TOPIC:- GHULAM KUBRA BIBI v.

MOHAMMAD SHAFI

OCTOBER 2017

CNLU, PATNA

NYAYA NAGAR, MITHAPUR, PATNA

SUBMITTED BY: SUBMITTED TO:

SANJEEV KUMAR Dr. SHAIWAL SIR

ROLL NO.- 1558 ‘FACULTY OF FAMILY LAW’

BA.LLB

3rd SEMESTER

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 DECLARATION PAGE
I here-by declared that project work reported in the BA.LLB(Hons.) entitled
“GHULAM KUBRA BIBI v. MOHAMMAD SHAFI ” submitted by me at
“CHANAKYA NATIONAL LAW UNIVERSITY” is an authentic record of my own
work, carried out under the supervision of “Dr. SHAIWAL SATYARTHI ” for the
partial fulfillment of the course “ FAMILY LAW-1”. This project work is not submitted
by me elsewhere for any other degree/diploma certificate in any institute or university.
I am fully responsible for the contents of my project report.
SANJEEV KUMAR

ROLL NO.-1558

BA.LLB

3rd SEMESTER

DATE- 12/10/17

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 ACKNOWLEDGE PAGE

I owe the present accomplishment. Any project completed or done in isolation is

unthinkable. This project, although prepared by me, is a culmination of efforts of a lots
of people.

Firstly, I would like to thank our teacher Dr. SHAIWAL SATYARTHI for his valuable
suggestions towards the making of this project.

Further to that, I would also like to express my gratitude towards my seniors who were
a lot of help for the completion of this project.

The contribution made by my classmates and friends are, definitely, worth mentioning.

I would like to express my gratitude towards my family members help also.

Last, but far from the least, I would express my gratitude towards the Almighty for
obvious reasons.

THANK YOU.

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 CONTENT PAGE

1. DECLARATION
2. ACKNOWLEDGE PAGE
3. OBJECTIVE AND SCOPE
4. RESEARCH METHODOLOGY
5. LIMITATION OF THE STUDY
6. TENTATIVE CHAPTERISTION
7. INTRODUCTION
8. GHULAM KUBRA BIBI v. MOHAMMAD SHAFI
9. JUDGEMENT
10.ESSENTIALS FOR THE VALIDITY OF MARRIAGE
11.CONCLUSION
12.BIBLIOGRAPHY

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OBJECTIVE AND SCOPE:
The fundamental objective of our research is to analyze the case Gulam Kubra Bibi vs.
Mohammad Shafi. The Researcher has analyzed the Hindu law provisions with respect to
above mentioned analysis.

RESEARCH METHODOLOGY:
For this project, we followed doctrinaire method which includes both descriptive method and
analytical method of writing throughout this project. We went through number of blogs,
editorials, articles and various websites on the internet.

LIMITATION OF THE STUDY:

• Lack of time
• Territorial limitation
• Finance

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 INTRODUCTION
The Arabic term ‘Nikah’ is used to describe marriage is transliterated into “the Union of Sexes”
and under this Arabic term, marriage became a civil contract in Muslim Law, as intended by
the Prophet Mohammed. It has since become one of the most sacrosanct social institutions
known to Man, while providing equal importance and according equal rights to both sexes.1

Chastity is forbidden and, in fact, looked down upon in Muslim communities. Marriage is a
contract for the purposes of the legislation of intercourse, procreation of children and the
regulation of social life in the interests of society by creating both rights and duties for the
parties partaking in this social contract and also between the parties and the children born out
of the aforesaid union. It can be entered into by parties who have reached puberty (majority for
the purposes of marriage) or by guardians of the persons concerned. Even lunatics can be
entered into marriage by their guardians.

Unlike civil contracts, however, a contract of nikah cannot be time-limited, not cancelled if
procreation is not possible (due to various reasons). It is, however, a very devotional act from
the perspective of the Muslim religion- an entwinement of two souls to achieve the spiritual
ends of continuing the line of the male.2
A marriage is valid (Sahih) if it is recognised by the courts as lawful. Following conditions
must be fulfilled in a valid Muslim marriage:
(1) The parties to the marriage i.e. husband and wife, must be competent.
(2) The consent of the parties, or of their guardians, must be a free consent.
(3) The required formalities are duly completed, and
(4) There must not be any prohibition or impediment in contracting the marriage.3
The case of Ghulam Kubra Bibi vs. Md. Shafi Mohammad Din, AIR 1940 Peshawar, 4
Mohammad Shafi sued Mt. Ghulam Kubra for restitution of conjugal rights. He also impleaded
her parents and asked that an injunction should be issued against them to restrain them from
interfering in his marital relations with his wife. The defence taken by Mt. Ghulam Kubra was
that she was never married to Mohammad Shafi. There was also a question whether the woman
was of age at the time when she was married. The validity of marriage was in question and it

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was also about restitution of conjugal rights in Muslim law. The issues which were raised in
this case were, Can a 'marriage' be upheld as valid on the vague statement of two persons that
they were witnesses to Nikah without any further details?5

GHULAM KUBRA BIBI v. MOHAMMAD SHAFI

Issues- Can a 'marriage' be upheld as valid on the vague statement of two persons that they
were witnesses to Nikah without any further details?
Facts - Mohammad Shafi sued Mt. Ghulam Kubra for restitution of conjugal rights. He also
impleaded her parents and asked that an injunction should be issued against them to restrain
them from interfering in his marital relations with his wife. The defence taken by Mt. Ghulam
Kubra was that she was never married to Mohammad Shafi. There was also a question whether
the woman was of age at the time when she was married. Evidence was led by either side. The
Mullah appeared and he said that he read the nikah at the instance of the grandfather of the girl.
He categorically denied that anyone was sent to the girl to enquire from her whether she agreed
to the marriage. One Mistri Abdul Karim, on the other hand, vaguely deposed that there were
two witnesses of the nikah. He did not give their names. Two witnesses, Mohammad Ramzan
and Mohammad Din were produced who alleged that they were the witnesses of the nikah.
They were again laconic, because they stopped at that, and did not give any detail as to what
was done by them. Mohammad Ramzan admitted that he was the neighbour of the plaintiff.
Mohammad Din did not deny that the plaintiff was working with him for the last 8 or 9 years.
The trial Judge held that the girl was of age when she was married. He was of the view that the
marriage had been proved. He, therefore, granted a decree as prayed for against all the
defendants. An appeal was preferred to the District Court. It was admitted by both the parties
before the learned Additional Judge that the girl was of age when the marriage was held. The
Judge maintained the decree for restitution of conjugal rights. But he did not think it necessary
to issue an injunction to the parents of the girl. He, therefore, accepted the appeal to this extent,
that he set aside the portion of the order relating to injunction. Mt. Ghulam Kubra has come
upon further appeal to this Court against the decree granting restitution of conjugal rights.
Mohammad Shafi has also come up on appeal with a request that the order issuing injunction
should be restored. This judgment will cover both the cases.6

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 According to Mahomedan law, it is absolutely necessary that the man or someone on his
behalf and the woman or someone on her behalf should agree to the marriage at one meeting,
and the agreement should be witnessed by two adult witnesses.7 As women are in pardah in
this part of the country it is customary to send a relation of the woman to her inside the house
accompanied by two witnesses.8 The relation asks the girl within the hearing of the witnesses
whether she authorizes him to agree to the marriage on her behalf for the dower money offered
by the husband. He explains to her the detail of the dower proposed. When the girl says “ yes”
or signifies her consent by some other method, the three persons come out. The future husband
and those three persons are then placed before the Mullah. The Mullah asks the boy whether
he offers to marry the girl on payment of the specified dower. He says “yes”. Then the relation,
who had gone inside, tells the Mullah that he is the agent of the girl. The Mullah asks him
whether he agrees to the marriage on payment of the specified dower. The relation says “yes”.
The witnesses are present there so that if the Mullah has any doubt he should question them as
to whether the relation is a duly authorized agent of the girl. Directly both sides have said “yes”
the Mullah reads the scriptures and the marriage is complete.9
JUDGEMENT
It was held that the first requirement of Muslim law is that both the bridegroom and bride
should give their consent for the marriage. This consent should be given in one meeting. There
should be two witnesses who should personally enquire from the girl as to whether she is
willing to marry or not. Qazi should explain marriage to the boy. The consent of the bridegroom
is also necessary. Both the parties should hear the words spoken by the other. There must be
no ambiguity.10
in this part of the case, a marriage is effected in order to show that the vague allegation that
there were two witnesses of the nikah has no value and that it should be proved that the whole
procedure has been gone through: in particular when the man who read the nikah is positive
that no one was sent to the girl to enquire from her whether she was a willing party. It is on the
record that the girl was 17 years of age when her marriage was solemnised. It appears that the
parties did not know then that according to Mahomedan law a girl becomes major for the
purposes of marriage when she reaches the age of puberty, which is presumed to be the age of
15 years. I think they were under the impression that she could not be major up to 18 years of

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age, as is the general law, and I guess that the girl was, therefore, given away by the grandfather
and not personally consulted. For when a girl is minor it is permissible in Mahomedan law that
her father or grandfather or other paternal relations should give her away. The marriage is valid
and is called a nikah all the same.11

It is interesting in this connection to point out that such nikah also requires two adult
witnesses. The witnesses produced in this case have only said that they were the witnesses of
the nikah. Who knows whether they were not the witnesses of the giving away of the girl by
the grandfather. For the reasons given above I hold that no valid marriage has taken place in
this case, and that the plaintiff has, therefore, no right to sue for restitution of conjugal rights.
The appeal of Mt. Ghulam Kubra is accepted and the suit of Mohammad Shafi is dismissed
with costs throughout. The appeal of Mohammad Shafi is dismissed.12
The Muslim marriage law requires that the witnesses must be sane, of full age and Muslims.
According to Hanfi marriage law they must include at least one male and two females so that
if the female witness forgets details of marriage the other female witness may remind her. They
inference to Quran:“O ye who believe! When ye deal with each other, in transactions involving
future obligations in a fixed period of time, reduce them to writing Let a scribe write down
faithfully as between the parties: let not the scribe refuse to write: as Allah Has taught him, so
let him write. Let him who incurs the liability dictate, but let him fear His Lord Allah, and not
diminish aught of what he owes. If the party liable is mentally deficient, or weak, or unable
Himself to dictate, Let his guardian dictate faithfully, and get two witnesses, out of your own
men, and if there are not two men, then a man and two women, such as ye choose, for witnesses,
so that if one of them errs, the other can remind her. The witnesses should not refuse when they
are called on (For evidence).” 13 However, the verse is not applicable on marriage for two
grounds. First, it is for financial transactions and second the transaction is to be for a fixed
period of time. While marriage conducted for a fixed period of time is considered void by most
of the Hanfi jurists.14
The Muslim marriage law in Pakistan does not specify any number and qualification of
witnesses. Generally, the witnesses should be Muslims. However, when bride is non-Muslim,
the condition of religion is not upheld.

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The Muslim marriage law in Fiji declares two women as valid witnesses to a Muslim marriage.
Tunician Muslim marriage law requires that the witnesses may be either male or female. In
Sudan and Yemen Two men or one man and two women are required to testify a Muslim
marriage. In Sudan, the law requires that the witnesses should be of ‘good reputation and
trustworthy’.15
ESSENTIALS FOR THE VALIDITY OF MARAIGE-

For a valid Islamic marriage, the following conditions must be satisfied:

1. The parties must have the capacity to marry
2. There must be a clear proposal and acceptance.
3. Free consent
4. No Legal disability
1. Capacity to marry
Every Muslim of sound mind who has attained puberty, may enter into a contract of marriage.
Puberty means the age at which a person becomes adult (capable of performing sexual
intercourse and procreation of children). A person is presumed to have attained the age of
puberty on the completion of 15 years. So the boy and girl who has attained puberty can validly
contract a marriage .A marriage under Muslim law is perfectly valid if the parties have attained
puberty and satisfied all other conditions specified by the law.
According to the child marriage restraint act 1929, a marriage of male below 21years of age
and female below 18 years of age is child marriage. The act prohibits such marriage. The Act
prescribes that for a valid marriage the minimum age for male is 21 and female is 18. The
parties who are violating the provisions of Child Marriage Restraint Act are liable to be
punished. Thus if two Muslims marry before attaining the age prescribed under the child
marriage restraint Act they are liable to be punished. However the marriage between two
Muslims who have attained puberty is valid though they have violated the provisions of Child
Marriage Restraint Act.
2. Proposal and Acceptance
Under the Muslim law for the validity of a marriage there must be a proposal and acceptance
at the same meeting. The proposal and acceptance must both be expressed at one meeting; a

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proposal made at one meeting and acceptance made at another meeting does not make a valid
Muslim marriage. Neither writing nor any religious ceremony is essential.
Under the Sunni law, the proposal and acceptance must be made in the presence of two male
Muslims who are of sound mind and have attained puberty or one male and two female
witnesses who are sane, adult and Muslim. Absence of witnesses does not render marriage void
but make it void able.
Under the Shia law witnesses are not necessary at the time of marriage.
The proposal and acceptance need not be made in writing. Where the offer and acceptance are
reduced into writing,the document is called ‘Nikah nama or Kabin-nama.
The proposal made by or on behalf of one of the parties to the marriage, and an acceptance of
the proposal by or on behalf of female witnesses, who must be sane and adult Muslim.
3. Free consent
Free consent of the parties is absolutely necessary for a valid marriage .If there is no free
consent a Muslim marriage is void. Under the Muslim Law, a marriage of a Mohammedan who
is of sound mind and has attained puberty is void; if it is brought about without his consent The
marriage of a girl who has attained puberty and is of sound mind would be void if her consent
is not obtained. When the consent to the marriage has been obtained by force or fraud, the
marriage will be invalid, unless it is ratified. When a marriage was consummated against the
will of the women, the marriage is void. The person who has been defrauded can repudiate the
marriage.
Lunatics and minors who has not attained puberty may be validly contracted by their respective
guardians. A minor is incompetent to give valid consent. The right to contract a minor in
marriage belongs successively to the following persons:
i) Father
ii) Paternal Grand Father (h.h.s-How high soever)
iii) Brother and other male relations on the fathers side
iv) Mother
v) The maternal uncle or aunt and other maternal relations.
Under the Shia law only the father and the paternal grandfather are recognized as guardian for
contracting marriage of a minor.
If a minor, whether male or female, be contracted in marriage by a remoter guardian, while a
nearer guardian is present and available and such nearer guardian does not give consent to the
marriage, the marriage is void. But if the parties ratify it after attaining puberty, it will be valid.

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However if the nearer guardian be absent at such a distance as precludes him from acting, the
marriage contracted by the remoter is also lawful.
Khair-ul-Balgh (Option of Puberty)
When a minor has been contracted in marriage by the father or father’s father, the contract of
marriage is valid and binding and it cannot be annulled by the minor on attaining puberty. But
if a marriage is contracted for a minor by any guardian other than the father or father’s father,
the minor has the right to repudiate such marriage on majority. This right is called Khair-ul-
Balgh which means Option of Puberty.
When a minor wife’s right of repudiation should be exercised within a reasonable time after
attaining puberty and failing which would result in the loss of such right. The right is lost if she
after having attained puberty permits the marriage to be consummated .If the consummation
was without her consent the right of repudiation will not be lost.
The dissolution of Muslim marriage act 1939 has considerably modified the law of option of
puberty. Prior to the Act the marriage is contracted for a minor girl by the father or grandfather,
the minor has no right to repudiate such marriage on majority. But according to sec 2(7) of the
act if the marriage is contracted for a minor girl by the father or grandfather can also obtain a
decree for divorce from the court if the following conditions are satisfied.
The marriage took place before the age of fifteen years
She repudiated the marriage before attaining the age of eighteen years:
The marriage has not been consummated
4. No Legal disability
Under Muslim Law, marriage under certain circumstances is prohibited or not permitted. The
prohibitions can be classified into two classes:
Absolute Prohibition
Relative prohibition
A) Absolute Prohibition
1) Prohibited degrees of relationship
Under the Muslim law marriage between persons who come within the blood relationship, or
certain other relationship is prohibited. The prohibited relationships are the following:
(a) Consanguinity: Consanguinity means blood relationship and a prohibits a man from
marrying the following females
1. His mother or grandmother (however high so ever)
2. His daughter or granddaughter (how low so ever)

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3. His sister whether full blood half blood or uterine blood
4. His niece or great niece (how low so ever)
5. His aunt (father’s sister or mother’s sister) or great aunt (how high so ever)
A marriage with a woman who comes within the relationship of consanguity is absolutely void.
Children born out of that wed-lock are illegitimate.
(b) Affinity : A man is prohibited from marrying certain female relatives due to nearness of
relationship. A man is prohibited from marrying
1. His wife's mother grandmother (however high so ever)
2. His wife's daughter or granddaughter (how low so ever)
3. His father's wife or paternal grandfather's wife (how high so ever)
4. Wife of one's own son or son's son or daughter's son (how low so ever)
A marriage with a woman comes within the relationship by affinity is void.

(c) Fosterage: It means the milk relationship. When a child is breast-fed/suckled by a woman
other than its own mother, she becomes the foster mother of the child. A man is prohibited
from marrying certain persons having foster relationship. According to Shia jurists fosterage
includes the same limits of relationship prohibitive to marriage as consanguinity. A man may
not marry the following females:
1. His foster-mother or grandmother (however high so ever)
2. His foster-sister (daughter of foster mother)
However Sunnis do not follow the same. Under the Sunni law, there are certain exceptions to
the general rule of prohibition on the ground of fosterage and a valid marriage may be
contracted with:
1. Sister's foster mother, or
2. Foster'-sister’s mother, or
3. Foster-son’s sister, or
The Shia jurists refuse to recognize the exception permitted by the Sunnis. The above
mentioned prohibitions on account of 'consanguinity', 'affinity' or 'Fosterage' are absolute and
the marriages contracted in contravention of these rules are void.
2) Polyandry
Polyandry means marrying more than one husband. Polyandry is a form of polygamy in which
a woman is having more than one husband at the same time. Under Muslim law Polyandry is
prohibited and a married woman cannot marry second time so long as the first marriage subsists

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and the husband is alive.If a woman violated this prohibition and contracted a second marriage
,the marriage is void and the woman is liable to be punished for bigamy under section 494 of
the Indian Penal Code.
B) Relative prohibition
Under Muslim Law, there are certain prohibitions, which are not absolute but only relative, and
marriage in violation of such relative prohibitions will only be irregular and not void and at the
moment when the irregularity is removed the prohibition ends and the marriage becomes valid.
The following are the relative prohibitions.
1) Unlawful conjunction
A man is prohibited from marrying two wives at the same time if they are related to each other
by consanguinity, affinity or fosterage, which they could not have lawfully intermarried with
each other if they had been of different sexes. Thus a Muslim cannot marry his wife’s sister
while the wife is alive. But he can make the marriage valid by marrying his wife’s sister after
the death or divorce of his first wife. Marriage with two such wives is an Unlawful conjunction.
Under sunni law a marriage in violation of the rule of unlawful conjunction is not void but only
irregular. However under Shia law, a marriage in violation of the rule of unlawful conjunction
is void. Under the Shia Law, a Muslim may marry his wife's aunt, but he cannot marry his
wife's niece without her permission
2) Marrying a fifth wife (Polygamy)
Muslim law permits polygamy (Marrying more than one wife ) with a restriction of maximum
four wives. So a Musalman can have four wives at the same time. If he marries a fifth wife
when he has already four, the marriage is not void, but merely irregular. But the fifth marriage
can be made valid after the death or divorce of any one of the four wives of his earlier
marriages. Under the shia law marriage with the fifth wife is void.
In India no Muslim marrying under or getting his marriage registered under The Special
Marriage Act, 1954,can marry a second wife during the lifetime of his spouse.
3) Absence of proper witnesses
A marriage must be contracted within the presence of proper and competent witnesses. Under
the Sunni law at least two male or one male and two female witnesses must be present to testify
that the contract was properly entered into between the parties. The witnesses must be of sound
mind, adult and Muslim. A marriage without witnesses is irregular.

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Under the Shia law the presence of witnesses is not necessary. The marriage is contracted by
the spouses themselves or their guardians in private are held valid. The absence of witnesses
does not render the marriage void but only invalid.
4) Differences of religion (Marriage with non-muslim)
The law with regard to marriage with a non-Muslim is different under Sunni law and Shia law.
Under Sunni law a male can marry a Muslim female or a Kitabia (a person who believes in a
revealed religion possessing a Divine Book viz Christianity and Judaism). A Sunni muslim
male can validly marry a jews or christian female. But he cannot marry an idolatress or a fire-
worshiper. A marriage, with an idolatress or a fire worshiper is merely irregular and not void.
A Muslim woman cannot marry a Kitabia /non-Muslim man. A marriage of a Muslim female
with a non-Muslim male, whether he is a Christian, or a Jew or an idolator or a Fire-Worshiper
is not void but irregular. According to Mulla, a marriage between a Muslim woman and Non-
Muslim male is irregular. But according to Fyzee, such a marriage is totally void.
Under Shia Law a marriage with a non-muslim is void. Both the spouses are required to be
Muslims. The marriage of Sunni male with a Shia female is void. A marriage of a Muslim
female with a non-Muslim male, whether he be a Christian, or a Jew or an idolator or a Fire-
Worshiper is void under Shia Law.
In India a marriage between a Muslim and a non-Muslim can only take place under The Special
Marriage Act, 1954.If a muslim male marries and registers under the Special Marriage Act,
1954, he cannot marry a second wife during the subsistence of the first marriage.
A marriage of a Muslim female with a non-Muslim male, whether he be a Christian, or a Jew
or an idolator or a Fire-Worshiper is void under Shia Law.
5) Marriage during IDDAT
Under Muslim law, a woman who is undergoing iddat is prohibited from marrying during that
period. Iddat is the period during which it is incumbent upon a woman, whose marriage has
been dissolved by divorce or death of her husband to remain in seculasion, and to abstain from
marrying another husband. The purpose behind that is to ascertain whether she is pregnant by
earlier husband , so as to avoid confusion of the parentage of the child.
The period of Iddat is prescribed as under:
1) In case termination marriage by divorce- three lunar months or three menstrual courses
2) In case of widow- 4 months and 10 days
3) In case the woman is pregnant - till the delivery

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Under Sunni Law a marriage with a woman undergoing Iddat is irregular and not void. Under
Shia law a marriage with a woman who is undergoing Iddat is void.

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 CONCLUSION
On the basis of Juristic opinion we can easily conclude, that marriage is simply a civil contract
under Muslim Law. It fulfills all the conditions of a contract-proposal and acceptance, free
consent and consideration.
But from the religious angle, Muslim marriage is a devotional act. Marriage is not devoid of
all religious and spiritual values. Along with its secular aspect it also partakes the elements of
a sacred union of two souls means for spiritual ends.
In Quran and Hadith spouses are strictly enjoined to love and honour each other. Enjoyment
and showering love and affection by each one has been called a noble act. Marriage under Islam
is sacrament keeping the view of Quranic injunction and traditions.
In the ultimate analysis it can be said that the marriage in Islam is neither purely a civil contract
nor a sacrament. It is devoid of none but the blending of the two.
An Islamic marriage contract is an Islamic prenuptial agreement. It is a formal, binding contract
considered an integral part of an Islamic marriage, and outlines the rights and responsibilities
of the groom and bride or other parties involved in marriage proceedings. In Sunni Islam, a
marriage contract must have two male witnesses, or, in the Hanafi school of jurisprudence, one
man and two women, if a second male is unavailable.[citation needed] Proper witnessing is
critical to the validation of the marriage, also acting as a protection against suspicions of
adulterous relationships. The importance of this is demonstrated in a narration in which a case
was brought before the second caliph Umar concerning a marriage which had been witnessed
by only one man and one woman (i.e. the participants); he responded: "This is a secret marriage
and I do not permit it. Had I been the first to come upon it, I would have ordered them to be
stoned."
In Shia Islam, witnesses to a marriage are deemed necessary, but in case are not available then
the two parties may conduct the nikah between themselves. It is also believed that temporary
marriage, or Nikah Mut'ah (a type of contract which had more relaxed requirements) was
prohibited in Sunni Islam, the necessity of witnessing was introduced by Sunni caliphs,
specifically Umar, to ensure that no couples engaged in secret union.

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BIBLIOGRAPHY
1) Aqil Ahmad- “Mohammedan Law”, 21st edn. 2004, Central Law Agency, Allahabad.
2) Dr. Mohammad Nazmi- “Mohammadan Law”, 2nd edn. 2008, Central Law
Publications, Allahabad.
3) Dr. Paras Diwan- “Muslim Law in Modern India”, 9th edn. 2005, Allahabad Law
Agency, Faridabad (Haryana).
4) DR. Tahir Mahmood- Hindu law, 2nd edn. 1986, The Law Book Company (p)
Ltd. Allahabad.
5) Kusum- “Family Law Lectures”, 2003, Lexis Nexis, New Delhi.

6) Noshirvan H. Jhabvala- “Principles of Muhammadan Law”, 25th edn. 2009, C.

Jamnadas & Co. Mumbai.
7) 19. Prof. R.K. Sinha- “The Muslim Law”, 5th edn. 2003, Central Law Agency,
Allahabad.
8) 20. Quran, The Holy Quran, translated by Abdullah Yusuf Ali, edn. 2004, Ayman
Publications, New Delhi

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