Customary divorce is a procedure of marital dissolution in various cultures around India and elsewhere based on long-established community practices. While statutory codes like the Hindu Marriage Act of 1955, Muslim personal laws, and other similar codes have become the mainstay of the legal code, customary divorce is an important feature in many communities and, in fact, more so in the rural and tribal areas. Customary divorce, on the other hand, works almost always based on uncodified norms and conventions that differ from region to region and community to community. It is an evolved issue in the context of law in India, being recognized in different ways. The Indian Constitution, under Article 13, recognizes customs and traditions. However, this article provides for the recognition of customs that do not conflict with the fundamental rights of people. Application of customary law in contemporary India is not without its problems. The validity and proof of a customary divorce depend on several factors, such as antiquity of the custom, continuity, and its reasonableness. Courts in India are expected to decide these customs. Most often no documentary evidence is available, and such divorces are confirmed to be valid through community testimonies and expert opinions.
This is so because it is hard to ascertain the age of the practice, and no documents are available for documentation purposes. Within the same community, the customs are also different from each other. Most traditional divorces are informal, have not been codified or officially recognised, and their legality varies from one location to another. This paper hopes to delve into the procedural and evidentiary requirements of proof for a customary divorce so as to understand the depth of legal provisions, the judicial role in this regard, and the individual’s plight in proving a valid divorce under custom. Furthermore, through the. Furthermore, this paper tries to put forward suggestions on how this process of proving customary divorce can be improved so that justice is delivered and traditions are given their due respect.
The following sections of this paper are intended to discuss the legal framework governing customary divorce in India, along with relevant statutory provisions, landmark judicial cases, and the essential criteria for a valid custom. It will also address the evidence-related challenges that arise in proving customary divorce, showing how documentary evidence, community declarations, and expert testimonies contribute to such proof. From these grounds, the paper will delineate how regular divorce is proved, the legal implications, and the possibilities of reforms to deal with challenges in this system.
Customary divorce is the termination of marriage on the grounds of widely followed community customs rather than statutory codification. Divorce practices vary across communities, which mostly originate from older customs passed down from previous generations. Customary divorce is mainly practiced in those communities that follow oral tradition and cultural rule rather than the rule of written law, especially among the tribal, rural, or specific religious communities. Unlike statutory divorce, which has well-defined law codes such as the Hindu Marriage Act, 1955, or Muslim personal law, customary divorces depend solely on the community’s mutual consent and hardly ever find their place in any kind of written code.
Recognition of customary divorce by the Indian legal system
The Indian legal system recognises customary divorce, although it is relatively rare and dependent on various other factors. Indian law, under religious laws, grants recognition to personal customs through different sections. One of such sections includes Section 29(2) of the Hindu Marriage Act, 1955, wherein the Indian legal system recognised the customs and practices related to marriage in different communities. This must be “ancient” and “reasonable” for such customs to be considered valid. Customary divorce occurs most frequently within tribal groups and in villages where laws are followed through the customs that prevail within any given community; this sometimes gives rise to differences from the codified law. Customary divorce in these regions is based on mutual consent, repudiation by either spouse, and other traditional mechanisms such as khula in a Muslim community or tribal rites within an indigenous society.
Section 29(2) of the Hindu Marriage Act, 1955 allows customs in divorce proceedings but subject to certain conditions: that is, the custom must not offend public policy and must have been long in existence without break. This is why the existence and consistency of a customary divorce practice should be proved. Such a custom for a divorce is accepted only when such evidence reveals that it had been a common practice for some time and remained so without interference from formal law.
Certain specific criteria from judicial interpretation should be met for the custom of divorce to be legitimate. The practice has to be proven as being antique first of all, that is, from time immemorial, or at least for quite some time. Therefore, generally at least 20 years will need proof, though that depends on the case. And it also has to show continuity, which is a consistent practice for many years and must have been an acceptable norm for the community. Third, the custom must be certain, that is, it must be clear, well articulated, and constantly followed by the community such that it must not be ambiguous or subjectively interpreted. Lastly, the custom should be reasonable and pass the test of justice, morality, and public policy. Courts dismiss customs that are discriminatory or against human rights. One such case is Bai Dayabai v. Chaganlal (AIR 1956 SC 354), where some unreasonable customs were declared to be against public policy and thus invalid.
The courts have largely been used in determining the validity of customary divorce, especially where divorce is based on a practice not put down in law. The judicial determination will be whether the given custom could be regarded as a rightful practice according to the already laid criteria and whether such practice accords with the very fundamentals of rights guaranteed by the Constitution. Further, the courts look upon the issue of whether such custom accords with the postulates of justice and equality, and this particularly in the context of the gender rights.
In the well-known judgement of Subramaniam v. Saraswati, AIR 1954 SC 76, the Supreme Court held that the burden of proving a custom of divorce lies on the party advancing the custom, and that the same must be shown to have been ancient, continuous, and consistent with public policy. In disputes, it pointed out that custom should be proven valid by plenty of evidence: testimonies from the members of the community, opinions of experts, and historical documents. The court held customary divorce valid only if these strict standards can be met.
The personal laws of India comprise a wide range of laws, each making their own provisions for divorce. The existence of customary divorce is thus indicative of the pluralistic nature of Indian society, where practices of law existing within communities are valued as well. Legal recognition for customary divorce hinges on the alignment of statutory law by virtue of which family law in India is structured. The sections that follow discuss some of the essential legal frameworks applicable to customary divorce under personal laws.
Customary Divorce under Hindu Law
The Hindu Marriage Act, 1955, is the main statute governing marriage and divorce for Hindus in India. Even though the Act primarily deals with divorce by judicial proceedings, Section 29(2) provides for customary divorce. It is, thus, in this section that recourse is provided to an ancient, continued, certain and reasonable custom of a community in proceeding with their divorce. Mutual consent divorce in Hindu law is that where the parties agree mutually to dissolve the marriage or repudiation where one party may unilaterally dissolve the marriage based on community practices.
For instance, niyog, which is the dissolution of marriage by community elders or religious authorities, may be considered customary divorce in rural and tribal societies. The same practice may not be written anywhere in the legal text, but the community accepts it as its customary law. Thus, developing such customs would become crucial for determining whether such practices are valid under the Hindu Marriage Act.
Muslim Law and Customary Divorce
In Muslim personal law, it comes under the laws of talaq, the husband-initiated divorce, as well as khula, where the wife initiates divorce. However, other than these formal processes specified in the Quran and its jurisprudence, innumerable traditional divorce practices are maintained within the Muslim communities of India. Customary divorce in Muslim law may take such forms as talaq-e-tafweez, whereby the right to divorce the husband is bestowed upon the wife, or procedures based on local religious authorities or family councils making decisions as to the conditions of divorce.
The recognition of such practices under Indian law is susceptible to the judicial scrutiny of courts, as was in the case of Khanum Jan v. Ambedkar, where the Supreme Court had the case regarding the validity of talaq practices that were not formally documented but were a part of community tradition. The court also ruled that even customary divorce, though not codified, could be recognised but should still be within the aim of long-standing practice, and such practices must also not violate the principles of equality and justice, particularly regarding women’s rights.
Tribal Laws and Customary Divorce
The tribal communities in India have specific laws and customs that govern the conditions of marriage and divorce. These are usually unwritten laws based on local traditions, practices, and authority among tribal elders. Tribal customary divorce might include panchayat decisions or choices from the tribal council, differing from the statutory procedures under the Hindu Marriage Act or the Muslim Personal Law.
One of the significant challenges with tribal customary divorce is the lack of formal records or documentation. Since many tribal communities live in rural areas with limited access to formal legal systems, the evidence required to establish the existence and validity of such customs is often difficult to obtain. The courts would then rely on the testimony of members within the community, expert witnesses, and anthropological studies in ascertaining whether or not a custom exists. For example, in cases dealing with tribal divorce practices, the Supreme Court has often relied on the testimonies of community elders and anthropologists in determining whether a custom exists and if it agrees with the principles of the law.
The court decides whether a customary divorce practice is valid and enforceable. In this regard, it should keep in mind that the practices are not against major constitutional values like equality and dignified treatment accorded to an individual. As such, in Subramaniam v. Saraswati AIR 1954 SC 76, it was emphasised that such customary divorces need judicial consideration. The court further ruled that customs recognised should respect set legal parameters and should also not contravene public policy.
Judicial scrutiny also encompasses whether these customary divorce practices are discriminatory to a party, more so the female gender. If customs are likely to go against the interests of females, courts have intervened to supersede or declare invalid such practices. For example, in regard to talaq or polygamous marriages, the courts have declared null and void those practices predisposed against women or infringing on their rights under the constitution.
We now turn to the evidentiary difficulties in proving customary divorce in the following sections and analyse landmark cases that have shaped the judicial understanding of customary divorce in India.
Proving Customary Divorce: Evidentiary Challenges
Proving customary divorces is difficult since customary practices remain largely unwritten and are significantly heterogeneous in different communities. The rules governing statutory divorce are codified procedures and evidence. Because customary divorce relies on tradition, community acceptance, and oral testimony, it is quite impossible to give concrete, verifiable proof in most cases. Formal involvement of the state may be absent in most informal customary divorces, and even formal or paper-based evidence is also missing. This makes the burden of proof particularly daunting for anyone who wishes to achieve a legal split by the courts.
Oral evidence is the most important tool in proving customary divorce. Most customs are unwritten. The courts will rely on the depositions of witnesses, more especially the members of the community or family members, to prove that the custom existed and how it was applied in a particular case. This form of evidence is important in cases where there is no formal documentation on the divorce. Community elders, religious leaders, and other people who know the practice can also act as witnesses to the validity of the practice.
However, oral evidence is limited to its authenticity and credibility. The credibility of testimonies is quite difficult to establish, and the courts must be very careful in their reliance on oral evidence. In some other cases, people may be testifying out of personal interests, such as property tussles or family feuds, making the testimonies not reliable and biased. In such a case, the courts will try to establish corroborative evidence, that is, community declarations, expert opinions, or anthropological studies, to validate the custom.
The Difficulty of Documentary Evidence
The other challenge of customary divorce is a lack of documentary evidence. Unlike statutory divorce, which attracts formal legal documents such as divorce decrees, judgements, or marriage certificates, customary divorce often takes place without the presence of any legal institutions. In this case, there is no formal document or written evidence of a divorce that thereafter becomes a burden to prove. Some of the traditional divorce practices may be found in the community records or religious scriptures, but such records are normally not available, or perhaps very rare in villages or tribal societies.
The documentary evidence is rare, and it tends to force courts to resort to indirect forms of proof, such as testimonies and historical contexts, in addition to the consistent practice over time. For example, courts can rely on historic accounts or anthropological works describing the custom as well as its application within the community. Still, these sources are not free from issues in that they fail to give an accurate picture of things nowadays or because they were written a long time ago.
Sometimes courts allow testimony by anthropologists, sociologists, or historians to prove that the custom does exist. Expert testimony can be given relating to the antiquity and continuity of the practice or whether it was reasonable, again factors that go into finding a valid custom. Where there is a lack of proof by documents, expert testimony fills in gaps by giving an informed opinion as to the cultural and historical significance of the custom.
Customary divorce is always recognised and legitimised within the community, even though it may not be a recognised state divorce. To this end, acceptance by the community of a divorce may become important evidence that can prove its legitimacy. In some cases, declarations by the community or public recognition of the divorce may serve as proof. For example, the community leader or elder can publicize the divorce or have a ceremony in which the community recognises the dissolution of marriage.
The problem lies in that such declarations are not documented or recorded in any formal manner, and one’s validity as evidence would raise a question. This then leaves the courts to meticulously discern the circumstances surrounding such declarations for it to be confirmed that they are genuine, or if the community, from time to time, recognised the custom in issue.
It then becomes suspicious of the authenticity of the declarations made by communities, especially when a practice is not uniform in such cases of customary divorces. For example, even if various persons from the same community testify that it was not in accordance with custom, then there are conflicting accounts of which divorce actually occurred or in what way, and therefore the court would be likely to struggle with validation of the testimonies from the community as good evidence.
For a customary divorce to be recognised, one must show that the custom is old and continuing. This requirement poses many problems, especially in regions where written records are very scarce and oral tradition is the only way of passing on cultural norms.
It is difficult to prove that a custom is old without any historical records or other forms of documentation. Oral histories, anthropological studies, or other such works, and the testimony of experts might form the bases of their evidence in respect of custom origins. Nonetheless, reliance of courts upon these might be fraught with scepticism because their credentials cannot always be proved valid. Corroborative testimony of other members of society might, for example, be necessary; even the testimonies may require the historicity to be corroborated by relevant and proper documentation of customs by historical observers.
This requires demonstrating that the practice has been followed in a uniform way over history, which can be a more challenging task if the custom was not static but evolved over time or the pattern of its application in society was not uniform. Evidence pertaining to how the custom previously worked and whether the custom continues to date within the group is sought by the courts. If the practice is no longer practiced or even replaced by the introduction of statutory divorce procedures, the courts may not recognise it.
In the absence of any written document, expert opinions and evidence garnered from anthropology would play a great role in proving the existence and validity of a customary divorce. Researchers in the fields of anthropology and sociology could also throw light upon the socio-cultural significance of the custom and testify as an expert based on the practice, continuation, and historical perspectives of the custom.
These experts can also be very helpful in giving useful evidence on the acceptance of the custom by the community and its place in the general social context. For example, they can testify on how the community has always solved marital disputes or dissolved marriages through customary ways. Sometimes, courts will hire anthropologists to conduct field research or studies in order to collect evidence on whether the custom is valid and whether it remains relevant.
However, there are challenges to the expert testimony as well. Experts might have their own versions of the custom and may not share the same view with the court or community. Expert evidence can also be very costly and very time-consuming. It’s problematic when resources for a case are scarce or when the custom in question is less documented.
Landmark Cases in Customary Divorce
There have been many landmark judgements over the years that have defined the Indian law in regard to customary divorce. It established the legal standards of recognition for customary divorce and brought to the fore the difficulties associated with establishing both the existence and legitimacy of such customs. Some of the most influential decisions are listed below.
Subramaniam v. Saraswati, AIR 1954 SC 76
One of the most important cases in the development of customary divorce law is Subramaniam v. Saraswati. There, the Supreme Court of India dealt with the case of whether a customary divorce-based community practice can be recognised or not under the Hindu Marriage Act, 1955. The Supreme Court held the view that customary divorce practices can indeed be recognised only if there are some set criteria available, such as antiquity and continuity, consistent with public policy.
In the case where the point of proof of existence was clearly and convincingly presented using testimonies from witnesses and opinions from experts. It went ahead establishing the principle that the burden of proving on is put before a person claiming that such custom exists, and for upholding the validity of this claimed custom, it should first be proved that the particular practice has been continued for a very long time by that community. This case will always stand as one among the strong principles of customary divorces in India.
Bai Dayabai v. Chaganlal (AIR 1956 SC 354)
In Bai Dayabai v. Chaganlal, the question of fact was whether there existed under the Hindu Marriage Act, a valid custom entitling a husband to give a unilateral repudiation, which ends the marriage relationship between man and wife, that being a direct infringement by such custom on the principles of justice or public policy of the well-established right of equality and security of women against hasty separation.
This was a landmark judgement as it brought forth the fact that the practices followed in the customary way should not violate any fundamental rights, specifically gender equality. It reiterated that though customary divorce could be recognised, it could not be contrary to the principles of the Constitution’s moral and ethical values like equality and dignity for every individual.
Khanum Jan v. Ambedkar (AIR 1961 SC 172)
In Khanum Jan v. Ambedkar, the Supreme Court was concerned with a case in which a Muslim woman tried to prove the validity of her divorce under customary Muslim practices. The Court held that the validity of a customary divorce depends on the specific practice followed by the community and that the party seeking recognition of the divorce must provide evidence that the custom is consistent with the community’s longstanding practices.
This is one such case that made it clear that, though the practice of customary divorce be allowed even under Muslim law, evidence of its being consistent and continuous in the community is required. This judgement also came out with community declarations and expert testimony regarding the validity of a custom.
Indra Sarma v. V.K.V. Sarma, AIR 2013 SC 3170
In the case of Indra Sarma v. V.K.V. Sarma, the Supreme Court considered whether, in the context of Hindu marriage, there could exist evidence of the existence of customary divorce. The Court laid down that a customary divorce can be recognised only in cases where it is ancient, continuous, and reasonable. The Court insisted that the existence of such a custom should be proved with clear evidence such as testimony from community elders, anthropologists, or historical records.
This case reinforced the principle that customary divorce is not automatically valid and that courts must carefully examine the evidence to determine whether the custom is truly consistent with the principles of justice, equality, and public policy.
The issue of customary divorce is also intertwined with gender dynamics because traditional practices could empower or disempower individuals, especially women. Customary divorce practices have been male-dominated in most societies, promoting control over marital dissolution by men. Nevertheless, the understanding of the gendered implications of customary divorce should be done both in terms of its legal recognition and of its possible social and cultural effects on women. The section will discuss how conventional divorce practices affect gender relations and women’s rights.
Traditionally, divorce practices are skewed towards males in some cultures; hence, the right to divorce is granted to the man at his discretion without asking the wife. This kind of practice is culturally bound to the patriarchal levels of society, where the males have been perceived as the heads of the families. For instance, in other tribal or indigenous societies, men can announce the intention to divorce a marriage without seeking the approval of the wife or other powerful authority figures. This is a bad practice regarding the rights of women since they are not entitled to participate in dissolution of their marriages.
On the other hand, some traditional divorce practices are more bilateral. Here, spouses can even file for divorce against each other. However, this is practiced less and is relatively confined to more liberalised or matriarchal societies in which the social status of women is greater. In such cultures, there is more representation of women in deciding over their marital destiny.
One example of the pattern of gender disparity in customary divorce is an important feature of several African and South Asian traditions. In these systems, for instance, women are often required to return the dowry or bride price in the event of a divorce. Such practices place an economic burden on women, particularly in societies where women have limited access to financial resources. The threat of repaying the dowry or bride price often places a woman in an absolutely powerless position, with very little in the way of living options once the divorce actually happens.
Women’s Rights and Customary Divorce
Recognition of customary divorce, especially in its more patriarchal forms, presents a contradiction for women’s rights. Customary divorce forms, which confer the power upon men to unilaterally dissolve the union, give very little options or means to protection to women. Women may be deserted by their husbands without any legal or material aid. In addition, if customary divorce is not legally accepted at the state level, then often alimony or distribution of property, which normally accompanies statutory divorce, is not available.
In disputed or contested customary divorces, this lack of formal legal recognition usually leaves the woman to navigate a tangle of traditional practices and social pressures coupled with uncertainty on the legal side. A power imbalance that may additionally be exacerbated in such divorces, especially where the husband has greater power within the community or resources, also might be seen without legal protection.
Various legal reforms have strived to fill this gap. For example, the Hindu Marriage Act of 1955 protects the rights of women during a divorce through maintenance, alimony, and division of property. However, such rights are mostly unutilizable in the case of customary divorces that occur beyond statutes’ reach. Moreover, such allowance of customary divorce through these cases often inadvertently further perpetuates patriarchal practices by denying women equally effective protection.
To this end, various reforms addressing the gender biases in customary divorce may be required. One such measure is the inclusion of gender-sensitive provisions in granting recognition to customary divorce. In this line, customary divorce practices have to be ensured not to become a source of undermining and disadvantage to women. For example, communities can be challenged to review traditional practices so that women have an equal voice in the dissolution of marriage and are not left vulnerable to the financial consequences of divorce.
A more elaborate legal framework may be designed for women’s protection under customary divorce. The same would ensure that women who undergo customary divorces are given legal remedies like maintenance and division of property even if the divorce is not recognised under customary law. This may be done by extending protection under statutory divorce laws to cases of customary divorces so that women get a more balanced deal.
In some countries, like India, reforms in family law have strengthened gender equality in divorce proceedings. However, generally, statutory divorce forms the base of these reforms, and customary divorce has been left aside. Reforming customary divorce practices to address the issues of inequality between genders is an important step towards upholding women’s rights over all forms of marital dissolution.
The Role of Courts in Recognizing Customary Divorce
Courts play a very significant role in deciding whether or not a customary divorce should be recognised in a court of law. As the Indian judiciary struggled through trying to deal with a case of customary divorce bordering on issues of tradition and community practices against constitutional rights. This section will investigate how courts recognise customary divorce, what approach the courts take when evaluating customary practices, and on what basis the courts determine whether a customary divorce should be legally valid.
Over time, judicial decisions on Indian customary divorce have become more inclined toward the consistency of customs with public policy, the enforcement of the fundamental rights of citizens, and the cause of social justice. The Indian judiciary has become quite more careful while exercising judicial power to declare any practice as customary that involves discriminatory preferences or goes against the principles of equality and non-discrimination under the Constitution.
Generally, the courts held that customary divorce, especially in indigenous or tribal communities, is part of the identity of their social and cultural community. Hence, courts tolerated community practices so long as they were not violative of constitutional rights and public policy. In this case, however, the courts did not hesitate to declare it inconsistent with those principles.
In cases where customary divorce is contested, the courts will rely on several factors to determine whether the custom should be recognized. Such factors include the antiquity and continuity of the custom, its consistency with public policy, and the impact it has on the rights of individuals, particularly women. The courts also consider whether the custom has been consistently practiced within the community and whether it reflects the values and social norms of that community.
Indian courts examine several essential factors for the validity of customary divorce. These essentials must have antiquity and continuity. It should be long-standing and continued to be practiced within the community. It often requires evidence, like testimony from witnesses, historical records, or expert opinions to establish its historical roots. It must also pass the test of reasonableness and public policy, comply with principles of justice, and protect the rights of individuals because courts will not acknowledge customs that are discriminatory, oppressive, or in violation of fundamental constitutional rights. The custom must also possess cultural value, constitute part of a people’s identity, and reflect legitimate social or cultural purposes. It should also reflect compatibility with constitutional rights in that it does not offend the principles of equality and cannot discriminate capriciously, most especially against women. Finally, evidence that the custom is observed must clearly and convincingly show the existence and observance of this custom through testimony, expert opinion, and historical or community documentation.
Landmark Cases on Customary Divorce
The Indian judiciary has passed many landmark judgements over the years, which have moulded the legal structure of customary divorce. Some notable cases are as follows-
- Subramaniam v. Saraswati AIR 1954 SC 76: This case enunciated the principles for considering a recognition of customary divorce by stating that the custom must be ancient, continuous, and consistent with public policy.
- Bai Dayabai v. Chaganlal (AIR 1956 SC 354): The Court in this case held that a customary divorce cannot be recognised if it runs counter to the principles of justice and public policy, particularly regarding the issue of gender equality.
- Indra Sarma v. V.K.V. Sarma (AIR 2013 SC 3170): This judgement further stressed the requirement that customary divorce practices should not run counter to constitutional principles, particularly on issues related to women.
Future of Traditional Divorce: Legal Reforms and Societal Changes
The future of customary divorce will likely come out as the result of other factors in legal reforms and societal trends toward marriages and divorces. Continuing on, India goes into this process of modernisation, slowly affecting the role of customary divorce in legal space. This next part will be discussing the possibility that these reforms may recognise customary divorces but also the shortcomings that come with traditional practices.
There is an emerging consciousness of the need to adjust customary divorce practice toward modern legal standards in favour of gender equality and respect for rights. Reform proposals include the inclusion of customary divorce under statutory law under a uniform legal standard of both statutory divorce that maintains provisions on maintenance, distribution of property, and safeguarding against arbitrary dissolution. This shall also include gender-sensitive reforms such as giving women equal rights both in initiating the divorce procedures as well as ensuring financial help after divorce. Another influential proposal is the establishment of the formal legal framework for the system of customary divorce, stipulating the conditions for its official acceptance, and ensuring that there exist all constitutional provisions and equitable defences before the courts for both. These reforms will modernise customary divorce practices but preserve their cultural integrity and promote equality.
Along with these legal reforms, the social transformations will also shape the future of customary divorce. In India, the trend for greater gender equality has gained popularity, and so have calls to recognise women’s rights in all areas of family law, including divorce. It is likely to impact customary divorce practices and attitudes in communities.
As societies embrace the need for gender equality and individual rights, divorce may slowly detest patriarchal tendencies. Women will be in a position to seek divorce and make claims regarding their rights under customary law, thereby increasing the fairness and equity associated with divorce.
Conclusion
The future of customary divorces in India has a direct correlation to how legal reforms are continuing to influence society and vice versa. In aiming to grow towards a more representative and fairer society, there is a significant need to ensure that customary divorce practices meet principles of gender equity, justice, and individual rights. It lies within the mandate and understanding of courts and legislations to work further toward ensuring that customary divorce is both respectful to cultural traditions as well as protective of the rights of all parties concerned. In order to achieve this effect, India should address the issue of gender inequality, put legal safeguards on women’s rights, and develop an all-inclusive legal framework for customary divorce.
Author: Anannya Mohanty is currently pursuing a BA LLB at Symbiosis Law School.
