What enables an obscurantist, patriarchal body such as the All India Muslim Personal Law Board to challenge the state’s authority to intervene in Muslim Personal Law is uncertainty over the constitutional status of personal laws, that is, does the authority of personal law come from religion or the secular state. However, what eventually came to be known as “Hindu and Mahomedan laws” were creations of the colonial state following a complex process of rationalisation, rather than a simple codification of religious commands.