Uncle-In-Law Cannot Adopt Niece's Husband as 'Ghar Damad'

Uncle-In-Law Cannot Adopt Niece's Husband as 'Ghar Damad' — Supreme Court July 2026 Landmark Judgment Explained

Uncle-In-Law Cannot Adopt Niece's Husband as 'Ghar Damad' — Supreme Court July 2026 Landmark Judgment Explained

Supreme Court of India delivers landmark judgment on Ghar Damad custom under Oraon tribal law — July 2026

Case Title

Bejla Oraon v. Kali Das Oraon & Ors.

Neutral Citation: 2026 INSC 672 | Bench: Justice Sanjay Karol & Justice Nongmeikapam Kotiswar Singh | Decided: July 2026

Have you ever heard of the term "Ghar Damad"? It is a fascinating tribal custom practiced among the Oraon community in Jharkhand, where a son-in-law is adopted into the family to continue the family line when there are no male heirs. But here is the twist — what happens when the person doing the adoption is not the father-in-law, but the uncle-in-law? Can an uncle adopt his niece's husband as a Ghar Damad? This very question reached the Supreme Court of India in July 2026, and the answer has sent ripples through the legal community.

In a landmark judgment delivered by a bench of Justice Sanjay Karol and Justice Nongmeikapam Kotiswar Singh, the Supreme Court held that an uncle-in-law cannot validly adopt his niece's husband as a Ghar Damad under the prevalent customary law of the Oraon tribe. This case — Bejla Oraon v. Kali Das Oraon & Ors. — is not just about one family dispute. It is about understanding the boundaries of tribal customary law, the burden of proof in custom-based claims, and the delicate balance between tradition and legal certainty.

If you are a law student, legal professional, or simply someone interested in how Indian courts handle tribal customs, this article is for you. We will break down the entire case — from the family tree to the final Supreme Court order — in simple, human language. No heavy legal jargon. Just clear explanations of what happened, why the court decided what it did, and what it means for the future of customary law in India.

What Was the Dispute About? Understanding the Family Background

Before we dive into the legal arguments, let us understand the people involved. This dispute revolves around a piece of ancestral land that has been fought over for decades. The story begins with a man named Sukhu Oraon, who had three sons: Dhungru, Ledura, and Bhoula. These three brothers were the original owners of the family property, and their descendants have been battling in court for years over who gets what.

Here is where it gets complicated. Ledura, the second son, had no children of his own. Bhoula, the third son, had a daughter named Budhain but no sons. Under the Oraon customary law, daughters do not have independent inheritance rights — a fact that both sides agreed upon. So when Bhoula died, his property could not go to Budhain directly.

The plaintiff in this case — Bejla Oraon — was the grandson of Dhungru (the eldest son). He claimed that since there were no valid male heirs left in Ledura and Bhoula's branches, he, as the nearest male agnate, was entitled to inherit the entire ancestral property. This is a straightforward claim under traditional inheritance principles.

But the defendants — Budhain and her husband Punai — had a different story. They claimed that Ledura had adopted Punai as his Ghar Damad (adopted son-in-law). According to this claim, Punai was taken into the family to continue the line, and therefore he had the right to inherit Ledura's share of the property. To support this, they produced a partition deed dated February 27, 1975, which supposedly divided the property between Budhain and Ledura.

The plaintiff, however, argued that this partition deed was invalid because Ledura had no authority to adopt Punai as a Ghar Damad. Why? Because Ledura was not Punai's father-in-law — he was Punai's uncle-in-law. And that, my friends, is the crux of this entire case.

Key Question Before the Supreme Court: Can an uncle-in-law (Ledura) adopt his niece's husband (Punai) as a Ghar Damad under Oraon customary law, thereby giving Punai inheritance rights in the family property?

The Journey Through Three Levels of Courts

This case did not reach the Supreme Court overnight. It traveled through three levels of courts over several decades, with each court giving a different verdict. Understanding this journey is crucial because the Supreme Court specifically criticized how the lower courts handled the case.

Stage 1: The Trial Court (Munsif, Gumla)

The case first went to the Munsif Court in Gumla, Jharkhand. The trial court framed the central issue: whether Punai was indeed Ledura's Ghar Damad. After examining the evidence, the trial court dismissed the plaintiff's suit and held that Punai's status as Ledura's Ghar Damad had been established. The court accepted the defendants' version and ruled against Bejla Oraon.

Stage 2: The First Appellate Court (1st Additional District Judge, Gumla)

Bejla Oraon was not satisfied and filed an appeal. The First Additional District Judge, Gumla, heard the appeal and affirmed the trial court's decision. The appellate court agreed that Punai was a valid Ghar Damad and that the partition deed was genuine. So now, two courts had ruled against the plaintiff.

Stage 3: The High Court (Jharkhand High Court at Ranchi)

The plaintiff then approached the Jharkhand High Court in a Second Appeal. This is where things get interesting. The High Court actually framed a specific substantial question of law: whether an uncle (Ledura) could adopt a Ghar Damad on behalf of his niece's husband (Punai). This was the exact legal question that needed answering.

However, instead of answering this question on its merits, the High Court simply upheld the concurrent findings of the two lower courts. In other words, the High Court said, "Since both lower courts agree, we will not interfere." The judgment was passed on June 10, 2024. The plaintiff, now represented by his legal heirs, finally approached the Supreme Court.

Supreme Court's Criticism of the High Court: The Supreme Court strongly criticized the High Court for framing a substantial question of law and then refusing to answer it. The bench observed: "If it was only the concurrent nature of findings that weighed with the High Court and nothing further, then there was no reason to formulate that question."

What is Ghar Damad? Understanding the Oraon Tribal Custom

Before we understand the Supreme Court's reasoning, we need to know what Ghar Damad actually means. This is not a concept found in mainstream Hindu law or the Indian Penal Code. It is a customary practice specific to the Oraon tribe of Chotanagpur region in Jharkhand.

The term "Ghar Damad" literally translates to "house son-in-law" or "resident son-in-law." It refers to a practice where a son-in-law is formally adopted into his wife's family, typically when the family has no male heirs. The purpose is to ensure that the family line continues, the ancestral property remains within the family, and there is someone to perform the religious and social duties that traditionally fall upon sons.

This custom is not unique to the Oraons. Similar practices exist in various tribal communities across India, where the concept of "bride price" or "matrilineal inheritance" takes different forms. However, what makes the Oraon custom specific is the strict requirement of who can induct a Ghar Damad.

Key Features of Ghar Damad Under Oraon Customary Law

• Purpose: To continue the family line when there are no male heirs (sons or grandsons)
• Who Can Induct: Only the last male owner of the property or, in his absence, his widow has the authority to adopt a Ghar Damad
• Relationship: The Ghar Damad must be the husband of the daughter of the last male owner
• Effect: Once validly inducted, the Ghar Damad acquires rights of succession to the family property, similar to a son
• Limitation: Daughters themselves do not have independent inheritance rights under this custom

The Supreme Court relied heavily on the authoritative work of S.C. Roy, a renowned scholar who wrote "The Oraons of Chotanagpur." This book has been cited by courts for decades as a reliable source of Oraon customary law. According to Roy's work, the Ghar Damad institution is carefully regulated and cannot be created by just any relative.

Supreme Court's Detailed Analysis and Reasoning

The Supreme Court bench of Justice Sanjay Karol and Justice Nongmeikapam Kotiswar Singh delivered a comprehensive judgment that addressed multiple legal issues. Let us break down their reasoning step by step.

1. The Burden of Proof in Custom-Based Claims

The Supreme Court started with a fundamental legal principle: "He who alleges a custom must prove it." This is not a new principle. It has been established in numerous precedents, including Gokal Chand v. Parvin Kumari (1952) and Aliyathammuda Beethathebiyyappura Pookoya v. Pattakal Cheriyakoya (2019). The Court emphasized that the burden of proving a custom lies squarely on the person who claims its existence.

In this case, the defendants (Budhain and Punai) were claiming that Ledura had the customary right to adopt Punai as a Ghar Damad. Therefore, it was their burden to prove that such a custom existed — not the plaintiff's burden to disprove it. The High Court had erred by shifting this burden. The High Court observed that "since it is not established that there is a bar against adoption by uncle-in-law, no adverse inference can be drawn." The Supreme Court rejected this approach completely.

The bench held: "Merely observing that the opposite to what has been alleged is not clearly stated, cannot be stated to be sufficient. To say the least, that is not the appropriate answer to a substantial question of law within the meaning of Section 100 CPC."

2. The Specific Requirement: Who Can Adopt a Ghar Damad?

This is the heart of the judgment. The Supreme Court carefully examined S.C. Roy's work and other authoritative sources on Oraon customary law. The conclusion was clear and unambiguous:

Supreme Court's Finding: "It is nowhere established that an uncle-in-law can adopt his niece's husband as his ghardamad within the prevalent customary law." A Ghar Damad can only be adopted by the last male owner or, in his absence, his widow. Ledura, being merely the uncle of Budhain (not her father), had no authority under customary law to adopt Punai as a Ghar Damad.

The Court quoted directly from S.C. Roy's book: "If there be no male issue or adopted son, but only a ghar damad duly adopted into the house as a prospective son-in-law by the last male owner or even by his widow, a son married to a daughter of a deceased and living in the house, the Rajhas lands left by the deceased male owner shall on the death of the widow go to such ghar damad, and bhuinhari land shall go to the nearest male agnate or agnates."

This passage makes it crystal clear that the authority to adopt a Ghar Damad is limited to two people: the last male owner or his widow. Ledura was neither. He was the uncle of the daughter (Budhain), not her father. Therefore, his alleged adoption of Punai was invalid ab initio (from the very beginning).

3. The Invalidity of the Partition Deed

Since Ledura had no authority to adopt Punai as a Ghar Damad, the entire foundation of the defendants' claim collapsed. The partition deed dated February 27, 1975, which purported to divide property between Budhain and Ledura, was based on the false premise that Punai had valid succession rights. The Supreme Court held that this partition deed was non est (it did not exist in the eyes of law) because the parties to it had no valid title to the property they were partitioning.

4. The Proper Rule of Succession

Having set aside the Ghar Damad claim, the Supreme Court had to determine who was actually entitled to the property. The answer was straightforward under Oraon customary law:

• There was no valid Ghar Damad (since the adoption was invalid)
• There were no other male heirs directly related to the original landowners
• Therefore, the property would devolve upon the nearest male agnate
• The plaintiff, Bejla Oraon, being the grandson of Dhungru (the eldest son), was the nearest male agnate

The Court concluded: "In the absence of a ghar damad or any other male heir directly related to the land owner, the nearest male agnate will have the right in the property."

5. The High Court's Failure to Answer the Framed Question

The Supreme Court also used this case to send a strong message to High Courts about their duty under Section 100 of the Civil Procedure Code (CPC). When a substantial question of law is framed in a second appeal, the High Court must answer it on merits. Simply saying "the lower courts agree, so we will not interfere" is not enough.

The bench observed: "Ordinarily, once a substantial question is framed, the parties have to be heard and issue decided accordingly. Framing a question and then declining to decide it defeats the very purpose of formulating it."

Complete Case Timeline: From Trial Court to Supreme Court

Stage	Court	Case Number	Decision	Key Finding
Trial Court	Munsif, Gumla	TS No. 22 of 1975	Dismissed Plaintiff's Suit	Held Punai was valid Ghar Damad of Ledura
First Appeal	1st Additional District Judge, Gumla	TA No. 42 of 1990	Affirmed Trial Court	Confirmed Ghar Damad status and partition deed validity
Second Appeal	Jharkhand High Court, Ranchi	Second Appeal No. 35 of 1995	Dismissed Appeal	Framed question but upheld concurrent findings without answering
Supreme Court	Supreme Court of India	2026 INSC 672	Allowed Appeal, Set Aside All Lower Courts	Uncle-in-law cannot adopt Ghar Damad; plaintiff decreed as nearest male agnate

Family Tree: Understanding the Relationships

Generation	Name	Relationship	Status in Case
First	Sukhu Oraon	Original Landowner (Grandfather)	Had 3 sons: Dhungru, Ledura, Bhoula
Second	Dhungru	Eldest Son of Sukhu	Father of plaintiff's father; had male descendants
Second	Ledura	Second Son of Sukhu	Childless; allegedly adopted Punai as Ghar Damad (held invalid)
Second	Bhoula	Third Son of Sukhu	Had daughter Budhain but no sons
Third	Bejla Oraon (Plaintiff)	Grandson of Dhungru	Claimed as nearest male agnate; suit decreed by SC
Third	Budhain (Defendant 1)	Daughter of Bhoula	Claimed property through husband Punai as Ghar Damad
Third	Punai (Defendant 2)	Husband of Budhain; Niece's Husband of Ledura	Claimed as Ghar Damad of Ledura; claim rejected by SC

Plaintiff vs Defendants: Claims and Counter-Claims

Aspect	Plaintiff (Bejla Oraon)	Defendants (Budhain & Punai)
Claim	Entitled to entire ancestral property as nearest male agnate	Punai is valid Ghar Damad of Ledura; entitled to Ledura's share
Basis of Claim	No valid male heirs in Ledura/Bhoula branches; nearest male agnate rule applies	Partition deed of 1975; Ledura adopted Punai as Ghar Damad
Key Evidence	S.C. Roy's book on Oraon customs; family genealogical records	Partition deed dated 27.02.1975; witness testimonies
Supreme Court Finding	Claim ALLOWED — decreed as rightful owner	Claim REJECTED — Ghar Damad adoption invalid; partition deed non est

Key Legal Principles Established by This Judgment

This case is not just about one property dispute. It establishes several important legal principles that will guide future cases involving tribal customary law. Here are the key takeaways:

Principle 1: Burden of Proof in Custom-Based Claims

The Supreme Court reaffirmed that in any case where a party relies on a custom, the burden of proving that custom lies entirely on the party asserting it. Mere absence of evidence disproving the custom is not enough. The party must affirmatively establish both the existence of the custom and that the parties are governed by it. This is a critical principle because customs are often unwritten and based on oral traditions.

Principle 2: Strict Interpretation of Customary Requirements

The Court demonstrated that customary law must be interpreted strictly according to its established sources. In this case, the requirement that only the last male owner or his widow can adopt a Ghar Damad was not a minor technicality — it was the core requirement of the custom. Allowing collateral relatives like uncles to adopt Ghar Damads would dilute the custom beyond recognition.

Principle 3: High Court's Duty Under Section 100 CPC

The judgment serves as a reminder to High Courts that when they frame a substantial question of law in a second appeal, they cannot simply defer to the lower courts' concurrent findings. They must independently analyze and answer the question. This ensures that important legal questions are settled at the High Court level, reducing the burden on the Supreme Court.

Principle 4: Hierarchy of Evidence in Customary Law

The Court showed a clear hierarchy of evidence when dealing with customary law:

• Primary Source: Authoritative scholarly works (like S.C. Roy's book)
• Secondary Source: Judicial precedents interpreting the custom
• Tertiary Source: Witness testimonies (which may be inconsistent or self-serving)

In this case, the defendants' witness testimonies were found to be internally inconsistent, while the plaintiff's witnesses were more reliable. The Court gave greater weight to the scholarly source.

Principle 5: Daughters' Rights Under Oraon Custom

The Court noted that under the applicable Oraon custom, daughters have no independent right of inheritance. This is a feature of the specific tribal custom, not a general rule of Indian law. However, the Court also noted that in the absence of a valid Ghar Damad, the property does not simply go to the daughter — it goes to the nearest male agnate. This shows how customary law creates its own unique succession rules.

How Does This Compare with Hindu Adoption Law?

Many readers might wonder: how is this tribal custom different from adoption under the Hindu Adoptions and Maintenance Act, 1956 (HAMA)? The differences are significant and highlight why customary law requires special treatment.

Aspect	Oraon Ghar Damad Custom	Hindu Adoption under HAMA, 1956
Governing Law	Unwritten tribal customary law	Statutory law (HAMA, 1956)
Who Can Adopt	Only last male owner or his widow	Any Hindu male/female of sound mind and major status
Who Can Be Adopted	Daughter's husband (son-in-law)	Any Hindu child below 15 years (unless custom permits otherwise)
Purpose	Continue family line and retain property	Provide care and family to childless parents
Legal Effect	Acquires succession rights like a son	Child becomes natural-born child with full inheritance rights
Registration	No formal registration required; proved by evidence	Can be registered under Section 16 for evidence
Revocability	Customary rules apply	Valid adoption cannot be cancelled (Section 15)

As you can see, the Ghar Damad custom is fundamentally different from statutory adoption. It is not about giving a child to childless parents — it is about bringing a son-in-law into the family to continue the male line. This is why the strict requirements about who can perform the adoption are so important. If anyone could adopt a Ghar Damad, the custom would lose its meaning and become a tool for property grabbing.

Why This Case Matters for Law Students and Legal Professionals

If you are preparing for judicial services, law school exams, or simply want to understand how Indian courts handle tribal customs, this case is a goldmine of learning. Here is why:

1. Understanding Customary Law in Modern India

India is a diverse country with hundreds of tribal communities, each having their own customs. The Constitution recognizes the validity of customary law under Article 13(3)(a), which defines "law" to include "customs or usages." However, customary law must pass certain tests: it must be ancient, certain, continuous, and not opposed to public policy. This case shows how courts apply these tests in practice.

2. The Art of Proving Custom

This case is a masterclass in how to prove (or disprove) a custom. The defendants failed because they could not produce:

• Any authoritative text supporting uncle-in-law adoption of Ghar Damad
• Consistent witness testimonies (defence witnesses contradicted each other)
• Any precedent where an uncle-in-law's Ghar Damad adoption was upheld

The plaintiff, on the other hand, produced S.C. Roy's authoritative book and consistent witness accounts. This shows the importance of reliable evidence in custom-based litigation.

3. Section 100 CPC and Second Appeals

The Supreme Court's criticism of the High Court is a crucial lesson for appellate practice. When you file a second appeal, you must frame substantial questions of law. But more importantly, the High Court must answer them. If you are a lawyer handling second appeals, this case gives you strong precedent to demand that the High Court engage with the legal issues rather than taking shortcuts.

4. Tribal Rights and Property Law

Tribal land rights are a sensitive issue in India. The Scheduled Tribes and Other Traditional Forest Dwellers (Recognition of Forest Rights) Act, 2006 and various state laws protect tribal land from alienation. This case shows how customary succession rules play a vital role in determining who gets tribal property. Any lawyer handling tribal land disputes must understand the specific customs of the community involved.

5. The Role of Scholarly Works in Legal Reasoning

The Supreme Court's heavy reliance on S.C. Roy's book shows that academic scholarship matters in court. For law students, this is encouraging — your research and writing can have real-world impact. For lawyers, it shows the value of citing authoritative texts when arguing cases involving specialized areas like tribal customs.

Related Legal Resources on Barristery.in

At Barristery.in, we cover a wide range of legal topics to help students, professionals, and citizens understand Indian law better. If you found this case analysis helpful, you will definitely benefit from these related articles on our website:

• Hindu Law Notes — Detailed Explanation of Marriage, Divorce, Succession & Adoption — A comprehensive guide covering all major Hindu law statutes including the Hindu Marriage Act, Hindu Succession Act, and Hindu Adoptions and Maintenance Act. Perfect for law students preparing for exams.
• Hindu Adoption and Maintenance Act, 1956 — Complete Section-wise Guide — This detailed article explains every section of HAMA 1956 with practical examples. Learn who can adopt, who can be adopted, effects of adoption, and maintenance rights under one roof.
• Biswanath Singh Institute of Legal Studies, Munger — Law College Guide — Looking for a good law college in Bihar? This guide covers admission process, fees, faculty, and career prospects at one of the emerging legal institutions in the region.
• Legal Careers Portal — LL.B Jobs, Internships & Moot Court Competitions — Your daily source for legal job alerts, internship opportunities, moot court competitions, essay competitions, and call for blogs from top law firms and organizations across India.

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Practical Implications of This Judgment

What does this case mean for people living in tribal areas? How will it affect future disputes? Let us look at the practical implications:

For Tribal Communities

• Clarity on Ghar Damad Rules: Tribal communities now have clear judicial guidance that only the last male owner or his widow can adopt a Ghar Damad. Uncles, brothers, and other collateral relatives cannot do so.
• Protection Against Property Grabbing: This judgment prevents unscrupulous relatives from creating fake Ghar Damad arrangements to grab property. The strict proof requirements will deter false claims.
• Need for Documentation: Tribal families should consider documenting Ghar Damad adoptions properly, with community witnesses and written records, to avoid future disputes.

For Lawyers and Judges

• Standard of Proof: Lawyers must now advise clients that mere oral claims of custom are insufficient. Authoritative texts, consistent witness accounts, and long-standing practice must be demonstrated.
• High Court Accountability: Judges in High Courts must take this judgment as a reminder to answer framed questions of law rather than taking the easy route of upholding concurrent findings.
• Expert Evidence: In tribal custom cases, lawyers should consider bringing in anthropologists or tribal experts as witnesses to establish or challenge custom claims.

For Law Students

• Case Study Material: This case is an excellent addition to your notes on customary law, evidence law, and civil procedure. It touches on multiple subjects simultaneously.
• Moot Court Potential: The legal issues in this case — burden of proof, custom interpretation, Section 100 CPC — make it ideal for moot court competitions.
• Research Topic: If you are looking for a dissertation or project topic, the conflict between statutory law and tribal customary law in inheritance matters is a rich area of study.

Frequently Asked Questions About Ghar Damad and This Case

Q1: What exactly is a Ghar Damad?

A Ghar Damad is a son-in-law who is formally adopted into his wife's family under Oraon tribal custom, typically when the family has no male heirs. He acquires succession rights similar to a son. However, this adoption can only be done by the last male owner of the property or, in his absence, his widow.

Q2: Can any relative adopt a Ghar Damad?

No. According to the Supreme Court's July 2026 judgment, only the last male owner or his widow has the authority to adopt a Ghar Damad. An uncle-in-law, brother, or any other collateral relative cannot do so. This is a strict requirement of Oraon customary law.

Q3: What happens if a Ghar Damad adoption is invalid?

If the Ghar Damad adoption is invalid, the person claiming through it has no succession rights. In such cases, the property devolves upon the nearest male agnate of the family, as happened in the Bejla Oraon case where the plaintiff was decreed as the rightful owner.

Q4: Is Ghar Damad the same as adoption under Hindu law?

No. Ghar Damad is a tribal custom, not statutory adoption under the Hindu Adoptions and Maintenance Act, 1956. The procedures, requirements, and legal effects are different. Ghar Damad is specific to certain tribal communities and follows their customary rules.

Q5: How do courts determine if a custom exists?

Courts look at multiple factors: (1) authoritative scholarly works, (2) long-standing and continuous practice, (3) consistency in community behavior, (4) witness testimonies from community elders, and (5) previous judicial precedents. The party claiming the custom must prove all these elements.

Q6: What is the significance of S.C. Roy's book in this case?

S.C. Roy's "The Oraons of Chotanagpur" is an authoritative anthropological work on Oraon customs. The Supreme Court relied heavily on this book because it has been cited and accepted by courts for decades as a reliable source of Oraon customary law. It provided the specific rule that only the last male owner or widow can adopt a Ghar Damad.

Q7: Can this judgment be applied to other tribal customs?

While this judgment is specific to Oraon customary law, the legal principles — especially the burden of proof rule and the strict interpretation of custom requirements — can be applied to other tribal custom cases. However, each community's customs must be examined independently based on their own authoritative sources.

Conclusion: A Landmark Victory for Legal Certainty in Customary Law

The Supreme Court's judgment in Bejla Oraon v. Kali Das Oraon & Ors. is a landmark decision that brings much-needed clarity to the law of tribal customs in India. By holding that an uncle-in-law cannot adopt his niece's husband as a Ghar Damad, the Court has protected the integrity of the Oraon customary law while also preventing potential misuse of customs for property grabbing.

The judgment is significant for multiple reasons. It reaffirms the burden of proof rule in custom-based claims. It criticizes the High Court's failure to answer framed questions of law. It demonstrates the importance of authoritative scholarly sources in proving customs. And most importantly, it shows that even in the realm of unwritten tribal customs, the law demands clear evidence and strict adherence to established rules.

For the Oraon community, this judgment means that the Ghar Damad institution remains meaningful and protected from dilution. For lawyers, it provides a clear precedent on how to handle custom-based property disputes. For law students, it is a rich case study that touches on evidence law, civil procedure, property law, and tribal rights — all in one judgment.

The Supreme Court's final words in this case were clear and decisive: "Taking a cumulative view of the matter, we are of the considered view that in the present facts the customs as alleged... could not be proved." The plaintiff's suit was decreed, the lower courts' judgments were set aside, and justice was done — not by ignoring custom, but by insisting that custom be proved according to its own strict requirements.

And that, dear readers, is how the rule of law works in India — even in the most traditional and remote communities.

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Last Updated: July 2026 | Article Published on Barristery.in | Case Citation: Bejla Oraon v. Kali Das Oraon & Ors., 2026 INSC 672