ISSN (Print) - 0012-9976 | ISSN (Online) - 2349-8846

A+| A| A-

Some Legal and Institutional Issues

On Ensuring Protection of Women in the NRI Marriages

The study examines the legal remedial measures for women trapped in the non-resident Indian marriages under private and public international law as well as the Indian legal and institutional framework, including a comprehensive legislation and a monitoring mechanism in the Prime Minister’s Office.

The Global Gender Gap Report 2021 vividly underscores the widening of the global gender disparity, especially due to the COVID-19 pandemic (2020–22), by a “generation from 99.5 years to 135.6 years” (WEF 2021). At the current pace, the South Asian region will take a staggering period of 195.4 years to bridge the gender gap. With 65 crore (0.65 billion) women population, India remains “the third-worst performer in the South Asian region, having closed 62.5% of its gap” (WEF 2021). The “gender gap” generally manifests through inequality, discrimination, and sexual and gender-based violence (SGBV) against women. The existing corpus of international law appears inadequate to address the “normative gap” (Desai 2021) on the gender challenge. Ironically, an institutionalised bias pervades against females (Desai 2022) even in the third decade of the 21st century.

One such segment relates to the plight of the Indian “women being trapped in fraudulent marriages with non-resident Indians (NRIs)” that has assumed “alarm­ing proportion” (Committee on Empowerment of Women 2007). As a sequel to the 2018 petition filed by eight women in the Supreme Court of India, another petition was filed in 2021 by three women. An estimated 50,000 incidents in NRI marriages have led to registration of criminal cases under Section 498A of the Indian Penal Code (IPC) and other provisions of law (Tribune 2018a) resulting in the abandonment of women. In Punjab alone, some 32,000 aggrieved women filed first information reports in different districts (Tribune 2018b).

According to the Ministry of External Affairs (MEA) website, there are 1,34,59,195 NRIs and 1,86,83,645 persons of Indian origin (PIO) with a total of 3,21,00,340 overseas Indians (MEA 2020d). The overseas Indians prefer to marry Indian residents due to cultural similarities and traditional values (NCW 2020a). In many of such marriages, the husbands abandon the wives while travelling to a foreign country, before reaching the husband’s residence abroad, or just after a short stay abroad.

In this grim situation, the MEA has sought to provide some safeguards to the women trapped in such NRI marriages. On 8 February 2019, a “draft bill” was introduced in the Rajya Sabha to provide protection to women “to create more accountability and offer more protection against exploitation of Indian women by their NRI spouses” (Rajya Sabha 2019) through registration in NRI marriages.

Within the limits of time and space, this article examines the international regulatory framework under the Hague Conference and 1979 Convention on the Elimination of all Forms of Discrimination Against Women (CEDAW) as well as the legal and institutional protection in India through available data and the case law.

The Challenge of NRI Marriages

The statement of objects and purposes of the 2019 draft bill seeks “to provide for compulsory registration of marriage for better enforcement of rights of the deserted spouses under various family laws.” During 2015–19, the MEA (2019a) recei­ved 6,094 complaints from women deserted by their NRI spouses. These complaints have been add­ressed by providing counselling, guidance, and information about procedures and mechanisms for serving a judicial summon to the overseas Indian husband; filing a case in India; issuing lookout circulars; getting access to lawyers and the non-governmental organisations impanelled with Indian missions, etc (MEA 2019b). In 2019, the MEA (2019c) revoked 21 passports, suspended 21 passports, and impounded one passport of NRI husbands for deserting their wives.

The Supreme Court in the case of Y Narasimha Rao v Y Venkatalakshmi examined this issue in the context of conflict of laws and highlighted the need for a guideline, inc­luding compulsory marriage registration.

International Legal Framework

The matters concerning inter-country fraudulent NRI marriages as well as harassment, discrimination, and violence against Indian women fall under both private international law as well as public international law.


Private international law: Primarily, marriages of Indian women with NRIs would attract domestic personal laws of India and the country of residence of the NRIs. Hence, there can be apparent “conflicts” between laws and jurisdictions of different countries owing to differences in societies, cultures, and the institution of marriage. The applicable body of private international law is also known as the “conflict of laws.” The corpus of “private” international law is huge and not a subject of this article.

This study seeks to examine only the part relating to “marriage” of Indian women with an NRI groom residing in a country that is also a party to the Hague Conference on Private International Law (HCCH).1

India formally joined the HCCH on 13 March 2008 after facing problems such as NRI marriages. It was felt that “if we are not signatories to the same Convention, then when we go to a foreign country’s court, we have to prove that our courts actually meet their standards” (Committee on Empowerment of Women 2007). Earlier it did participate in the HCCH instruments such as: (i) Convention on Inter-country Adoption (1993), (ii) Convention on Taking of Evidence Abroad in Civil or Commercial Matters (1970), (iii) Convention on the Service Abroad of Judicial and Extrajudicial Documents in Civil or Commercial Matters (1965), and (iv) Convention abolishing the requirement of Legalisation for Foreign Public Documents (1961).

It seems that most of the cases of NRI marriages have been dealt with under extradition treaties/arrangements or agree­ments on mutual legal assistance treaties. Therefore, the platform of HCCH provides a good base to take up the matter with specific member countries where the NRIs may be based (such as Australia, Canada, Germany, the United Kingdom [UK], and the United States [US]).


Public international law: In the realm of public international law, the 1979 CEDAW provides for taking appropriate measures to suppress all forms of discrimination and exploitation of women, including trafficking and prostitution (Article 6, UN Women 1979).

Often the main intention of the grooms in NRI marriages is to marry an Indian woman to get free domestic help abroad. This brings it under the rubric of “modern slavery” or “modern trafficking” that CEDAW (Article 6) prohibits (Bhargava et al 1989). Both “modern slavery” and “trans­national abandonment” of the wives by the NRI husbands are the new face of discrimination as well as SGBV against women (Bhattacharjee 2013). At the minimum, compulsory registration of NRI marriages could help in mitigating the problem. However, India has made a reservation to the CEDAW Article 16(2) (Freeman 2009):

though in principle it fully supports the principle of compulsory registration of marriages, it is not practical in a vast country like India with its variety of customs, religions, and level of literacy. (UN 2006)

The 2019 draft bill has a small step to fully comply with the CEDAW.

Legal–Institutional Framework

The issues arising from NRI marriages have led to the abandonment of wives, domestic violence, and extramarital rel­ationships, delay in getting immigration, ex parte divorce, etc. Indian women also face language problems that res­trict them from availing proper legal remedy in a foreign country. The study has sought to examine the exi­sting legal and institutional framework to deal with fraudulent NRI marriages as well as its interface with the relevant body of rules of private international law.

Legal Framework


(i) Availability of lenient grounds for divorce in some legal systems: It seems easier for NRIs to take divorce abroad due to the availability of lenient grounds in some jurisdictions. It aggravates the plight of Indian women in foreign lands. On the contrary, it becomes a nightmare for the women entrapped in NRI marriages to get justice in India. The Indian courts have pronounced some far-reaching judgments. Still, the courts alone cannot remedy the societal malady faced by women.


(ii) Jurisdictional problem: Some of the NRI marriages are annulled by an ex parte divorce decree obtained by a husband in the foreign court. The Indian courts have held on many occasions that any matrimonial relief granted by foreign courts must be in accordance with the matrimonial law under which the parties were married. In Dipak Banerjee v Sudipta Banerjee, the maintenance proceedings initiated by the wife under Section 125 of the Code of Criminal Procedure (CrPC), 1973 was upheld. The status of the husband as a citizen or a domicile in foreign country does not stop the Indian domiciled wife to approach an appropriate court to seek maintenance.


(iii) Marriage legislations: India’s marriage legislations have remained scattered in enactments, such as the Code of Civil Procedure (CPC), the Special Marriage Act (SMA), the Indian Succession Act, and the Indian Divorce Act and some rules have evolved from judicial decisions. Moreover, the SMA, 1954 prescribes (Section 15) compulsory regis­tration and permits dissolution (on ­mutual consent of the parties—Section 28) of marriages.

It is an established principle of the Indian private international law that, for a marriage to be formally valid, it must comply with the lex loci celebrationis (law of the place of marriage). A marriage is governed by the personal laws, yet Section 4 of the SMA, 1954 provides for the conditions for solemnisation of special marriages. The Himachal Pradesh High Court held in Marian Eva v State of Himachal Pradesh that a marriage under the SMA may be solemnised in India bet­ween two citizens of India or two foreigners or between a foreigner and an Indian citizen. The Kerala High Court also took the same view in Rajeev v State of Kerala. The Foreign Marriage Act, 1969 was enacted to implement the recommendations of the Third Law Commission (Law Commission of India 1962). It provided for solemnisation of marriage abroad between parties where one of the parties must be an Indian citizen on the same lines as the SMA, 1954.


(iv) Foreign judgments before the ­Indian courts: The general provisions relating to the recognition of foreign judgments and decrees are also applicable to that of foreign divorces. Section 13 of the CPC, 1908 embodies a fundamental principle of private international law that a judgment delivered by a foreign court should be enforced not only by way of courtesy but also on considerations of justice, equity, and good conscience.

The judgment of a foreign court is reg­arded conclusive on any matter adjudicated upon between the parties. However, it will be subject to six exceptions ([a] to [f]) contained in Section 13 of the CPC, 1908. The Supreme Court took great pain to explain these exceptions in Y Narasimha Rao v Y Venkata Lakshmi. However, in Satya v Teja Singh, the Supreme Court refused to apply the rule that the husband’s domiciliary law determines the jurisdiction. In Harmeeta Singh v Rajat Taneja, the wife was deserted by her husband and filed a suit for maintenance under the Hindu Adoptions and Maintenance Act, 1956. It was affirmed that even if the husband procured a decree of divorce in the US, it would not be recognised since the Indian court had jurisdiction in the matter. In order to avoid conflicts, a special law in the UK like the Foreign Judgments (Reciprocal Enforcement) Act, 1933 is required. It provides the “power to extend Part I of Act to foreign countries giving reciprocal treatment” (Section 1).2

In Vikas Aggarwal v Anubha, the Supreme Court held that inherent powers of the Court (Section 151 of the CPC) can, in fact, be marshalled to advance the interests of justice. Similarly, in Ramesh Venkat Perumal v State of Andhra Pradesh II, the Andhra Pradesh High Court rejected the contention of the husband for the quashing of proceedings under Section 498A of the IPC and held that it is a continuing offence and the sanction required (under Section 188), is not a condition precedent to initiate the criminal proceedings.


(v) Analysis of the case data: In this section, on the basis of the available data, the factual situation regarding complaints by the Indian women tra­pped in fraudulent NRI marriages refl­ects their plight. Hence, the role of relevant Indian institutions becomes very crucial in this respect.


Ministry of External Affairs: The ministry received 3,955 complaints from the Indian women who faced domestic violence abroad. The year-wise data of complaints received—1,158 (2019), 1,299 (2018), and 1,498 (2017)—show continuance of the pattern (MEA 2020a) in harassment, domestic violence, and matrimonial disputes. The 2017–20 data concerning the legal assistance provided to Indian women show that very few cases of distressed women victims in NRI marriages reach the Indian missions (Table 1) (MEA 2020b).

The MEA has now prepared an emigration bill, 2021 “to consolidate and amend the law relating to emigration of citizens of India” (MEA 2021). The purpose of this bill is to regulate the outflow of Indian nationals going abroad, especially for work purposes. However, the draft bill does not make any reference to “emigration of Indian women taking place through the institution of marriage” so as to check their getting tra­pped into fraudulent marriages with NRIs. Hence, the MEA needs to duly work out appropriate inter-linkages and safeguards bet­ween the draft “Emigration Bill 2021” and the “Registration of Marriage of Non-resident Indian Bill 2019.”


National Commission for Women: The National Commission for Women (NCW) is another statutory body that has been receiving complaints from distressed women in NRI marriages. As on 20 March 2022, the NCW website provides details of 30,865 complaints (NCW nd) out of which, six major causes have been chosen (18,952 complaints), as shown in Table 2 (p 25) (NCW 2021).

National Crime Records Bureau: The National Crime Records Bureau (NCRB) seeks to maintain an authentic record of crimes against women. However, the actual picture of crimes against them can only be guessed due to various attitudinal, societal, and institutional barriers in the registration of complaints. The NCRB data (Table 3) provide a grim picture.

The growth rate in crimes against women, particularly married women, is alarming. In 2019, as per the NCRB (2019c) data, 3,813 women died by suicides due to non-settlement of marriage (1,037), dowry issues (1,815), extramarital affairs (440), divorce (278), and others (643).


Situation in Punjab: The status of complaints received and actual cases registered against the NRIs by the Punjab police during January 2013 to April 2020 is indicative of the prevailing crisis (Punjab Police 2022a). The disposal of a large number of complaints could be the result of factors, such as coercion, attitudes of the police, allurements, compromises, and sheer desperation of women trapped in NRI marriages. As on 28 February 2022, there were 291 proclaimed offenders and 52 absconders out of which 130 proclaim­ed offenders and 23 absconders were in matrimonial disputes (under Section 299 of the CrPC), as shown in Table 4. Out of the total 1,268 complaints registered at the NRI cells (Table 4A), they pertained to matrimonial issues (569), property disputes (285), and other matters (414).

The cumulative pic­­­ture of the data shown in Table 4 (A, B, and C) indi­cates the prevailing crisis. It should make the sociologists, legal sch­o­­lars, social reformers, heads of religious institutions, women’s organisations, police, lawyers, judiciary, bureaucratic structures, and the policymakers concerned and alarmed. The lookout notices and declarations as proclaimed offenders and/or absconders do not appear to dampen the spurious practices that drive the penchant for indulging in fraudulent NRI marriages.

Institutional Framework

The MEA, Ministry of Women and Child Development (MoWCD), and Ministry of Law and Justice (MoLJ) have come together and formed an integrated nodal agency (INA) that caters to the matri­monial disputes relating to NRI mar­riages. These are forwarded to the NCW for scrutiny.

On that basis, the INA can issue the lookout circulars (LoC). As a part of it, consequential action can be taken, including the possibility of swift revocation or impounding of the passport of the NRI offenders (GOI 2018).

The Committee on Empowerment of Women (2007) suggested that “all marriages, irrespective of religion should be compulsorily registered.” Similarly, the report (No 219) of the Law Commission of ­India also recommended, “registration of marriages must be made compulsory.” It called for a “new composite legislation for NRIs or suitable changes be made in existing legislations for streamlining the laws and procedures” (Law Commission of India 2009a). Now the 2019 bill has sought to focus on four main aspects3 in the NRI marriages. The Parliamentary Standing Committee (PSC) has recommended for intensification of efforts for coordination with the member countries of the 1965 Hague Convention on the Service Abroad of Judicial and Extra-judicial Documents in Civil or Commercial Matters. It also called for taking up the issues of NRI marital disputes during bilateral meetings and consular dialogues with the concerned countries (MEA 2020c). The 2019 bill falls short of the requirement for a comprehensive legislation to address all the problems arising from the fraudulent NRI marriages. It rem­ains to be seen as to how the PSC fin­ally decides to give the go ahead to the MEA in the matter.

The MEA has compiled the data from nine countries (United Arab Emirates, Bahrain, Kuwait, Germany, UK, US, Australia, New Zealand, and Canada) about the incidences of cheating against Indian women by their NRI spouses and provided some basic guidelines for the protection of women. It underscores the gravity of the situation and the nature of prob­lems faced by Indian women trapped in fraudulent NRI marriages (MEA 2016a).

Conclusion: A Way Forward

Against the backdrop of the above discussion, there is an urgent need for taking the following concrete legal and institutional steps to stem the tide and ameliorate the conditions of Indian women trapped in fraudulent NRI marriages.


Enact a special comprehensive legislation that can be designated as the Non-resident Indian Marriages (Protection of Women) Act: It can comprise basic precautionary measures, including compulsory registration of NRI marriages, a verification mechanism for antecedents, provision for bond, a set of guarantors, deposition of a bank surety, cooling-off period after marriage, a ­registration and monitoring mechanism at the Indian missions abroad, allowing the breakdown of the marriage as a ground for dissolution, penalty clauses, and setting up of a special national regulatory authority for NRI marriages. It can provide for a specialised set of regi­onal NRI courts in cities, such as Ahmedabad, Amritsar, Bhopal, Kolkata, Hyderabad, Kochi, and New Delhi.


The MoWCD can be designated as the nodal ministry: It can help in coordination with other ministries for addressing the issues of emigration, extradition, repatriation, crimes against women as well as participation of India in the Hague Conference processes, implementation of India’s international obligations under conventions, such as CEDAW along with resolutions, instruments, and other policy-related initiatives undertaken by the United Nations.


Registration of NRI marriages must be made compulsory: Pending enactment of the above proposed comprehensive legislation on NRI marriages, the 2019 bill needs to serve as a deterrent against bigamous practices, fraudulent matters, and provide proof of a valid NRI marriage through registration within 30 days to the concerned Indian mission after a cooling-off period in India.


Dissolution of marriage on the ground of ‘irretrievable breakdown’: It needs to be allowed as a ground for divorce when one of the spouses is an NRI. This would require an amendment to the Hindu Marriage Act 1955 and the Special Marriage Act 1954 as already done in the Marriage Laws (Amendment) Bill, 2013 (original Bill No XLI-C of 2010),4 passed by the Rajya Sabha. In 2009, the Law Commission of India (2009b) recommended aforesaid amendments to the Hindu Marriage Act, 1955 as a new ground for divorce. This will provide def­ence to the woman when the husband obtains an ex parte divorce.

The problem of abandoned brides in consonance with the private international, law needs to be solved on a case-by-case basis. Due to differences in private international law rules, there is a great disparity in the judgments. It calls for an urgent need for a comprehensive examination of the international conventions and bilateral treaties and draft an appropriate national policy, specifically to address the challenge of NRI marriages in consultation with the union and state governments. The MEA has recently taken steps to provide financial help to distraught women through the Indian missions to fight legal battles. It was revised and streamlined in November 2016 (MEA 2016b).


Need for a ‘special monitoring cell’ in the Prime Minister’s Office (PMO): Such a specialised monitoring and coordination cell needs to be located in the PMO due to the involvement of multiple agencies, such as the Overseas Indian Affairs, MEA, MoWCD, NHRC, and state governments in dealing with issues relating to fraudulent NRI marriages. The NRI cell set up (2009) in the NCW deals with the complaints received from distressed women (NCW 2020b). In view of the limited statutory powers and the “weight” of the NCW, the coordination needs to be entrusted to the “special monitoring cell” in the PMO to address the challenge in earnest.


1 HCCH (1955) d7d051ae-6dd1-4881-a3b5-f7dbcaad02ea.pdf (

2 Foreign Judgments (Reciprocal Enforcement) Act, 1933 [23 GEO 5 CH 13.]; Foreign Judgments (Reciprocal Enforcement) Act, 1933 (

3 The Registration of NRI Marriage Bill (2019), No 11.

4 The Marriage Laws (Amendment) Bill, 2013 (original Bill No XLI-C of 2010);


Bhargava, Simran, Salil Tripathi and Amrit Kakaria (1989): “Ninety Per Cent Indians Settled Abroad Hunt for Spouses from Back Home, but Alarming Number Go Sour Too,” India Today, 15 February.

Bhattacharjee, S (2013): “Distant Silences and Default Judgments: Access to Justice for Trans-nationally Abandoned Women,” University Of Pennsylvania Journal of Law and Social Change, Vol 16, pp 95–110.

Committee on Empowerment of Women (2007): Plight of Indian Women Deserted by NRI Husbands, 12th Report, 13 August; Lok Sabha Secretariat, pl 21, (

Desai, Bharat H (2021): “Gender Based Violence a Global Challenge,” Tribune, 2 November.

— (2022): “Build Sustainable Society,” Tribune, 8 March.

Freeman, Marsha A (2009): “Discussion Paper, Reservation to CEDAW: An Analysis for UNICEF,” UNICEF,

GoI (2018): “WCD Ministry to Providing All Possible Assistance in NRI Marital Dispute Cases,” Press Information Bureau, Government of India (

HCCH (1955): Statute of The Hague Conference on Private International Law; came into being on 15 July 1955 and amended on 1 January 2007.

— (2020): Annual Report 2020, Hague Conference on Private International Law.

HCCP (2020), Annual Report 2020, p 8, be1e5b62-3e96-4cb2-a104-044181a2a6f5.pdf (, viewed on 14 March 2022.

— (2022): Membership GrowthHCCH | HCCH Members.

Law Commission of India (1962): The Law of Foreign Marriages, 3rd Law Commission, 23rd Report, Ministry of Law; Report 23. pdf (

— (2009a): Need for Family Law Legislations for Non-resident Indians, Report No 219, Department of Legal ­Affairs, Ministry of Law and Justice (

— (2009b): Irretrievable Breakdown of Marriage: Another Ground for Divorce, Report No 217, March (

Ministry of External Affairs (2016a): Legal and Other Provisions in Foreign Countries on Indian Women Cheated/Abandoned/Abused by Overseas Indian Spouses, pp 13–17, legal_provisions_in_foreign_countries.pdf (

— (2016b): Legal and Financial Assistance to Indian Women, proforma-legal-assistance.pdf (

— (2019a): “Question No 688 on Complaints of NRI Brides,” Lok Sabha, 20 November,

— (2019b): “Question No 2093: Special Laws against Absconding NRI Husbands,”

— (2019c): “Question No 1712: Revoking Passport of NRI Husband,” Lok Sabha, 13 February,

— (2020a): Starred Question No 284 on “Indian Women Facing Domestic Violence Abroad” (by Vijay Goel), Rajya Sabha, 19 March, (

— (2020b): Unstarred Question No 1427 in the Lok Sabha, “Legal Assistance to Women,” Annexure 1, ( (

— (2020c): The Registration of Marriage of Non-Resident Indian Bill, 2019; Third Report of Committee on External Affairs 2019–20, Lok Sabha Secretariat; SC Report_NRI Bill, 2019.pdf ( Release NRI BILL 13 3 2020.pdf.

— (2020d): “Population of Overseas Indians,”

— (2021): Draft Emigration Bill 2021 | Ministry of External Affairs, Government of India, (

National Commission for Women (2021): Nature-wise Report of Complaints Received by NCW.

— (2020a): “Abandoned Indian Women Trapped in NRI Marriage: The Way Out,”

— (2020b): “Functions of NRI CELL,” Functions of NRI CELL | National Commission for Women (

— (nd): “Important Case Laws Related to NRI Marriages,” NCW: Important Case Laws for NRI’s (

NCRB (2019a): Crime against Women (IPC + SLL), Table 3A.1; Table 3A.1_2.pdf (, viewed on 20 March 2022.

— (2019b): IPC Crime against Women, Table 3A.2; Table 3A.2_2.pdf (, viewed on 20 March 2022.


Punjab Police (2022a): Details of NRI Complaints/ Cases RegisteredPunjab Police, NRI Complaints/Cases (, viewed on 24 March.

— (2022b): Performa Monthly Report of Proclaimed Offenders/AbscondersI (, viewed on 24 March.

Rajya Sabha (2019): “The Registration of Marriage of Non-Resident Indian Bill,” 8 February, 3763RS.p65 (

Sundari, Anitha and Pragya Patel (2016): “Transnational Marriage Abandonment: A New Form of Violence against Women?” Open Democracy, 6 June.

Tribune (2018a): “Abandoned by NRI Husbands, Eight Women Approach SC,” 13 November,

— (2018b): “Centre Forms Panel to Deal with NRI Wife-deserters,” 30 August,

United Nations (2006): Declarations, Reservations, Objections and Notifications of Withdrawal of Reservations Relating to the Convention on the Elimination of All Forms of Discrimination against Women, Indian Declaration to CEDAW of 9 July 1993,

United Nations Women (1979): Convention on the All Forms of Discrimination against Women, 1979; CEDAW 29th Session 30 June to 25 July 2003.

World Economic Forum (2021): Global Gender Gap Report 2021, p 5, Preface—Global Gender Gap Report 2021 | World Economic Forum (, viewed on 20 March 2022.


Harmeeta Singh v Rajat Taneja (2003); IIAD Delhi 14, 102 DLT 822, I (2003) DMC 443, 2003 (67) DRJ 58; Harmeeta Singh v Rajat Taneja on 23 January 2003 (

Marian Eva and Anr v State of Himachal Pradesh (1993); AIR 1993 HP 7, II (1992) DMC 142; on 6 March 1992 (

Rajeev v State of Kerala (2001); 1 Ker LT 578; V Rajeev v State of Kerala on 30 May 2008 (

Ramesh Venkat Perumal v State of A P and Anr (1998); DMC 523, 1998 (1) ALD Cri 122, 1998 (1) ALT Cri 1, II (1998) DMC 523; on 10 November 1997 (

Satya v Teja Singh (1975); 1 SCC 120; on 1 October 1974 (

Y Narasimha Rao and Ors v Y Venkata Lakshmi and Anr (1991); SCR (2) 821, 1991 SCC (3) 451;


Dear Reader,

To continue reading, become a subscriber.

Explore our attractive subscription offers.

Click here

Updated On : 18th Jul, 2022
Back to Top