Saturday, September 21, 2013

Uniform Civil Code - Article 44: A Dead Letter in the Constitution?



Introduction
Today, with a deepening of democratic processes, each caste and community is becoming more conscious of its identity and today our polity is mainly based on these identities. Politicians have been fighting elections mainly on the basis of caste and communities and have thus aggravated the feeling of identities. In Rajasthan, when Roop Kanwar committed Sati, the Rajputs defended it as a matter of their identity. The Rajput youth stood with swords to defend the memorial created there.
Democracy in a country like India, with its pluralist tradition lasting over thousands of years cannot succeed without respecting pluralist ethos. It is interesting to note that the west has discovered pluralism recently after Second World War and hence call it post-modernist phenomenon. But India has known it even during the medieval ages.
Modernization has brought new problems though we have begun to imitate the west yet we have failed to recognize the intractable social structure; changes are embraced much more easily in the upper class economic elite in stark contrast to the masses. This is much more so as far as Muslims are concerned. This is much greater degree of poverty and illiteracy among them compared to other communities. There is a very weak middle class among them to advocate modernization and change. This is precisely why the priestly class, which itself comes from the poor strata, has a much greater hold over the community.
And yes, we have to find a solution to the problem of gender discrimination in the given laws in all communities. How to go about it? This is given raise to think about the framing of a common civil code. But when we remember the issues like Rajput’s one as mentioned earlier, it is very difficult in such a political atmosphere to think of enacting a Uniform Civil Code (here-in-after referred to as ‘UCC’). The caste practices among Hindus are far more important than any law of the country. Each caste has its own customs and traditions, which supersede all laws of the country. In several parts of U.P., if any boy of lower caste marries a girl of upper caste, they are publicly beheaded.
The reality in India is much more complex than western societies, which have been totally secularized. The process of secularization in India, though not negligible, is yet far more slow and tortuous. And no law, however ideal, can become acceptable if it alienates people and ignores social realities. A law has to be socially rooted, in order to be acceptable.
What is a Civil Code?
The civil code is a set of laws governing the civil matters of the citizens in the country relating to matters like marriage, divorce, adoption, custody of children, inheritance, succession to property etc.
The Common Civil Code if enacted will deal with the personal laws of all religious communities relating to the above matters which are all secular in character of Indian state and to enhance fraternity of unity among citizens by providing them with a set of personal laws which incorporates the basic values of humanism.
The Need for a Uniform Civil Code
The need for a UCC was felt as soon as the constitution came into force. Even after 55 years, this directive could not be implemented for reasons better known to all those concerned with this directive. The UCC also aims to overcome the particularistic and often reactionary aspects of personal laws of various religious communities. The objective thus is also to bring a social reform and uplifting the status of women. The UCC is eminently desirable in the interest of modernization of society and for a common system of Justice for all.
The absence of UCC gives rise to piquant, unwarranted and ugly situations. In the words of court: Marriage is the very foundation of civilized society. The relation once formed, the law steps in and binds the parties to various obligations and liabilities there under. Marriage is not an institution in maintenance of which the public at large is deeply interested. It is the foundation of the family and in turn of society without which no civilization can exist. Till the time, we achieve the government uniform civil code for all the citizens into second marriage while the first marriage is subsisting to become a Muslim. Since monogamy is the law for Hindus and the Muslim law permits as many as four wives in India, errand Hindu husband embraces Islam to circumvent the provisions of the Hindu law and escape from penal consequences.”
The provisions of the Indian Constitution
Part III of the constitution that is, Article 12 to Article 35 provides for fundamental rights, which are enforceable by the High Courts of the various states and the Supreme Court of India. Part IV of the constitution provides for socio-economic rights styled as Directive Principles of state policy and are not enforceable by any court of law. However, Article 37 clarifies that such directive principles “are nevertheless fundamental in the governance of the country and it shall be the duty of the state to apply these principles in making laws.”
Under Part IV of the Constitution, Article 44, states that “the state shall endeavor to enact a Uniform Civil Code for citizens throughout the country”. On the other hand, under Part III of the Constitution, Article 25 provides” Freedom of conscience and free profession, practice and propagation of religion.” The tussle is mainly between these two articles.
The Supreme Court since two decades has started a trend (which is now considered to be a well settled law) that the Directive Principles and Fundamental Rights ought to be harmoniously constituted, and whenever possible fundamental Rights should be adjusted in their ambit so as to give effect to the trend can manifestly be evinced in ABK Singh v.Union of India[1], followed by Woman Rao v. Union of India[2] and Griha Kalyan Kendra Worker’s Union v. Union of India[3].
It is the state, which is charged with the duty of securing a UCC for the citizens of the country and unquestionably, it has the legislative competence to do so.
Development so far in the domain of UCC
The Constitution of India came into force in 1950. Since then, Article 44 has been gathering dust with no government at the centre ever having any guts and wisdom to touch it. This tragic situation certainly buries the spirit of the constitution a thousand fathoms deep.
 Of course, article 44 was not drafted without uproar and objections in the constituent assembly against the making of UCC for the entire nation.[4] Firstly, it would infringe the fundamental right to freedom of religion enshrined in article 25 and secondly, it would be highly derogative to the interests of the minorities. It is submitted that the first objection is highly misconceived as the objective contained in article 44 in no way offends religious freedom of faith and guarantee article under 25 sub clause (b) of clause (2) provides an exception to the effect that any existing or future laws providing for the social welfare and reform shall not be affected by the operation of this article. As regards the second objection that the enactment would be tyrannical to minorities, Shri K.M. Munshi a member of drafting committee in the constituent assembly said that nowhere in the advised Muslim countries the personal law of each minority has been recognized as a sacrosanct as to prevent the enactment of a civil code.
Pundit Jawaharlal Nehru, while defending the introduction of the Hindu Code Bill instead of a UCC in parliament in 1954, said “I don’t think at the present moments the time is ripe in India for me to try to push is through”. It appears that even 51 years thereafter, the rulers of the day are not willing to retrieve article 44 from the cold storage where it is lying since 1949. The governments, which have come and gone, have so far failed to make any effort towards unified personal law for all Indians.
The broad approach of the Judiciary can be well appreciated at this Juncture in the development and discussion in the domain of UCC. A Constitution bench speaking through Justice Y.V.Chandrachud in Mohd. Ahmed Khan v. Shah Bano Begum[5] observed:
                           It is a matter of regret that article 44 of our constitution has remained a dead letter… It provides that the state shall endeavor to secure a uniform civil code for the citizens throughout the territory of India. There is no evidence of any official activity for framing a uniform civil code for the country. A belief seems to have gained ground that it is for the muslim community to take a lead in the matter of reforms of their personal law. A common Civil Code will help the cause of national integration by removing disparate loyalties to laws, which have conflict ideologies. No community is likely to bell the cat by making gratuitous concessions on this issue.”
The Supreme Court has reiterated the same in the famous Sarla Mudgal Case[6] of 1995. After this, on July 23, 2003, the Hon’ble Supreme Court has suggested that parliament has to frame a common civil code for the country as that would help the cause of national integration. A three judge bench comprising the Chief Justice V.N. Khare, Justice S.B. Sinha and Justice. A.R. Lakshmanan, made this suggestion while declaring as unconstitutional section 118 of the Indian Succession Act, 1925 (ISA) on the ground that it was arbitrary, irrational and violated Article 14 of the constitution, which says that the state shall not deny to any person equality before law or the equal protection of the laws within the territory of India.
Under section 118 of the ISA, applicable only to Christians, “No man having a nephew or niece or any nearer relative shall have power to bequeath any property to religious or charitable uses, except by a will executed not less than 12 months before his death and deposited within six months from its execution I some place provided by law for safe custody of the will of living persons.”
The bench was allowing a writ petition from a Christian priest, John Vallamatton, challenging the provision as it discriminated against Christians bequeathing their property for charitable and religious purposes. Writing the main judgment, the Chief Justice observed, “It is a matter of regret that article 44 of the constitution has not been given effect to.”
But, the reactions of many religious groups against the Supreme Court ruling on implementation of UCC sank in a surprise. The All India Muslim Personal Law Board (AIMPLB) has rejected outright the Supreme Court observations on enforcement of a uniform civil code, saying such a law could not be imposed on any particular religion.
Mohammed Rabe Hasan Nadwi, chairman of the AIMPLB in the year 2003 said that it is the consistent stand of the AlMPLB that a uniform civil code is not feasible in India, as no community would like to lose the rights and privileges granted to it by its personal law based on religion. Saiba Farooqui, general secretary of the voluntary group national federation of Indian women, said, “The court should have avoided such comments in the current situation of the country.” Though she opposes the Muslim personal law, she feels it should not be interfered with at present.
Arguments ‘For’ the enforcement of UCC
  1. The Common Civil Code will bring all the personal laws governing matters like marriage, divorce, adoption, inheritance, succession to property etc. under a single roof and creates a space for the practices of all communities in a just manner and integrates the values and ideals of humanism.
  2. The one common argument given by all the political parties highlighting their reluctance to implement the Uniform Civil Code is that implementing Article 44 violates the rights of Indians provided under Article 25 i.e., “Freedom of conscience and free profession, practice and propagation of religion.” The counter argument I would like to cite is present in the same Article 25 itself under Clause 2, where it is clearly indicated that this article shall not affect the operation of any existing law.
  3. With the non-implementation of Article 44 of the constitution, article 14 to 18 are being violated which provides for Right of equality and prohibition of discrimination on the grounds of sex and religion. Many personal laws relating to marriage, inheritance, guardianship, divorce, adoption and property relations in all communities are unjust – especially unjust to women.  
  4. Ambiguity is created due to the presence of different laws governing a social institution such as marriage, particularly in the case of polygamy and divorce. Also, possibility of a separate law for Muslims under the Muslim Personal Law supporting child marriage based on Shariat.
  5. It creates an uneasy division on the basis of religion when certain people are given special status. When even the law of the land is not the same for all people in India, it becomes increasingly difficult to preach equality among the citizens.
  6. All laws including penal laws are applied to one and all in this country without any distinction as to religion, race, caste, creed, sex etc… The anomaly is that it is not so apropos of Muslim personal law. The matters vis-à-vis marriage, inheritance, divorce, Muslim personal law governs conversions etc. in Muslim religion. There is an urgent need to rectify this uneven and higgledy-piggledy situation so as to bring light in the lives if Muslim womenfolk in India. One country and one law shall be the lodestar.
  7. Much misapprehension prevails about bigamy in Islam. Ironically, Islamic countries like Syria, Tunisia, Morocco, Pakistan, Iran etc have codified the personal law where in the practice of polygamy has been either totally prohibited or severely curtailed to check the misuse and abuse of this obnoxious practice.
The tragedy is that a secular country like India is lagging behind in according red carpet welcome to article 44.
Arguments ‘Against’ the enforcement of UCC
1.      All the personal civil codes have unjust laws pertaining to women and children. These have to be changed, not on the principle of uniformity but on equality and justice to the ignored and downtrodden. If all the communities can sit together and remove the injustices in their personal laws, uniformity will inevitably come about. What is now needed is not a Uniform civil code, but a just civil code.
2.      After having a kind perusal at the Supreme Court’s observations, no matter how, good intentioned the judges may be but such issues will only cause problems. It is true that women are not getting Justice in Muslim personal law. But any such reform has to come from within the Muslim women. Law is not the solution. In such a hostile situation, Muslims would not be ready to accept a uniform code.
3.      Muslims are educationally and economically backward. If the government is really concerned about the equality then they should work on these fields rather than touching the emotional issue of Uniform Civil Code and also it depends on the government’s urge to implement it.
4.      The foremost argument of AIMPLB is that, Sharia (Islamic Law) is an integral part of Islam; implementation of Uniform Civil Code would mean depriving Muslims and many communities from their personal laws and fundamental right to religion. Sharia is a law made by god. Any human being does not make it. Therefore, nobody has the right to intervene into it. Not even the Muslims.
5.      The ideal of secularism cannot be achieved unless the right to religion and certain conventions based on religion give a place of preference and permanence to the directive contained in article 44 of the constitution. Therefore, it is the utmost needs of the present times to achieve uniformity in social relations, which would be the foundation on to build a unified, integrated and the strongest democracy in the world. Then comes the glorious suggestion of Supreme Court to enact a uniform civil code in order t`o strengthen the feeling of oneness among all religious sects to preserve the unity and integrity of India.
6.      Uniform personal law is purely political – a communal weapon to chastise Muslims with false argument that Hindus have a code, and to force Muslims to yield one. Hindus did not codify the joint family property law, which entrusted power and wealth to men. But, that is beside the point. Do we want a Uniform civil code (really uniform personal laws) for its own political sake to give the BJP and others a communal edge in politics or for genuine justice reasons?

Conclusion
The Indian constitution envisages a secular state by guaranteeing religious freedom to all under the umbrella of a religion free state. This is apparent from an examination of articles 25 to 30. The religious freedom is however subject to certain limitations. Similarly, though the state is forbidden from propagating or promoting any religion, it can constitute a general fund through taxation for the promotion and maintenance of all religions, and to provide aid in suitable cases, without discrimination. These provisions clearly indicate the great role played by religion in certain aspects of our life. It is true that in bringing a common code for all religions is no easy task for the legislature. Indian secularism has, therefore, to develop the philosophy of coexistence. To achieve the philosophy of coexistence the support of two powerful factors are necessary- a high degree of tolerance by all religions sects and strict adherence by all concerned to the principles of equality and nondiscrimination, which are the keystones of our constitutional edifice.
The founding fathers placed article 44 in the directive principles of state policy within through fundamental in governance of the country do not lay the state under a positive obligation enforceable either by legal or constitutional means. Moreover, the language in which it is couched itself seems to express a hope rather than issue a mandate. Nevertheless, the legislature is under no less an obligation to achieve the most ideal goal set out by the article. These are no more religious issues but rather social issues which are affecting the human populace and relationships among them.
In pursuance of the goal of secularism, the state must stop administering religion based personal laws.  The researcher asserts that whether the lead comes from majority community or not, the state must act. Every rational being committed to secular principles accepts this view, as it is the duty of the state to achieve national harmony through the implementation of the directive enshrined under Part IV of the constitution.
Despite the progressive judicial pronouncements and juristic opinions in favour of carrying out the directive under article 44 of the constitution, parliament has done nothing to achieve this noble ideal. At this juncture, Justice Kuldip singh’s candid observations deserve and demand to be accorded a red carpet welcome. He stated:[7]
The traditional Hindu law – personal law of the Hindus – governing inheritance, succession and marriage was given a go by as back 1955-56 by codifying the same. There is no justification whatsoever in delaying indefinitely the introduction of uniform personal law in the country. The learned judge proceeded further to observe that those who preferred to remain in India after the partition, were aware of the fact that Indian leaders did not believe in the two nation theory or three nation theory and also that in Indian republic there would be only one nation – Indian nation and no community could make a claim to be a separate entity on the basis of the religion. Not only could a lawman, even a layman, appreciate this judgment.
However, everything depends upon the government’s urge to implement it. If the government makes it compulsory that everybody will have to wear helmet while driving, then will it ask Sikhs to take off their turbans? Or if the government legalizes the abortion to control population growth, will the Christians accept it? Or if the government legalizes killing of cows, will it not hurt Hindus? So, it has to be dealt with carefully. Religion is a sentimental and sacred issue in India. Government should listen to everybody before doing anything. It is high time that the Government takes some concrete action in order to implement the Uniform Civil Code rather than dilly-dallying around the issue for the sake of short-term political gains.  But nothing can be done overnight. A slow, steady and a persuasive approach are necessary because justice delayed is justice denied but if justice is hurried, justice may be buried. No matter, how arduous and long stand the task be, the legislature should leave no stone unturned in achieving this constitutional ideal. But bringing uniform legislation should not jeopardize the harmony of distribution of legislative powers envisaged in VII schedule of the constitution.












REFERENCES

       ARTICLES

1)                 B.G. Verghese, Who is afraid of a Uniform Civil Code? The Hindu (13/8/2003)
2)                 Personal Laws and Common Sense, The Hindu (28/7/2003)
3)                 Supreme court suggest framing of a common civil code, The Hindu (23/7/2003)
4)                 Vir Sanghvi, Towards a Uniform Civil Code, Sunday Hindustan Times (10/8/2003)
5)                 Do we need a uniform civil code? Hindustan Times (30/72003)
6)                 A.G. Noorani, UCC: Keep the faith, Hindustan Times (28/7/2003)
7)                 Babir K. Punj, Common chord – A Uniform approach to the Law, Times of India (15/8/2003)
8)                 BJP welcomes court suggestion on common civil code, The Hindu (24/7/2003)
9)                 Who is for a Common Civil Code? Hindustan Times, (22/1/2004)
10)             Religious groups unhappy with SC’s remarks on UCC, Hindustan Times, (23/7/2003)
11)             J.Venkatesan, SC suggests framing of a Common Civil Code, The Hindu, (24/7/2003)
12)             Chandan Mitra, What if we had a Uniform Civil Code, The pioneer (August, 2003)
13)             Rakesh Bhatnagar, The long wait for Uniform Civil Code, Times of India, (March 4, 1997)
14)             Christopher Jaffrelot, Ambedkar and the Uniform Civil Code, Ambedkar and untouchability- analyzing and fighting Castes, Permanent Blach Publications 2004
15)             Ms. Ritu Raj, Uniform Civil Code and National Integration, Competition Success Review, November 2003
16)             V.R. Krishna Iyer, Unifying Persona Laws, The Hindu (8-7-2003)
17)             Rajeev Dhawan, Codifying Personal Laws, The Hindu (1-8-2003)

JOURNALS

1)              Too personal to be Uniform? Lawyer’s Collective, July 2003
2)              D. Sura Reddy, Article 44: Adead Letter? Journal of Indian Law Institute, 1996.
3)              Satyanarayana, Uniform Civil Code: A myth? Cochin University Law review, 1986.





[1] AIR 1981 SC 298
[2] AIR 1982 SC 232
[3] (1991) 1 SCC 611
[4] C.A.D. (Constituent Assembly Debates) Vol II pp.546-548
[5] 1985 2 SCC 556
[6] 1995 3 SCC 635
[7] Supra note. 5

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