage as part of that law in force immediately before the commencement of this Act shall cease to have effect with respect to any matter for which provision is made in this Act;

(b) any other law in force immediately before the commencement of this Act shall cease to apply to Hindus in so far as it is inconsistent with any of the provisions contained in this Act.

                But at the same time section 5 of the Act is also important which provides exception to the basic rule provided under Section 4. Section 5 reads as under:

5. Act not to apply to certain properties

This Act shall not apply to

(i) any property succession to which is regulated by the Indian Succession Act, 1925, by reasons of the provisions contained in section 21 of the Special Marriage Act, 1954;

(ii) any estate which descends to a single heir by the terms of any covenant or agreement entered into by the Ruler of any Indian State with the Government of India or by the terms of any enactment passed before the commencement of this Act;

(iii) the Valiamma Thampuran Kovilagam Estate and that Palace Fund administered by the Palace Administration Board by reason of the powers conferred by Proclamation (9 of 1124) dated June 29, 1949, promulgated by the Maharaja of Cochin

                Thus section 5(ii) of the Act saves the properties covered by rule of Primogeniture.

                For an estate to be covered under Section 5(ii) of the Hindu Succession Act, 1956, it is essential that the covenant or agreement or statute must by its terms and by its own force declare that the Estate would descend to a single heir.

                By virtue of Section 4 of the said Act, the custom relating to impartible estates and Primogeniture would cease to operate and would stand abrogated. However, such custom would not cease ipso facto upon the coming into operation of the said Act in 1956, by virtue of section 5(ii) of the Hindu Succession Act-1956. This is clarified by the Supreme Court in the case of Revathinnal Balagopala Varma v. His Highness Shri Padmanabha Dasa Bala Rama Varma(MANU/SC/0733/1991 : 1993 Supp1 SCC 233)  as under:

                “In other words, while the Act may have an immediate impact on some matters such as, for e.g. that covered by Section 14 of the Act, its impact in matters of succession is different. There the Act only provides that, in the case of any person dying after the commencement of the Act, succession to him will be governed not by customary law but only by the provisions of the Act.”
                This section 5(ii) protects an estate which descends to a single heir by the terms of any covenant or agreement entered into or by the terms of any enactment inasmuch as Hindu Succession Act is not applicable to such an estate. This section stands as an exception to Section 4 of the Act referred to above (Bhaiya Ramanuj Pratap Deo Appellant v. Lalu Maheshanuj Pratap Deo and others AIR 1981 SUPREME COURT 1937).

The Public and Private Properties of Sovereign vis -a -vis Ancestral Property:

The Supreme Court in  Revathinnal Balagopala (Supra 6) held that one incidence of the property held by a sovereign was that there was no distinction between the public or State properties on the one hand and private properties of the sovereign on the other; and the other incidence was that no one could be a co-owner with the sovereign in the properties held by him. The Supreme Court also emphasized that when they are speaking of the property of an absolute sovereign, there is no pretence of drawing a distinction, the whole of it belongs to him as sovereign and he may dispose of it for public or private purpose in whatever manner he may think. The Apex Court in fact approved a decision of the Gujarat High Court in D.S. Meramwala Bhayala v. Ba Shri Amarba Jethsurbhai (MANU/GJ/0155/1967 : (1968) (9) GLR 609).

                While distinguishing the ancestral property from sovereign one, it has been observed by the Court in the said judgement that the characteristic feature of the ancestral coparcenary property is that members of the family acquire an interest in the property by birth or adoption and by virtue of such interest they can claim four rights: (1) the right of partition; (2) the right to restrain alienation by the head of the family except for necessity; (3) the right of maintenance; and (4) the right of survivorship. It is evident from the nature of a sovereign Estate that there can be no interest by birth or adoption in such Estate and These rights which are the necessary consequence of community of interest cannot exist. The Chief of a sovereign Estate would hold the Estate under municipal power and not under municipal law. He would not be subject to municipal law; he would in-fact be the fountainhead of municipal law. The municipal law cannot determine or control the scope and extent of his interest in the Estate or impose any limitations on his powers concerning the Estate. As a sovereign ruler, he would be the full and complete owner of the Estate entitled to do what he likes with the Estate. During his lifetime no one else can claim on interest in the Estate. Such an interest would be inconsistent with his sovereignty. To grant that the sons acquire an interest by birth or adoption in the Estate which is a consequence arising under the municipal law would be to make the Chief who is the sovereign Ruler of the Estate subject to the municipal law. Besides, if the sons acquire an interest in the Estate by birth or adoption, they would be entitled to claim the rights enumerated above, but these rights cannot exist in a sovereign estate. None of these rights can be enforced against the Chief by a remedy in the municipal courts. The Chief being the sovereign Ruler, there can be no legal sanction for enforcement of these rights. The remedy for enforcement of these rights would not be a remedy at law. Still, the resort would have to be taken to force for the Chief as the sovereign Ruler would not be subject to municipal law, and the municipal courts would not control his actions. Now it is impossible to conceive of a legal right which has no legal remedy. If a claim is not legally enforceable, it will not constitute a legal right and, therefore, by the very nature of a sovereign estate, the sons cannot have these rights. If these rights cannot exist, in the sons, it must follow as a necessary corollary that the sons do not acquire an interest in the Estate by birth or adoption. From this judgment, it is clear that the characteristics of ancestral coparcenary property: (1) the right of partition; (2) the right to restrain alienations by the head of the family except for necessity; (3) the right of maintenance and (4) the right of survivorship, do not apply to the properties owned by the sovereign Ruler and that the son does not acquire any interest in such properties either by birth or adoption and even after the State of the sovereign Ruler has merged with India, the character of his properties do not change. In the case of Revathinnal Balagopala Varma, the Supreme Court referred to all the earlier decisions which have been referred and concluded that there is no distinction between the private and public properties owned by the sovereign Ruler and the incidents of ancestral or coparcenary properties are not at all applicable to such properties held by the sovereign Ruler. It is also held in this judgment that the mode of succession does not make any difference. As soon as one sovereign Ruler succeeds another, all the incidents of sovereignty are then possessed by the successor sovereign Ruler. In the said case also, the sovereign before surrendering his sovereignty entered into a covenant gave an option to the sovereign Ruler to furnish a list of such properties which he wanted to retain as personal properties. In case of a sovereign ruler, no incidence of coparcenary or Joint Hindu family can be applied to the properties held by him and his sons, have no right by birth (The judgment of Bhagwati, J. in Meramwala’s case, I.L.R. (1968) Guj 966 : (1968) GLR 609 and the judgment of a Division Bench of the Kerala High Court in Travancore case 1983 KLT 408. In Thakore Vinay Singh’s [Mohanpur] case MANU/SC/0424/1987 : 1988 Sup SCC 133 : AIR 1988 SC247 the Supreme Court held that there was no coparcenary, and in Vishnu Pratap Singh v. State of Madhya Pradesh 1990 Sup SCC 43 wherein it was held that the Ruler was the absolute owner of all properties. The Supreme Court judgment MANU/SC/0733/1991 : 1993Supp 1 SCC 233 in appeal from the Kerala High Court, and in the Nabha case MANU/SC/0963/1994 : 1994Supp 1 SCC 734 : JT 1993 (Supp) SC 288 are conclusive on this aspect. (As observed in Tikka Shatrujit supra 1).

The Zamindars:

                The custom of Primogeniture for Zamindars evolved as an exception to the general customs of Mitakshara survivorship and Mitakshara succession. However, the Zamindars did not have any sovereign power, i.e., the power to lay down the law. The Princes wielded sovereign powers and, therefore, they (all the Princes but with a rare exception) had applied the Rule ofPrimogeniture which then had taken shape as the law promulgated by them as a sovereign Ruler.
                In Nabha case, where the Supreme Court said that, though Impartibility and Primogeniture, in relation to Zamindari estates or other impartible estates, are to be established by custom, in the case of a sovereign Ruler, they are presumed to exist squarely applies.
                There were, in the pre-1950 era, thousands of Zamindaris in India. The fundamental difference is that they did not enjoy sovereign ruling powers and were merely landowners with the right to collect land revenue. Too many of these impartible estates, the succession was also governed by Primogeniture.

                A table depicting the difference between the Ruler of an Indian State on the one side and the holder of an impartible Zamindari on the other (Supra 1. Tikka Shatrujit)-

   Ruler of an Indian State   The holder of a Zamindari
1.The Ruler (Sovereign) would be the absolute owner of the State and its properties. None else would have any interest or share in his property.1. The holder of a Zamindari, as distinct from the Ruler of an Indian State, may hold it as an impartible estate. If; it is ancestral, he holds it on behalf of the family, and although there would be no right of partition, his interest will not be that of an absolute owner, which a sovereign ruler was. It would have been family property and of the type understood by the series of decisions in that regard.
2.Primogeniture would be presumed to apply as a Rule for succession.  2Primogeniture would not, repeat not, be Presumed to apply, but will have to be proved as a Custom.
3.He would have been a signatory to a Covenant/agreement ceding his State first (15.8. 1947) to the Dominion of India on three subjects, external affairs, communication & defence. And after that – by the Covenant or the Merger Agreement ceding the administration of his State to the Union or other Government before 26.1.1950.  3 to5He would not have been a party to any of the items 3 to 5 in the first column. This establishes the difference in status between a former Ruler on the one side and a Zamindari on the other. This, in turn, makes all the difference to the applicable law.
4.After 26.1.1950, he would be recognized as  a Ruler of a former Indian State by the President of India under Article 366 of the Constitution. He would be receiving an annual privy purse for the amount fixed by the Ministry of States.  
5.He would be receiving an annual privy purse for the amount fixed by the Ministry of States.  
6.On his death, succession 6. If he dies after to his Estate (properties) would be covered by the first part of the exception under Section 5(ii) and therefore not affected by the 1956 Act. If he dies after 17.6.1956, it will make no difference to the succession which will still be by Primogeniture.  6.If he dies  after 17.6.1956, succession to his Estate shall not be by Primogeniture. It will be as per Section 8 of the Hindu Succession Act.
7.He would be Derecognized as a Ruler by the 26th amendment.  7.Since he was never recognized as a Ruler, there is no question of “Derecognition”.

Post Independence:

                We can divide the period into two 1. Pre-merger of estates  2. Post-merger of estates.
After the integration of States in 1948-49, the Government of India, in several matters about succession in the erstwhile Princely States, recognized the existence of this rule. The Hindu Succession Act, 1956 specially provided Section 5(ii) to continue this rule (Supra 1).

                Once principality or sovereignty is proved Impartibility of Estate and Primogeniture may be presumed. With respect to a Raj as a Principality, the general rule is otherwise, and that is the rule of Primogeniture. It is a Sovereignty, a Principality, a subordinate Sovereignty and Principality no doubt, which, in its very nature excludes the idea of division in the sense in which that term is used (Baboo Gunesh Dutt Singh v. Maharaja Moheshur Singh, Vol. VI [1854-7 Moore’s Indian Appeals 164) the Privy Council).

The character of the Estate as a Raj or Principality as one of the factors for concluding that the Estate was impartible, once the Estate was held to be impartible, Primogeniture applied as a consequence (In the Ramnad case ILR [1901] Mad 613 a Division Bench).

            The Rule of Primogeniture only prevails in families of ruling chiefs or Jagirdars whose ancestors were ruling chiefs (In Salig Ram v. Maya Devi MANU/SC/0057/1955 : AIR 1955 SC 266; and in Jai Kaur v. Sher Singh MANU/SC/0300/1960 : AIR 1960 SC 1118,’21).

In Mohd. Yusuf v. Mohd. Abdullah (AIR 1944 Lahore 117) , a Bench of the Lahore High Court, had held that, the onus shifts on to that party who challenges recitals in the manual of customary law, to establish that what has been recited in the manual, is incorrect.

            In H.H. Maharaja Pratap Singh v. H.H. Maharani Sarojini Devi (MANU/SC/0963/1994 : 1994 Supp 1 SCC 734 : JT 1993 (Supp) SC 244)  [Nabha]the Supreme Court says: Though Impartibility and Primogeniture, in relation to zamindari estates or other impartible estates, are to be established by custom, in the case of a sovereign Ruler, they are presumed to exist.

            The law of Primogeniture prevails in all Rajpoot sovereignties; the rare instances in which it has been set aside, are only exceptions to the rule [Annals and Antiquities of Rajasthan, (Oxford University Press, 1920. Reported in 1978 by M N Publishers, New Delhi – 110048) Colonel James Todd, a former Political Agent to the Western Rajputana States,)(See supra 1 also)]

            When the fact of the existence of a custom amongst a particular class of people has been repeatedly proved in the courts, the courts have the power to take judicial notice of it (Kunhanbi v. Kalanthar [1914] MLJ163 the Madras High Court).
            When a custom or usage, whether in regard to tenure or a contract or a family right, is repeatedly brought to the notice of the Courts,  the Courts may hold that custom or usage to be introduced into the law without the necessity of proof in each individual case. It becomes in the end, indeed a matter of process and pleading. Analogy may be found in instances in the law Merchant or in certain customs in copyhold tenure (Pittapur case AIR 1918 PC 81).

            The holder of such impartible estates (non-sovereign ones) may not always be an absolute owner, and it could well be family property, yet the one who succeeded to the impartible Estate by Primogeniture had the right to transfer inter vivos or by a Will (See V. T S T Thevar v. v. T S S Pandia Thevar MANU/SC/0377/1965 : AIR 1965 SC 1730.).
            Once the distinction is borne in mind that the Estate was a sovereign estate and its Chief a sovereign ruler, the real import of the decision becomes clear. It establishes beyond doubt that the acquisitions by a sovereign ruler cannot be claimed to be joint family property. (See V. T S T Thevar v. v. T S S Pandia Thevar MANU/SC/0377/1965 : AIR 1965 SC 1730.)

                        If someone asserts that to a particular property held by a sovereign but the legal incidents of sovereignty do not apply, it will have to be pleaded and established by him that the said property was held by the sovereign not as a sovereign but in some other capacity.


Akhileshwar Prasad Mishra
Additional District Judge
District-Ambedkar Nagar (U.P.)

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