SHAM LAL & ORS. ETC. vs AMAR NATH & ORS.

The Supreme Court clarified the rules of succession to Stridhana of a Hindu widow married in an approved form, as per Yajnyawalkya and Mitakshara, stating that her kinsmen inherit if she dies without issue. The Court held that the order of succession prioritizes unmarried daughters, married daughters unprovided for, and so forth, with the husband's heirs only inheriting if none of these are present. The Court rejected the argument that 'without issue' includes son's daughters, affirming that the Mitakshara's interpretation is well-settled and that the Hindu Women’s Rights to Property Act, 1937, does not apply to a Hindu female's property.