Labishwar Manjhi vs Pran Manjhi And Ors.

The Supreme Court addressed the applicability of the Hindu Succession Act, 1956 to members of the Santhal tribe, holding that Section 2(2) of the Act excludes Scheduled Tribes from its provisions. The Court emphasized that despite the parties being Hinduised, their tribal customs govern succession, thus the High Court's ruling that Hindu law prior to the Act applies was upheld. The Court confirmed that the customary law of the Santhal tribe prevails over the Hindu Succession Act, leading to the conclusion that the widow's gift was valid under tribal customs.