Ram Charan & Ors. v. Sukhram & Ors., 2025
The ruling is significant because tribal communities have often remained outside the purview of modern personal laws like the Hindu Succession Act.
Judgement Details
Court
Supreme Court of India
Date of Decision
18 July 2025
Judges
Justice Sanjay Karol ⦁ Justice Joymalya Bagchi
Citation
Acts / Provisions
Facts of the Case
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The appellants are legal heirs of Dhaiya, a woman belonging to a Scheduled Tribe.
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They claimed a share in the ancestral property of Dhaiya’s maternal grandfather.
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The male heirs in the family contested the claim, arguing that under tribal custom, women were excluded from inheritance.
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The Trial Court, First Appellate Court, and the High Court rejected the appellants’ claim on the ground that the appellants had failed to prove a custom allowing female inheritance.
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The appellants approached the Supreme Court, arguing that in the absence of a prohibitory custom, women should not be excluded from succession.
Issues
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Whether tribal women can be denied inheritance rights in the absence of a specific custom prohibiting such rights?
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Whether it is unconstitutional to require a woman to prove a custom allowing her inheritance, rather than requiring the opposing party to prove a custom that excludes her?
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Whether gender-based exclusion from property rights violates Articles 14 and 15(1) of the Constitution?
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Whether customs that discriminate on the basis of gender must evolve in accordance with constitutional values?
Judgement
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The Supreme Court allowed the appeal, setting aside the lower courts’ judgments, and granted the appellants equal share in the ancestral property.
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It held that in the absence of any established or proven custom prohibiting female succession, the right to equality under Article 14 must prevail.
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The Court also emphasized that the burden should not lie on women to prove that they are entitled to inherit, but rather on those who seek to exclude them to prove a valid, prevailing custom.
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The judgment authored by Justice Sanjay Karol called the gender-based exclusion unreasonable and discriminatory, stating: “Customs too, like the law, cannot remain stuck in time and others cannot be allowed to take refuge in customs or hide behind them to deprive others of their right.”
Held
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Tribal women are not automatically excluded from inheritance simply because the Hindu Succession Act does not apply to Scheduled Tribes.
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In the absence of any proven prohibitory custom, equality must be the default rule.
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Requiring women to prove positive custom to inherit is wrong in law and constitutionally flawed.
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The Court declared that denying succession to a female tribal based on gender in absence of custom violates Articles 14 and 15.
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The appeal was allowed, and the appellants were granted equal inheritance rights.
Analysis
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This landmark judgment is a strong affirmation of constitutional morality over outdated customary practices.
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It aligns with the progressive expansion of gender rights, placing a constitutional check on customary law.
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The Court’s reasoning reflects a shift from patriarchal interpretations of tribal inheritance to a gender-equal lens.
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The Court also reminded lower courts of their duty to apply principles of justice, equity, and good conscience where codified law is silent.
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The ruling is significant because tribal communities have often remained outside the purview of modern personal laws like the Hindu Succession Act, making judicial interventions crucial for ensuring equality.