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Core idea: Article 44 (Directive Principle, Part IV) says: ‘The State shall endeavour to secure for the citizens a uniform civil code throughout the territory of India.’ It is non-justiciable (Article 37). The debate is between equality and gender justice (Articles 14, 15) and religious freedom and cultural pluralism (Articles 25–29). As of 2026 there is still no national UCC; Goa has a historic common code, and Uttarakhand (2024) and Gujarat (2026) have enacted State UCCs.
Covers Constituent Assembly (23 November 1948), Related provisions, Goa.
Related provisions
Goa
Constituent Assembly (23 November 1948): Draft Article 35 (now 44) was debated; Muslim members sought a proviso protecting personal laws; Dr. Ambedkar, K.M. Munshi and others supported the provision; it was adopted as a Directive Principle on the understanding that it would be enacted when society was ready.
Related provisions: Article 25(2)(b) (State may regulate social welfare and reform), Article 13, Entry 5 of List III, Article 254 (a State UCC that conflicts with a Central law needs Presidential assent), Article 371A and Sixth Schedule (tribal customs).
Goa: the Goa, Daman and Diu Administration Act 1962 continued the Portuguese Civil Code 1867 as the Goa Civil Code; the Supreme Court in Jose Paulo Coutinho v Maria Luiza Valentina Pereira (2019) described Goa as a shining example of a State with a uniform civil code, while noting that the Goa code recognises some religion-based exceptions (verify).
Case Point Mohd. Ahmed Khan v Shah Bano Begum (1985) Chandrachud CJ: a common civil code will help national integration by removing disparate loyalties to laws having…
Case
Point
Mohd. Ahmed Khan v Shah Bano Begum (1985)
Chandrachud CJ: a common civil code will help national integration by removing disparate loyalties to laws having conflicting ideologies; regretted that Article 44 remained a dead letter
Jordan Diengdeh v S.S. Chopra (1985)
Urged Parliament to frame a UCC; the divorce laws of Christians and others needed uniformity
Sarla Mudgal v Union of India (1995)
Kuldip Singh J.: conversion to Islam to marry again does not dissolve the first marriage; second marriage is bigamy; urged the government to take steps for a UCC
Ahmedabad Women Action Group v Union of India (1997)
The Court declined to strike personal laws as discriminatory, saying it is for Parliament
Lily Thomas v Union of India (2000)
Reaffirmed Sarla Mudgal; conversion does not defeat Section 494 IPC
John Vallamattom v Union of India (2003)
Section 118 ISA struck down; CJ Khare said that Article 44 should be implemented
Danial Latifi (2001)
Upheld the 1986 Act but read it to secure equality
Shayara Bano (2017)
Triple talaq void (3:2); a UCC was not decided; the minority (Khehar CJ and Nazeer J.) asked Parliament to legislate on Muslim marriage and divorce
Jose Paulo Coutinho (2019)
Goa Civil Code and Article 44; urged Parliament to take a fresh look
Covers 21st Law Commission (2018), 22nd Law Commission (14 June 2023), Prime Minister (Independence Day 2024), Assam (2024).
21st Law Commission (2018)
Assam (2024)
21st Law Commission (2018): Consultation Paper on Reform of Family Law: a UCC is ‘neither necessary nor desirable at this stage’; reform personal laws to remove discrimination instead.
22nd Law Commission (14 June 2023): invited public views on a UCC (renewed consultation); no final report on UCC was published at the last report (verify).
Prime Minister (Independence Day 2024): called for a ‘secular civil code’ (reported).
Assam (2024): the Assam Muslim Marriages and Divorces Registration Act 1935 was repealed and a compulsory registration law was enacted (verify).
10.4Uttarakhand Uniform Civil Code Act 2024 (first State UCC)#
In brief
Covers Process, Scope, Key features, Challenge.
Process
February 2024
March 2024
January 2025
Scope
Key features
mandatory registration
Challenge
Process: committee headed by Justice (retd.) Ranjana Prakash Desai; Bill passed by the State Assembly in February 2024; Presidential assent in March 2024; brought into force in January 2025 after rules were notified (reported; verify exact dates).
Scope: applies to residents of Uttarakhand (also residents living outside the State) and excludes Scheduled Tribes and persons whose customary rights are protected by the Constitution; covers marriage and divorce, succession (wills and intestate), live-in relationships, and miscellaneous provisions.
Key features: equal marriage age (21 for men, 18 for women); monogamy (bigamy prohibited); mandatory registration of marriages and divorces; equal grounds of divorce for men and women; prohibition of practices such as triple talaq, halala and iddat; marriages and divorces by religious customs allowed as to ceremonies but not to substance; equal inheritance rights for sons and daughters; children of void or voidable marriages and live-in relationships treated as legitimate; adopted and biological children treated alike; live-in relationships to be registered and terminated with notice.
Challenge: petitions have been filed in the High Court against the live-in registration and other provisions (verify status).
Process: committee chaired by Justice (retd.) Ranjana Prakash Desai; Bill introduced on 24 March 2026, passed the same day by the Gujarat Assembly after about seven and a half hours’ debate; Presidential assent reported in early October 2026; the State must notify rules before it comes into force (reported; verify).
Scope: Marriage and divorce, succession and live-in relationships; applies to residents of Gujarat and to Gujarat residents living outside the State; excludes Scheduled Tribes and groups whose customary rights are protected by the Constitution.
Reported features: registration of live-in relationships and of their termination; prohibition of bigamy (a marriage is valid only if neither party has a living spouse); all separations must be through civil courts (reportedly ending extra-judicial or customary divorce); compulsory registration of marriages; common succession framework.
Opposition: concerns that it is politically driven and may infringe religious freedom and fundamental rights.
For Against Gender justice and equality; national integration; removes discriminatory customs (triple talaq, unequal inheritance); modernisation; Article 44 mandate…
For
Against
Gender justice and equality; national integration; removes discriminatory customs (triple talaq, unequal inheritance); modernisation; Article 44 mandate
Threatens religious freedom (Article 25) and minority cultural rights (Article 29); diversity of customs (tribal, Christian, Sikh); the 2018 Law Commission view; reform within each community preferable; risk of majoritarian codification
States are laboratories: Entry 5, List III permits State action
A ‘uniform’ code ‘throughout the territory of India’ implies a national law; State UCCs create patchwork and Article 254 issues
Covers Narasu Appa Mali (1952), Reform by consent vs imposition.
Narasu Appa Mali (1952)
Essential religious practices test (Shirur Mutt, 1954) and its use in triple talaq (Shayara Bano), Sabarimala (2018, Indian Young Lawyers Association v State of Kerala) and Hijab cases.
Narasu Appa Mali (1952) and the question whether personal laws are subject to fundamental rights (unsettled).
Reform by consent vs imposition: the UCC can be enacted by Parliament under Entry 5, List III or Article 44 as a directive; no deadline.
Article 44 is in Part IV (DPSP), not Part III; it is not enforceable.
Uttarakhand was the first State to enact a UCC post-Independence; Goa’s code is a continuation of a pre-Independence Portuguese law.
The Law Commission (2018) said UCC was neither necessary nor desirable at this stage; the 22nd Commission started fresh consultation in 2023.
State UCCs exclude Scheduled Tribes.
Shah Bano, Sarla Mudgal, John Vallamattom each urged the government to enact a UCC; none ordered it.
★Analysis Angle: Uniform Civil Code (UCC)
Analyse / traps
Recent trend: Gujarat’s 2026 Act and assent, Uttarakhand’s 2025 implementation, rule-making and High Court challenges, and the Law Commission’s silence make this a highly probable MCQ area: ‘Which State first enacted a UCC after Independence?’ (Uttarakhand), ‘Which was the second?’ (Gujarat), ‘Which State has a Portuguese-origin code?’ (Goa), ‘Who chaired the committees?’ (Justice Ranjana Prakash Desai), ‘Which Article?’ (44).
Last updated: . Notes are a revision aid; check official UGC sources for any rule or scheme that changes over time. Spotted a mistake? Write to netlawverse@gmail.com.