“When parents live in different countries, which country decides where the child should live?”
This question has become increasingly important with the growth of NRI marriages, international families, cross-border relocation and marriages between persons belonging to different religious communities.
An NRI child-custody dispute is rarely a simple contest between a mother and father. It may simultaneously involve Indian guardianship law, personal law, foreign custody orders, ordinary residence, citizenship, immigration status, jurisdiction, constitutional remedies and the welfare of the child.
The controversy popularly associated with the film Mrs Chatterjee vs Norway brought these issues into public attention. However, the film must be distinguished from the actual proceedings. The Norwegian Government has stated that the film was inspired by an actual case but contains creative liberties and should not be treated as a judicial record.
For an Indian court, the central question is ultimately not:
Which parent has the stronger legal claim?
It is:
What arrangement best serves the welfare and best interests of the child?
That principle runs through Indian custody jurisprudence involving Hindu, Muslim, Christian, Parsi, interfaith and NRI families.
What Is NRI Child Custody?
An NRI child-custody dispute may arise where:
- one or both parents reside abroad;
- the child was born or raised outside India;
- the child holds foreign citizenship;
- the parents separate abroad;
- one parent brings the child to India;
- a foreign court has passed a custody or return order; or
- one parent proposes permanent international relocation.
The dispute becomes more complex where the child has an established educational, social, cultural and family life in another country.
Illustration
An Indian couple has lived in the United States for eight years. Their child was born there and attends school there. Following marital differences, the mother brings the child to India.
An Indian court may have to consider:
- where the child ordinarily resides;
- whether foreign proceedings are pending;
- whether a foreign custody order exists;
- how the child came to India;
- the child’s relationship with each parent;
- education and stability; and above all, the child’s welfare.
Foreign citizenship alone does not determine custody. Bringing the child to India does not automatically settle jurisdiction or custody either.
The Norway–Bhattacharya Dispute: A Major Lesson in International Child Custody
The real-life dispute associated with Mrs Chatterjee vs Norway concerned Sagarika Bhattacharya and Anurup Bhattacharya, an Indian family living in Norway.
Norwegian child-welfare authorities became involved in the care of their children, leading to substantial public and diplomatic attention in India. The dispute was eventually resolved through cooperation involving Indian and Norwegian authorities.
The important legal lesson is not simply whether India or Norway was “right”, or whether the mother or father had the stronger claim.
The central lesson is that international child disputes must ultimately be examined from the child’s perspective.
Relevant considerations may include:
- physical safety;
- emotional security;
- psychological well-being;
- educational continuity;
- stability of residence;
- relationship with both parents;
- relationship with grandparents and caregivers;
- ordinary residence;
- cultural and social environment; and
- consequences of moving the child between countries.
The film can therefore serve as a public introduction to NRI custody issues, but it should never be cited as though it were itself a reported judicial decision.
The Statutory Framework for NRI Child Custody in India
There is no single Indian statute that exhaustively governs every international child-custody dispute.
The applicable framework may include:
A. GUARDIANS AND WARDS ACT, 1890
Important provisions include:
- Section 7 – appointment or declaration of guardian;
- Section 9 – jurisdiction and ordinary residence;
- Section 12 – interim protection and custody; and
- Section 17 – matters relevant to welfare of the minor.
B. HINDU MINORITY AND GUARDIANSHIP ACT, 1956
Where Hindu personal law applies:
- Section 6 – natural guardianship; and
- Section 13 – welfare of the minor as the paramount consideration.
The HMGA operates alongside the Guardians and Wards Act.
C. MUSLIM PERSONAL LAW
Muslim custody disputes may involve principles concerning hizanat/custody and guardianship, together with the Guardians and Wards Act and the circumstances of the individual case.
The Muslim Personal Law (Shariat) Application Act, 1937 forms part of the wider personal-law framework.
D. Christian Families
For Christian families, the Divorce Act, 1869, particularly Sections 41–44, contains provisions concerning custody of children in matrimonial proceedings, alongside the general guardianship framework where applicable.
E. Parsi Families
For Parsi families, the Parsi Marriage and Divorce Act, 1936, including Section 49 concerning custody, may become relevant in matrimonial proceedings.
F. Interfaith and Special Marriage Act Families
Where an interfaith marriage is solemnised under the Special Marriage Act, 1954, Section 38 empowers the District Court to make orders concerning custody, maintenance and education of minor children in proceedings under the Act.
Accordingly, the first question is not simply:
“Is the mother entitled to custody?”
or
“Is the father the natural guardian?”
The correct inquiry is:
What is the applicable legal framework, where does the child ordinarily reside, what proceedings exist in other jurisdictions, and what arrangement best serves the child’s welfare?
Guardians and Wards Act, 1890
Section 7 – Appointment or Declaration of Guardian
Section 7 enables the competent court, subject to the statutory requirements, to make an order regarding guardianship where necessary for the welfare of the minor.
Illustration
An Indian father works in Dubai while the mother lives in Chennai with their minor child.
The father’s higher income does not create an automatic right to custody. The court must examine whether the proposed guardianship and custody arrangement promotes the child’s welfare.
Section 9 – Ordinary Residence and Jurisdiction
Section 9 is particularly significant in NRI custody disputes.
For guardianship of the person of a minor, jurisdiction ordinarily depends upon the court where the minor ordinarily resides.
Ruchi Majoo v. Sanjeev Majoo, (2011) 6 SCC 479, is an important authority on this issue.
Illustration
A child has lived in Canada for seven years, attends school there and has an established family and social environment there.
A parent cannot necessarily create Indian jurisdiction merely by bringing the child to India for a short visit.
At the same time, foreign citizenship does not automatically deprive an Indian court of jurisdiction where Indian law otherwise confers jurisdiction.
Ordinary residence is ultimately a factual question.
Section 12 – Interim Protection and Custody
Section 12 permits interlocutory orders concerning the production and temporary custody or protection of a minor.
This can become important where there is a concern regarding:
- removal of the child;
- concealment;
- international relocation;
- disruption of an existing arrangement; or
- non-compliance with an interim custody order.
Illustration
If one parent fears that the other will remove the child from India while custody proceedings are pending, the court may, depending upon the facts, consider appropriate interim protective directions.
Section 17 – Welfare of the Minor
Section 17 is central to custody adjudication.
The court may consider:
- age of the child;
- sex and religion, where legally relevant;
- character and capacity of the proposed guardian;
- relationship between the child and the proposed guardian;
- circumstances of the guardian; and
- intelligent preference of a sufficiently mature child.
The statutory framework therefore places the welfare of the minor at the centre of the custody decision.
Hindu Minority and Guardianship Act, 1956
Where Hindu personal law applies, the HMGA becomes particularly relevant.
Section 6 – Natural Guardians
Section 6 identifies natural guardians of a Hindu minor subject to its statutory qualifications.
However:
Natural guardianship does not mean automatic physical custody.
A parent may have the status of natural guardian without automatically being entitled to have the child physically placed in that parent’s care.
Section 13 – Welfare Paramount
Section 13 expressly makes the welfare of the minor the paramount consideration in guardianship matters.
Muslim Personal Law and NRI Child Custody
Muslim custody disputes require particular care because Muslim personal law distinguishes between custody (hizanat) and guardianship.
Traditional rules concerning custody may depend upon:
- age;
- sex;
- personal circumstances;
- applicable school of Muslim law; and
- circumstances of the parents.
A personal-law claim should not, however, be treated as an absolute entitlement to physical custody.
Gohar Begam v. Suggi alias Nazma Begam, AIR 1960 SC 93; (1960) 1 SCR 597.
The Supreme Court considered a mother’s custody claim concerning her infant daughter and recognised the relevance of custody rights under Mohammedan law while considering the welfare of the child.
Personal-law rights are relevant, but custody remains connected with the welfare of the child.
Athar Hussain v. Syed Siraj Ahmed, (2010) 2 SCC 654; AIR 2010 SC 1417.
The Supreme Court considered the relationship between Muslim personal law and the Guardians and Wards Act and reaffirmed the importance of the welfare of the minor.
For an NRI Muslim family, therefore, the correct approach is neither:
“The mother has hizanat, therefore custody is automatically hers.”
Nor:
“The father is the legal guardian, therefore custody is automatically his.”
The court must consider personal law, statutory law and welfare together.
Christian Child Custody
Christian custody disputes may involve the Divorce Act, 1869, the Guardians and Wards Act, 1890 and other applicable provisions depending upon the relief sought.
Sections 41–44 of the Divorce Act specifically address custody of children in matrimonial proceedings.
Illustration
A Christian couple has lived in the United Kingdom for several years. Following separation, one parent brings the child to India.
The court may examine:
- ordinary residence;
- foreign proceedings;
- foreign custody orders;
- circumstances of relocation;
- parental relationships;
- education; and
- overall welfare.
The child’s physical presence in India does not, by itself, answer where the child should ultimately live.
Parsi Child Custody
For Parsi families, the Parsi Marriage and Divorce Act, 1936, including Section 49 concerning custody, may become relevant in matrimonial proceedings.
Illustration
A Parsi couple and their child have been living in Canada. After separation, one parent brings the child to Mumbai.
The court may examine:
- ordinary residence;
- foreign proceedings;
- established home;
- relationship with each parent;
- education;
- family support; and
- whether remaining in India or returning abroad serves the child’s welfare.
The family’s religious identity may form part of the legal framework, but the child’s welfare remains controlling.
Interfaith Marriages and the Special Marriage Act
Interfaith NRI marriages can create an additional layer of complexity.
The court may need to identify:
- how the marriage was solemnised;
- whether the Special Marriage Act applies;
- the child’s citizenship and legal status;
- applicable personal-law provisions;
- guardianship rights;
- foreign orders;
- ordinary residence; and
- welfare.
Where the marriage is under the Special Marriage Act, Section 38 specifically empowers the District Court to make appropriate orders concerning custody, maintenance and education of minor children.
Illustration
A Hindu mother and Muslim father live in Dubai. Their child attends school there. Following marital differences, the mother brings the child to India.
The court cannot simply assume that one parent’s religion determines custody. The legal framework must first be identified and then applied through the overriding welfare inquiry.
The Golden Rule: Welfare of the Child Is Paramount
The most consistent principle in Indian custody jurisprudence is that the welfare and best interests of the child are paramount.
In Nil Ratan Kundu v. Abhijit Kundu, (2008) 9 SCC 413, the Supreme Court emphasised the importance of the child’s physical and emotional well-being, education, health, development, surroundings and sufficiently mature wishes.
The court may therefore consider:
- physical safety;
- emotional security;
- psychological development;
- educational continuity;
- financial and caregiving stability;
- relationship with both parents;
- grandparents and extended family;
- cultural and social environment;
- child’s own views;
- impact of relocation; and
- effect of prolonged litigation.
A child is not an asset to be divided between parents.
Landmark Case Law on NRI and International Child Custody
Rosy Jacob v. Jacob A. Chakramakkal, (1973) 1 SCC 840; AIR 1973 SC 2090.
The Supreme Court treated the welfare of the children as the dominant consideration and recognised that custody arrangements can be modified when circumstances change and a different arrangement becomes necessary for welfare.
NRI relevance: Relocation, schooling, parental circumstances and changing needs may justify revisiting custody arrangements.
Surinder Kaur Sandhu v. Harbax Singh Sandhu, (1984) 3 SCC 698.
The Supreme Court stressed that custody must be determined primarily by reference to the welfare and interests of the child, rather than merely competing parental rights.
Elizabeth Dinshaw v. Arvand M. Dinshaw, (1987) 1 SCC 42.
The case involved a child brought to India despite custody arrangements in the United States.
The Supreme Court gave substantial importance to welfare and the circumstances surrounding removal from the foreign jurisdiction.
Significance: It remains a foundational authority concerning international custody and wrongful removal.
Nil Ratan Kundu v. Abhijit Kundu, (2008) 9 SCC 413.
The Supreme Court emphasised welfare as paramount and considered physical and emotional well-being, education, health, development, surroundings and the child’s sufficiently mature wishes.
It provides a strong general statement of the welfare principle across custody disputes.
V. Ravi Chandran (Dr.) v. Union of India, (2010) 1 SCC 174.
The case involved an international custody dispute where a child had been brought to India from the United States while foreign custody proceedings and orders existed.
The Supreme Court considered the foreign custody order and comity of courts, while distinguishing between a summary inquiry and an elaborate inquiry.
The Court directed return of the child in the circumstances of that case, leaving substantive custody issues to the competent foreign jurisdiction.
A foreign order is highly relevant, but the manner in which an Indian court proceeds remains dependent on the facts and welfare of the child.
Athar Hussain v. Syed Siraj Ahmed, (2010) 2 SCC 654; AIR 2010 SC 1417.
The Supreme Court considered Muslim personal law alongside the Guardians and Wards Act and emphasised that personal-law principles cannot displace what is conducive to the welfare of the minor.
Ruchi Majoo v. Sanjeev Majoo, (2011) 6 SCC 479.
The case involved an Indian family connected with the United States, foreign proceedings concerning custody and the presence of the mother and child in India.
The Supreme Court considered:
- Section 9 of the Guardians and Wards Act;
- ordinary residence;
- foreign proceedings;
- comity; and
- visitation.
The existence of foreign proceedings did not automatically remove the responsibility of Indian courts.
Significance: A leading authority on ordinary residence, jurisdiction, foreign proceedings, comity and visitation.
Surya Vadanan v. State of Tamil Nadu, (2015) 5 SCC 450.
The case involved children with strong connections to the United Kingdom and proceedings concerning their custody there.
The Supreme Court gave substantial weight, in the circumstances, to the children’s connection with the foreign jurisdiction, foreign orders and comity.
Indian courts can direct return of children to a foreign jurisdiction where circumstances justify it.
The decision must, however, be read alongside later authorities including Nithya Anand Raghavan and Lahari Sakhamuri, which emphasise a fact-sensitive approach.
Nithya Anand Raghavan v. State (NCT of Delhi), (2017) 8 SCC 454.
The Supreme Court considered a child brought to India from a foreign jurisdiction where foreign proceedings and orders existed.
The Court explained that an Indian court may conduct either a summary inquiry or an elaborate inquiry, depending upon the circumstances.
A foreign custody order is important but not automatically conclusive.
Relevant considerations may include:
- welfare;
- ordinary residence;
- relationship with both parents;
- circumstances of removal;
- possibility of harm;
- psychological well-being; and
- overall circumstances.
Comity of courts is important, but it cannot be applied mechanically at the expense of the child’s welfare.
Lahari Sakhamuri v. Sobhan Kodali, (2019) 7 SCC 311.
The case involved children born in the United States who were US citizens and had substantial connections with the United States.
The Supreme Court considered:
- foreign citizenship;
- foreign proceedings;
- intimate connection with the foreign country;
- comity; and
- welfare.
Significance: Foreign citizenship and foreign connection are relevant but not independently decisive of custody.
Yashita Sahu v. State of Rajasthan, (2020) 3 SCC 67.
The parents had lived in the United States and their daughter was a US citizen. The mother brought the child to India while proceedings were pending in the United States.
The Supreme Court considered earlier international custody authorities and placed considerable emphasis on:
- welfare;
- meaningful relationship with both parents;
- visitation;
- parental access;
- video communication;
- international custody; and
- habeas corpus jurisdiction.
Custody with one parent should not ordinarily become exclusion of the other parent from the child’s life where meaningful contact is safe and appropriate.
Foreign Court Orders: Must an Indian Court Automatically Follow Them?
No—not automatically.
A foreign custody order is an important factor, but Indian courts have repeatedly recognised that international custody disputes cannot be resolved through mechanical enforcement of foreign orders without considering welfare and the circumstances of the case.
| Factor | Legal significance |
|---|---|
| Foreign custody order | Important consideration |
| Foreign citizenship | Relevant but not conclusive |
| Ordinary residence | Important jurisdictional and factual factor |
| Foreign proceedings | Relevant |
| Comity of courts | Important judicial principle |
| Circumstances of removal | Highly relevant |
| Child’s wishes | Relevant where sufficiently mature |
| Welfare of child | Paramount consideration |
This balance emerges particularly from Ruchi Majoo, V. Ravi Chandran, Nithya Anand Raghavan, Lahari Sakhamuri and Yashita Sahu.
Summary Inquiry vs Elaborate Inquiry
A significant development in international custody jurisprudence is the distinction between a summary inquiry and an elaborate inquiry.
Summary Inquiry
Where circumstances permit, the court may examine whether the child should return to the jurisdiction more appropriately connected with the custody dispute.
Elaborate Inquiry
Where circumstances require a deeper examination, the court may investigate:
- welfare;
- safety;
- emotional circumstances;
- parental capability;
- schooling;
- existing caregiving arrangements;
- circumstances of removal;
- risk of harm;
- child’s wishes; and
- consequences of relocation.
V. Ravi Chandran and Nithya Anand Raghavan demonstrate that there is no universal mechanical formula for every international custody dispute.
Does Foreign Citizenship Decide Custody?
No.
A child may have Indian citizenship, foreign citizenship, dual nationality where legally permissible, or another immigration status.
Citizenship can indicate a child’s connection with a particular country, but it does not automatically confer custody upon either parent.
Lahari Sakhamuri v. Sobhan Kodali is particularly relevant.
The ultimate question remains:
What arrangement best protects the child’s welfare and best interests?
Can a Parent Permanently Take an NRI Child to India?
A parent should not unilaterally relocate a child internationally without first considering:
- existing custody orders;
- consent requirements;
- ordinary residence;
- foreign proceedings;
- immigration consequences;
- Indian law;
- foreign law; and
- consequences of wrongful removal.
Illustration
A child has lived in Australia since birth. The mother brings the child to India without the father’s consent while an Australian custody proceeding is pending.
Physical possession in India does not automatically become legal custody.
The Indian court may examine the circumstances of removal, foreign proceedings, ordinary residence and the child’s welfare.
The Child’s Relationship with Both Parents
Modern custody jurisprudence increasingly recognises that welfare may include maintaining a meaningful relationship with both parents, where contact is safe and appropriate.
This may include:
- physical visitation;
- weekend or holiday access;
- video calls;
- telephone communication;
- access to school information;
- sharing medical information;
- participation in important decisions;
- vacation arrangements; and
- contact with grandparents and extended family.
Yashita Sahu v. State of Rajasthan is particularly significant in this regard.
Senior Counsel’s Approach
Do not ask only, “Who gets custody?” Ask also, “How will the child continue to have a healthy and meaningful relationship with the other parent?”
The Child’s Own Wishes
Where a child is sufficiently mature to form an intelligent preference, the court may consider that preference.
However, the child’s wishes are not automatically decisive.
The court may need to distinguish between:
- a genuine and mature preference; and
- a preference influenced by parental pressure, coaching, fear or manipulation.
The child’s wishes are therefore one component of the wider welfare assessment.
Wrongful Removal and International Relocation
Cross-border removal can fundamentally alter a custody dispute.
The parent who brings the child to India may argue that:
- the child is now settled in India;
- the child has developed family relationships here;
- the child attends school here; or
- return would cause emotional disruption.
The other parent may argue that:
- removal was unauthorised;
- the child ordinarily resided abroad;
- a foreign custody order exists;
- proceedings are pending abroad; or
- the child should be restored to the foreign jurisdiction.
Indian courts have considered these competing factors in cases including:
- Elizabeth Dinshaw;
- V. Ravi Chandran;
- Surya Vadanan;
- Nithya Anand Raghavan;
- Lahari Sakhamuri; and
- Yashita Sahu.
The governing approach remains fact-specific and welfare-centred.
What Has Changed Since the Norway Dispute?
It would be legally inaccurate to say that the Guardians and Wards Act, 1890 or Hindu Minority and Guardianship Act, 1956 was comprehensively amended specifically because of the Norway dispute.
The more significant development has been judicial interpretation and the evolution of Supreme Court jurisprudence.
Modern international custody analysis may require consideration of:
- Guardians and Wards Act, 1890;
- Hindu Minority and Guardianship Act, 1956;
- Muslim personal law;
- Christian custody provisions;
- Parsi custody provisions;
- Special Marriage Act, 1954;
- constitutional jurisdiction;
- foreign law;
- foreign custody orders; and
- Supreme Court jurisprudence on international custody.
The principal development has therefore been judicial rather than a Norway-specific statutory amendment.
How the Welfare Principle Protects the Child
A welfare-centred approach has practical consequences.
Emotional Stability
A child should not be treated as an object to be divided between competing parents.
Physical Safety
Allegations of abuse, neglect or violence require appropriate judicial attention.
Psychological Well-being
The court may consider the psychological impact of prolonged litigation and repeated relocation.
Educational Continuity
Schooling, educational development and established social surroundings may be relevant.
Stable Living Arrangements
An established home and consistent caregiving relationship can carry considerable weight.
Relationship With Both Parents
Where safe and appropriate, the child should be able to maintain meaningful relationships with both parents.
Family and Cultural Continuity
Relationships with grandparents, relatives and cultural communities may also be relevant.
When Should an NRI Parent Seek Immediate Legal Advice?
Urgent legal advice should be considered where:
- the child is about to be taken abroad;
- the child has already been removed from India;
- a foreign custody or return order exists;
- court-ordered visitation is being refused;
- permanent relocation is threatened;
- the child is being concealed;
- parallel proceedings exist in India and another country; or
- there are allegations of abuse, neglect or other risks.
International custody disputes can involve time-sensitive jurisdictional and procedural issues. Early legal assessment can therefore be strategically important.
Practical Checklist for NRI Parents
Before commencing or defending an international custody case, preserve:
- Child’s birth certificate.
- Passport and citizenship documents.
- Immigration records.
- School records.
- Medical records.
- Foreign custody orders.
- Indian court orders.
- Evidence of ordinary residence.
- Travel records.
- Evidence concerning relocation.
- Communications between parents.
- Evidence concerning abuse or neglect allegations.
- Evidence of the child’s relationship with each parent.
- Evidence concerning the child’s educational and social environment.
Most importantly:
Do not unilaterally relocate a child internationally without first obtaining appropriate legal advice.
Frequently Asked Questions
The Core Legal Position — In a Nutshell
The Supreme Court’s international custody jurisprudence can broadly be reduced to five propositions:
- Personal law matters—but is not the whole answer. Hindu, Muslim, Christian, Parsi and other applicable legal frameworks may affect parental rights.
- Natural guardianship does not automatically mean physical custody. A parent may have guardianship status without being entitled to physical custody.
- Foreign orders matter—but are not automatically decisive. Comity is important, but it cannot replace the welfare inquiry.
- Foreign citizenship and ordinary residence matter—but neither alone determines custody. The entire factual matrix must be considered.
- Welfare is paramount. This remains the controlling principle across the leading authorities.
Conclusion: In International Custody, the Child Is the Centre of the Court’s Inquiry
International child custody is not simply about which parent wins.
It is about where the child can live safely, develop emotionally, continue education, maintain stability and, where appropriate, preserve meaningful relationships with both parents and both sides of the family.
For Hindu, Muslim, Christian, Parsi, interfaith and Special Marriage Act families, the applicable legal framework may differ. But the central judicial question remains:
What serves the best interests and welfare of this particular child?
The Supreme Court decisions in Elizabeth Dinshaw, V. Ravi Chandran, Ruchi Majoo, Nithya Anand Raghavan, Lahari Sakhamuri and Yashita Sahu, read with the broader welfare jurisprudence of Rosy Jacob, Surinder Kaur Sandhu and Nil Ratan Kundu, provide the foundation for understanding international child custody in India.
For an NRI parent facing a cross-border custody dispute, early legal advice is critical. Delay in assessing jurisdiction, ordinary residence, foreign proceedings, existing orders, relocation risks and the child’s welfare can materially affect litigation strategy.
The strongest custody case is not necessarily the case of the parent with the strongest legal entitlement. It is the case that most convincingly demonstrates what is genuinely in the child’s best interests.
Key Authorities
- Gohar Begam v. Suggi alias Nazma Begam, AIR 1960 SC 93; (1960) 1 SCR 597.
- Rosy Jacob v. Jacob A. Chakramakkal, (1973) 1 SCC 840.
- Surinder Kaur Sandhu v. Harbax Singh Sandhu, (1984) 3 SCC 698.
- Elizabeth Dinshaw v. Arvand M. Dinshaw, (1987) 1 SCC 42.
- Chandrakala Menon v. Vipin Menon, (1993) 2 SCC 6.
- Nil Ratan Kundu v. Abhijit Kundu, (2008) 9 SCC 413.
- V. Ravi Chandran (Dr.) v. Union of India, (2010) 1 SCC 174.
- Athar Hussain v. Syed Siraj Ahmed, (2010) 2 SCC 654.
- Ruchi Majoo v. Sanjeev Majoo, (2011) 6 SCC 479.
- Surya Vadanan v. State of Tamil Nadu, (2015) 5 SCC 450.
- Nithya Anand Raghavan v. State (NCT of Delhi), (2017) 8 SCC 454.
- Lahari Sakhamuri v. Sobhan Kodali, (2019) 7 SCC 311.
- Yashita Sahu v. State of Rajasthan, (2020) 3 SCC 67.
© RRC Law Associates