Punjab & Haryana High Court, Chandigarh
Citation(2020) 9 SCC 1
CourtSupreme Court of India (Three-Judge Bench)
Date11 August 2020
Year2020
BenchArun Mishra, S. Abdul Nazeer, M.R. Shah JJ.
Acts/ArticlesHindu Succession Act 1956 Section 6 (as amended 2005)
CategoryConstitutional Law, Property & Land Law

Key Principle Established

Daughters have equal coparcenary rights by birth under the Hindu Succession (Amendment) Act, 2005 — irrespective of whether the father was alive on the date of the amendment.

Brief Facts

The question before the Three-Judge Bench was whether a daughter’s coparcenary right under the 2005 Amendment depends on the father being alive on 9 September 2005. This resolved the conflict between Prakash v. Phulavati (2016) and Danamma v. Amar (2018).

Ratio Decidendi

  • The daughter’s coparcenary right is by birth — it does not depend on the father being alive on the date of the amendment
  • The 2005 Amendment is retroactive in nature — it confers rights from birth, not from the date of the amendment
  • A daughter has the same rights and liabilities as a son in Hindu Mitakshara coparcenary property
  • This applies regardless of whether the father died before or after 9 September 2005

Impact & Significance

This is the definitive judgment on daughters’ property rights in Hindu law. It overruled Prakash v. Phulavati and settled the law that daughters have equal coparcenary rights by birth. Enormous impact on property succession in Haryana where agricultural land inheritance traditionally excluded daughters.

Tags & Related Topics

Constitutional Law Property & Land Law Hindu Succession Act 1956 Section 6 (as amended 2005)
← Previous Judgment Prakash v. Phulavati

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Disclaimer

This judgment summary is for educational and research purposes. While care has been taken to accurately represent the ratio and findings, for authoritative reference always consult the original judgment text from official sources (SCC Online, AIR, Manupatra, or court websites).

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