JOURNAL OF THE INDIAN LAW INSTITUTE

This article examines the development of women’s inheritance rights in England, Canada, and India. These countries share an English common-law heritage. However, all three have followed distinctly divergent paths in the area of women’s inheritance rights.

This article begins with a brief overview of the different personal laws in India under which women may be able to claim maintenance as well as of the relevant provision (Section 125) in the Code of the Criminal Procedure. The author examines the Indian Supreme Court's decision in Yamunabai's case, arguing that the case demonstrates how the law has been applied unfairly towards women who have entered void marriages.