ONE LAW, MANY INDIAS: A CRITICAL RE-EXAMINATION OF THE UNIFORM CIVIL CODE, THE CONSTITUENT ASSEMBLY’S DIRECTIVE PRINCIPLE COMPROMISE, AND THE EDUCATIONAL MANUFACTURE OF CONSENT

Authors:- 1) Z. Zeenath Farzu, 2) Sameera Noby, Final year students, Pursuing L.L.B (Unitary) in Nehru Academy of Law, Palakkad Kerala (Citation – RLF/ART/2026/03)

Brief bio: We are final year law student with interest in research and exploring international humanitarian laws and constitutional deadlocks. Also keen on exploring and analysing statutory and constitutional conflicts. 

The Uniform Civil Code (UCC) is routinely presented, in policy discourse and increasingly in enacted state law, as an unqualified constitutional aspiration whose realisation is simply a matter of political will. This paper argues that this framing understates two things: the sheer difficulty of applying a single civil code evenly across India’s religious and caste diversity, and the deliberateness with which the Constitution’s framers withheld Article 44 from the chapters on Fundamental Right, placing it instead among the non-justiciable Directive Principles of State Policy. Also, the Legislative Members, framing the Fundamental Duties avoided any inclusive provision for UCC. Drawing on the Constituent Assembly Debates, on the pattern of Scheduled Tribe exemptions and unresolved customary-law questions, such as fraternal polyandry in Uttarakhand’s Jaunsar-Bawar region, within the four state Uniform Civil Codes enacted (two States) and passed (two States) between 2024 and 2026, and on recent, contested revisions to NCERT and CBSE school curricula, this paper contends that the current sub-national wave of UCC legislation is moving faster than either the constitutional design or the gradual and consultative approach which the Constituent Assembly Members coveted. It further argues that the school curriculum, by simultaneously trimming coverage of India’s contested religious and communal history while retaining an affirmative civic framing of legal uniformity as national integration, risks producing a generation that inherits an assumption of uniformity’s desirability rather than arriving at it through engagement with the diversity a UCC necessarily displaces. The paper concludes not that a Uniform Civil Code is illegitimate, but that its legitimacy, on the framers’ own terms, depends on a depth of consent and a respect for plurality that recent legislative practice has not consistently supplied.

Keywords: Uniform Civil Code; Legal Pluralism; Directive Principles of State Policy; Constituent Assembly; Civic Education; Religious and Caste Diversity; Consent.

A Uniform Civil Code is frequently described, by its supporters and increasingly by state legislatures, as the natural and overdue completion of the constitutional project of national integration that’s one law, replacing many, for one people. This paper takes issue with that description, not by denying that India’s personal laws contain real inequities, particularly for women, but by questioning three assumptions on which the case for uniformity typically rests.

First, it questions whether ‘personal law’ in India was ever uniform enough, even within a single religion or caste, for a single code to represent anything other than the elevation of one community’s norms over the customary norms of many others. Second, it questions whether the swift, state-by-state enactment of Uniform Civil Codes since 2024 is consistent with, or a departure from, the constitutional choice to lodge Article 44[1] among the non-justiciable Directive Principles rather than the Fundamental Rights or Fundamental Duties, a choice this paper argues was neither accidental nor merely procedural. Third, it questions whether the generation now coming of age is encountering the case for a Uniform Civil Code as a live, seriously contested policy question, or as an inherited civic assumption, shaped in part by contemporaneous and contested revisions to the school curriculum through which most Indians first encounter the idea of Article 44 at all.

These three questions are connected. If personal law was always more plural than the Hindu-Muslim binary in which the UCC debate is usually conducted, then uniformity is not simply a matter of replacing ‘many religious laws’ with ‘one secular law’; it is a matter of choosing, among many customary systems, including several practised by Hindus and by constitutionally recognised tribal communities, which one becomes the template for all. If the framers deliberately built consent and gradualism into Article 44’s constitutional placement, then a legislative wave that proceeds by exemption and expedited passage, rather than by the sustained consultation Uttarakhand itself modelled, sits uneasily with that design. And if the school curriculum increasingly presents the case for uniformity while curtailing the historical material that would allow a student to weigh what pluralism costs to give up, then the ‘consent’ on which the framers’ compromise depended risks becoming, for a generation of students, a foregone conclusion rather than a live choice.

Discussions of the Uniform Civil Code typically proceed as though ‘personal law’ in India divides neatly along religious lines: Hindu law, Muslim law, Christian law, Parsi law, each internally coherent and externally distinct. This framing understates the diversity within what is loosely called Hindu law itself, and it is this internal diversity, as much as inter-religious difference, that a uniform code must necessarily flatten.

Before its statutory reform in the mid-twentieth century, Hindu succession law was not a single system but a family of regional schools, the most consequential divide being between the Mitakshara system, prevalent across most of India, and the Dayabhaga system followed in Bengal and Assam, which differed fundamentally on when a son’s right in ancestral property arose. Beneath even this divide sat further regional and caste-specific customary systems that codification only partially absorbed. Among the Nair community of Kerala, inheritance and family organisation historically followed the Marumakkathayam system of matrilineal descent, in which property passed through the female line within the taravad, or joint matrilineal household, a structure fundamentally at odds with the patrilineal, individual-inheritance model that later codification, and any uniform code modelled on it, presupposes.[2] A structurally similar matrilineal system, Aliyasantana, governed inheritance among the Bunt and allied communities of coastal Karnataka and required separate statutory treatment.[3] In Meghalaya, the Khasi and Garo communities continue to practise matrilineal inheritance today, a system protected not as a religious personal law but as a customary and social practice under the Sixth Schedule to the Constitution, which vests law-making power over marriage and social custom in Autonomous District Councils rather than in Parliament or the state legislature.[4]

Marriage practices show a comparable diversity that a single code, framed around monogamous, registration-based marriage, cannot straightforwardly absorb. Fraternal polyandry, in which a woman is married to two or more brothers, has been documented among the Jaunsari community of Uttarakhand’s Jaunsar-Bawar region, among the Toda community of the Nilgiris in Tamil Nadu, and, as recently as 2025, among the Hatti community of Himachal Pradesh’s Trans-Giri region, where the practice, known locally as Jodidaran, continues to be solemnised as a functioning social institution intended to preserve undivided agricultural landholding among brothers.[5]

The Constitution’s response to this diversity has not been to deny it exists, but to shield it selectively: where a community holds Scheduled Tribe status, as the Hatti now do, its customary marriage practices retain constitutional protection notwithstanding a state’s general ban on plural marriage; where a community’s status is more ambiguous, as with the Jaunsari, whose classification and the precise reach of the Uttarakhand Code over them has itself been a subject of uncertainty and dispute, no such settled protection exists.[6] Naga customary law receives comparable, express constitutional protection: no Act of Parliament touching Naga religious or social practice, or Naga customary law and procedure, applies to Nagaland unless the state’s own legislature so decides.[7]

The point of this survey is not that every one of these customary systems is beyond critique; several, including forms of polyandry and polygyny alike, have been criticised on the same grounds of gendered inequity that motivate the case for a Uniform Civil Code in the first place. The point, rather, is that ‘personal law’ in India was never a binary of Hindu and Muslim law awaiting a single secular replacement. It was, and in the constitutionally protected pockets described above remains, a genuinely plural field, plural along lines of caste, region, and tribe as much as religion.

A uniform code, however, carefully drafted, cannot avoid the fact that it makes one of these systems, typically the codified, patrilineal, Sanskritic model that already underlies the Hindu Marriage Act and the Hindu Succession Act, the default against which every other community’s departure is measured and, eventually, disallowed.

The state-level Uniform Civil Codes enacted since 2024, in Uttarakhand,[8] and the states such as Gujarat,[9] Assam,[10] and Madhya Pradesh,[11] waiting for the Presidential assent, supply the clearest evidence that the diversity described in Section II cannot simply be legislated away. Every one of the four codes exempts Scheduled Tribes from its application, a concession made not out of administrative convenience but out of constitutional necessity, given the protections in Part XXI and the Fifth and Sixth Schedules. In Uttarakhand, this exemption covers a small Scheduled Tribe population of the state’s total population, the Tharu, Bhotiya, and other Scheduled Tribe communities of the border districts of Chamoli and Pithoragarh, leaving the code to apply, at least formally, to the remaining 97 per cent.[12]

The exemption itself, though, has drawn criticism from an unexpected direction. The Jaunsari community of Jaunsar-Bawar, whose fraternal polyandry is well documented, is itself one of Uttarakhand’s five officially recognised Scheduled Tribes, alongside the Tharu, Bhotiya, Buksa, and Raji, and is therefore exempted from the Code’s ban on plural marriage under Section 2 of the Uttarakhand Uniform Civil Code Rules, 2024.[13] Rather than leaving the community’s position unsettled, this exemption has instead been attacked by supporters of the Code as unprincipled: an Uttarakhand High Court advocate has argued that, unlike Scheduled Tribes in states such as Chhattisgarh or Jharkhand, Uttarakhand’s tribal communities are ‘far more integrated with normal life,’ so that ‘there was no reason to exclude them from the UCC; whatever reason has been given to exclude them is baseless,’ and the state government’s own standing counsel has suggested the carve-out may be temporary, describing eventual tribal inclusion as a likely ‘third phase’ of the Code’s rollout.[14] The dispute, in other words, is not over whether Jaunsari customary polyandry currently falls outside the Code’s reach, it does, but over whether the line the Code draws between which communities’ customs merit protection and which do not can be defended on any principle more precise than administrative convenience. Critics have raised a further, related gap: the Uttarakhand Code, for all its stated commitment to gender equality, makes no provision at all for third-gender or same-sex relationships, a silence that itself undercuts the claim that the Code achieves uniform coverage of the population it purports to govern.[15]

Political reaction to the Uttarakhand Code’s claim to uniformity has been sharp on a related point. A spokesperson for the state’s opposition party publicly questioned how the legislation could be termed ‘uniform’ at all, given that only one state had adopted it and given the exemptions built into its text, describing the exercise instead as converting a single state into what she called a ‘Hindutva Laboratory’ ahead of national elections.[16] Whatever one makes of the framing, the underlying observation, that a code applying unevenly across tribal status, contested even by the Code’s own supporters, and silent on gender identity cannot accurately be called uniform in the ordinary sense of that word, is difficult to dismiss. Gujarat, Assam, and Madhya Pradesh have each replicated the same Scheduled Tribe exemption in their own codes, meaning the pattern is not an Uttarakhand-specific drafting oversight but a structural feature of the entire sub-national wave: each state has, in effect, conceded that a single code cannot cover its entire population, while continuing to describe the result as uniform for the population that remains.

The scale of what these exemptions carve out varies considerably, and that variation itself undercuts any suggestion that the exemption is a marginal technicality. Assam, the first North-Eastern state to endorse a Uniform Civil Code (awaiting Presidential assent), has a Scheduled Tribe population considerably larger, and more politically organised, than Uttarakhand’s, spread across autonomous council areas whose customary institutions predate the Code by generations; framing the Assam Bill as achieving uniformity therefore means, in practice, framing a code that does not reach a substantial and geographically concentrated share of the state’s population as nonetheless uniform for the state as a whole. Gujarat presents a related difficulty from a different direction: its own Adivasi belt, concentrated in districts such as the Dangs, falls outside the Code’s reach on the same Scheduled Tribe logic, while segments of the state’s Muslim community have separately raised the same objection voiced in Uttarakhand, that a code drafted without sustained engagement with the community most directly affected by the end of separate personal law cannot straightforwardly claim their consent merely because it claims their coverage. Madhya Pradesh, finally, illustrates the point at its sharpest: a Bill covering the state’s general population while exempting its Scheduled Tribes, passed by voice vote over an Opposition walkout, is uniform in name for whichever share of the population did not object loudly enough to stop it, which is a considerably thinner sense of uniformity than the phrase ‘Uniform Civil Code’ is generally taken to promise.

It is worth asking, more carefully than the current pace of legislation invites, why Article 44 sits where it does in the Constitution’s architecture. The Constitution offers, broadly, three registers in which a citizen’s or the state’s obligations can be framed: Fundamental Rights, enforceable against the state and directly justiciable before the courts; Fundamental Duties under Article 51A, which guide citizen conduct without creating an enforceable claim; and Directive Principles of State Policy, which Article 37 expressly declares ‘shall not be enforceable by any court,’ while remaining, in the same breath, ‘fundamental in the governance of the country.’[17] The Uniform Civil Code sits in the third register, and notably it does not sit in the second either: the Fundamental Duties inserted into the Constitution by the Forty-second Amendment in 1976 contain no duty on the citizen to observe or support a common civil code, even though other duties in that list, such as promoting harmony among religious and linguistic groups, touch on closely related terrain.[18] The absence is notable: had the framers, or later Parliament, wished to frame legal uniformity as something citizens owe one another, Article 51A was the available vehicle, and it was not used.

This was not an oversight. The Constituent Assembly’s Fundamental Rights Sub-Committee, chaired by Sardar Vallabhbhai Patel, considered directly whether a uniform civil code should be guaranteed as a justiciable Fundamental Right and decided, by a narrow majority, that it should not be; the matter was instead routed into the Directive Principles. Three members of that sub-committee, Minoo Masani, Hansa Mehta, and Amrit Kaur, dissented from that outcome, arguing that leaving the UCC unenforceable would allow it to be indefinitely deferred, and proposed instead that it be guaranteed to citizens within five to ten years.[19] Their proposal was not adopted. When the matter reached the floor of the Assembly as Draft Article 35 on 23 November 1948, Muslim members including Mohammad Ismail and Naziruddin Ahmad objected that the provision would amount to ‘tinkering’ with personal laws that communities had observed for generations, and pressed for an express saving clause protecting personal law from the article’s reach.[20] Dr B.R. Ambedkar, closing the debate, declined to accept a blanket saving clause, but offered the dissenting members a different kind of assurance: that Article 44 created, in his words, only a ‘power’ for a future Parliament, not an ‘obligation’ on the present one, that its scope should not be read as more expansive than its text warranted, and, according to several accounts of the debate, that any future uniform code might initially be made applicable only to those who chose to be governed by it.[21] A recent academic account of the debate describes the eventual placement of the Uniform Civil Code within the non-justiciable Directive Principles as, in essence, ‘a compromise between legal uniformity and pluralist accommodation,’ a considered middle path rather than an unfinished piece of drafting.[22]

Read together, these sources support a specific claim: the framers did not simply fail to make the Uniform Civil Code enforceable; they affirmatively declined to make it a Fundamental Right that citizens could claim immediately, declined to make it a Fundamental Duty that citizens owed one another, and instead lodged it among aspirations the state should pursue only as, and when, social consensus permitted, with Ambedkar’s own language suggesting that consent, not compulsion, was to be uniformity’s engine. Measured against that design, the manner in which Uttarakhand, Gujarat, Assam, and Madhya Pradesh have proceeded, using Scheduled Tribe exemptions to carve out the population least able to accept the code rather than to build consensus with it, and, in Madhya Pradesh’s case, passing the measure by voice vote amid vocal opposition protest rather than through anything resembling the Uttarakhand committee’s forty-three public consultations, looks less like the fulfilment of Article 44’s promise and more like an attempt to convert a consent-anchored directive into ordinary majoritarian legislation by the most expedient available route: the state list rather than the national one.[23] This is not to say state legislatures lack the constitutional competence to act; marriage, divorce, and succession sit in the Concurrent List, and a state law inconsistent with an earlier Union statute can prevail within that state once it receives the President’s assent under Article 254(2).[24][25] It is to say that constitutional competence and constitutional fidelity to the framers’ own stated conditions for pursuing uniformity, gradualism and consent, are two different questions, and the current pace of legislation has answered only the first.

Ambedkar’s own qualification deserves closer attention than it usually gets, because it is frequently elided in contemporary invocations of his support for the Uniform Civil Code. Ambedkar did not simply endorse uniformity in the abstract; he coupled his endorsement with the specific suggestion that any future code might, at least initially, be made applicable only to those who consented to be governed by it, a model closer to an opt-in civil code than to the compulsory, all-encompassing statutes now being enacted. None of the four state codes adopted since 2024 has taken up this opt-in possibility for the non-exempt population; each instead applies compulsorily to every resident who is not a member of an exempted Scheduled Tribe, with no mechanism by which a Jaunsari family, for instance, could elect to continue under its customary marital arrangement while a neighbouring family opted into the new Code. Whether an opt-in model would have been administratively workable at scale is a fair question; whether its absence brings the current codes closer to, or further from, the consent-based vision Ambedkar actually articulated is a question the enacted texts, on their face, answer for themselves.

If Ambedkar’s compromise made consent the precondition for a uniform code’s legitimacy, then the manner in which successive generations are taught to understand both India’s religious plurality and the case for legal uniformity becomes, itself, a matter of constitutional consequence, not merely of pedagogy. It is in this light that recent, and contested, revisions to NCERT textbooks used across CBSE-affiliated schools deserve attention.

Between 2020 and 2025, NCERT carried out a series of deletions and revisions to its Political Science and Social Science textbooks that removed or altered material bearing directly on India’s contested religious history. In 2024, references to the demolition of the Babri Masjid, to the killing of Muslims during the Gujarat riots, and to the ideology of Hindutva were dropped from the Class 11 and Class 12 Political Science textbooks; in one passage, the words ‘Babri Masjid’ were themselves replaced with the phrase ‘three-domed structure.’[26] In April 2025, NCERT’s revised Class 7 Social Science textbook removed chapters on the Delhi Sultanate and the Mughal Empire in favour of expanded coverage of ancient Indian dynasties, continuing a reduction in Mughal-era content that had already begun in 2022.[27] NCERT’s director defended the changes publicly, arguing that the purpose of school textbooks was ‘not to create violent, depressed citizens’ by teaching them about riots, and stating that ‘all changes in textbooks are based on evidence and facts’ rather than any project of ideological revision.[28] Critics were not persuaded: the School Teachers’ Federation of India, at its 2025 conference, formally condemned the cumulative pattern of revisions as ‘ideologically driven,’ warning that it posed ‘a grave threat to the constitutional values of secularism, equality, and diversity,’ and Congress leader Jairam Ramesh went further, alleging that NCERT had ‘been functioning as an RSS affiliate since 2014.’[29][30]

This paper does not take a position on the accuracy of the ‘RSS affiliate’ characterisation, which is a matter of ongoing political dispute rather than settled fact, and it accepts that NCERT’s own stated rationale, avoiding the teaching of communal violence to school-age children, is not on its face unreasonable. What is significant for the argument of this paper is narrower and better supported: the same institutional process that has, on the critics’ account, curtailed students’ exposure to the contested, minority-inflected history of communal conflict in India has not, on any account, curtailed the civics curriculum’s coverage of Article 44 itself, which continues to be taught, across CBSE Political Science and Legal Studies syllabi, as a Directive Principle whose fulfilment represents an unqualified marker of national integration and secular modernity, largely without the countervailing material on customary and tribal legal diversity surveyed in Section II of this paper, or the gradualist, consent-based reading of Ambedkar’s own remarks surveyed in Section IV. A student encountering the two halves of this curriculum together, less material on why plurality has historically mattered and been fought over, unchanged or increasing material presenting uniformity as a settled constitutional good, is more likely to inherit the desirability of a Uniform Civil Code as background civic knowledge than to arrive at a view on it, favourable or otherwise, through engagement with what such a code asks India’s customary and religious communities to give up. Whether this convergence is the product of deliberate design or of two separately motivated processes, a curriculum-rationalisation exercise defended on child-welfare grounds, and a legislative wave pursued on federalism and political grounds, arriving at the same destination, is a question this paper cannot resolve on the available evidence. But the effect on the depth of consent available to the next generation of citizens and legislators is, on either account, the same, and it is an effect the framers’ own compromise in Section IV suggests should matter a great deal to how the Uniform Civil Code’s legitimacy is ultimately judged.

None of the foregoing supports the conclusion that a Uniform Civil Code is illegitimate as such, or that the gender inequities documented within several personal-law systems do not deserve legislative attention. It supports a narrower conclusion: that the legitimacy of any move toward uniformity, on the framers’ own terms, depends on preserving, rather than bypassing, the plurality and consent that Article 44’s placement in the Directive Principles was designed to protect. Four modest correctives follow.

First, future state codes, and any eventual national code, should engage directly with the sub-tribal, sub-caste, and regional customary diversity documented in Section II, rather than treating the Scheduled Tribe exemption as a complete answer to the problem of plurality. The unresolved status of communities such as the Jaunsari suggests that the boundary of who is, and is not, covered by a ‘uniform’ code requires far more careful, community-specific fact-finding than has so far been undertaken.

Second, the Law Commission’s 2018 view, that targeted removal of discriminatory provisions within each personal-law system may achieve the gender-equality goals usually invoked in support of a UCC without requiring wholesale replacement of plural systems, deserves renewed consideration precisely because it can proceed community by community, with the consent of each, rather than by simple legislative majority.[31]

Third, any state considering a Uniform Civil Code after Madhya Pradesh should be expected, as a matter of constitutional practice rather than mere political courtesy, to replicate the depth of Uttarakhand’s forty-three-consultation process rather than its result alone; a code adopted by voice vote amid walkouts cannot straightforwardly claim the consent-based legitimacy Ambedkar’s compromise presupposed.

Fourth, and most directly responsive to Section V, civics and legal-studies curricula should present the Uniform Civil Code as what the Constituent Assembly Debates show it to be: a question the framers themselves treated as genuinely open, weighed against India’s religious and customary plurality and resolved, deliberately, in favour of gradualism and consent rather than immediate uniform command. A curriculum that teaches Article 44 without also teaching why it was placed where it was, and what plurality it was designed to accommodate, does not equip the next generation to consent to a Uniform Civil Code so much as it invites them to inherit one.

The case for a Uniform Civil Code is usually made as though uniformity were self-evidently desirable and its absence merely a matter of unfinished business from 1950. This paper has argued that both halves of that assumption deserve scrutiny. India’s personal laws were never uniform even along the single axis of religion most commonly invoked in the debate; they encompassed, and in constitutionally protected pockets still encompass, matrilineal inheritance, fraternal polyandry, and Sixth Schedule customary governance that a single code, however carefully drafted, cannot fully absorb without asking some communities to give up more than others. And the framers who wrote Article 44 did not regard uniformity as self-evidently desirable either: they debated it, split over it, and ultimately chose to lodge it among the Directive Principles rather than the Fundamental Rights or Fundamental Duties, on the express understanding, voiced by Ambedkar himself, that it created a power for a future Parliament rather than an obligation on the present one, to be exercised, if at all, with the consent of those it would govern.

Set against that design, the sub-national wave of 2024 to 2026, four codes in under two and a half years, each conceding through its own Scheduled Tribe exemption that uniformity cannot in fact reach the whole population, and at least one passed by voice vote amid walkouts rather than sustained consultation, reads less as the patient fulfilment of a constitutional aspiration than as an attempt to reach, by state-level majority, a destination the framers deliberately made contingent on something more. That the school curriculum through which the next generation first encounters Article 44 has, in the same period, become a site of open dispute over how much of India’s plural and contested religious history it should teach only sharpens the concern: a Uniform Civil Code adopted by a generation that has not been shown what plurality costs to relinquish is not the consent-based uniformity the Constituent Assembly bargained for, whatever else it may be.

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[1]Constitution of India, art. 44.

[2]K. Saradamoni, Matriliny Transformed: Family, Law and Ideology in Twentieth Century Travancore (Sage 1999) (on the Marumakkathayam system of matrilineal inheritance among Kerala’s Nair community prior to its statutory abolition); see also the Aliyasantana system of the Bunt and allied communities of coastal Karnataka, codified separately under the Madras Aliyasantana Act, 1949, and left substantively in force, though formally renamed, in the successor states created by the States Reorganisation Act, 1956.

[3]See supra note 2.

[4]Patricia Mukhim, The Matrilineal System of the Khasis and Garos of Meghalaya, Raiot (various dates); the Khasi and Garo matrilineal systems of inheritance in Meghalaya are protected under the Sixth Schedule to the Constitution of India, which empowers Autonomous District Councils to make laws on, inter alia, marriage and social customs.

[5]Polyandry in India, Drishti Judiciary (July 28, 2025), https://www.drishtijudiciary.com/editorial/polyandry-in-india.

[6]What is the Legal Status of Polyandry in India?, Rau’s IAS Compass (July 23, 2025), https://compass.rauias.com/current-affairs/legal-status-polyandry-india/ (citing Section 2 of the Uttarakhand Uniform Civil Code Rules, 2025).

[7]Constitution of India, art. 371A (special provision for Nagaland, under which no Act of Parliament affecting Naga religious or social practices, customary law and procedure, or administration of civil and criminal justice involving decisions according to Naga customary law applies to Nagaland unless the State Legislative Assembly so decides).

[8]The Uniform Civil Code, Uttarakhand, 2024 (Act No. 3 of 2024), assented to 12 March 2024, brought into force 27 January 2025.

[9]Uniform Civil Code Bill 2026: Gujarat Joins Uttarakhand in Historic Legal Reform, LexHorizon (Mar. 27, 2026), https://www.lexhorizon.in/post/uniform-civil-code-bill-2026-gujarat-joins-uttarakhand-in-historic-legal-reform.

[10]Assam Becomes Third State to Pass Uniform Civil Code (UCC) Bill, 2026, Drishti IAS (May 29, 2026), https://www.drishtiias.com/state-pcs-current-affairs/assam-becomes-third-state-to-pass-uniform-civil-code-ucc-bill-2026.

[11]Uniform Civil Code in India: All about Madhya Pradesh’s UCC Bill, Lawctopus (Aug. 1, 2026), https://www.lawctopus.com/clatalogue/clat-pg/uniform-civil-code-in-india-2/.

[12]Ban On Polygamy, Fixed Marriage Age, Exempt Tribals: Recommendations In UCC Draft For Uttarakhand, Outlook (Feb. 6, 2024), https://www.outlookindia.com/national/ban-on-polygamy-fixed-marriage-age-tribals-exempted-recommendations-in-ucc-draft-for-uttarakhand.

[13] The Uniform Civil Code of Uttarakhand, 2024, S. 2

[14]Uttarakhand Uniform Civil Code Bill Tabled; Polygamy, Polyandry Banned, The Tribune (Feb. 6, 2024), https://www.tribuneindia.com/news/uttarakhand/uttarakhand-ucc-bill-tabled-polygamy-polyandry-banned-588080/.

[15]1 Step Forward, Many Steps Back In Uttarakhand’s Uniform Civil Code, IndiaSpend (Mar. 18, 2024), https://www.indiaspend.com/governance/1-step-forward-many-steps-back-in-uttarakhands-uniform-civil-code-900242.

[16]See supra note 12.

[17]Constitution of India, art. 37 (the Directive Principles ‘shall not be enforceable by any court, but the principles therein laid down are nevertheless fundamental in the governance of the country’).

[18]Constitution of India, art. 51A (Fundamental Duties of citizens, added by the Constitution (Forty-second Amendment) Act, 1976, containing no duty to observe a common civil code).

[19]The Constituent Assembly Debated Uniform Civil Code, Article 35 (which became Art. 44 later) on November 3, 1948, Vol VII.

[20]An Analysis of the Chronological Journey of Uniform Civil Code, IJIRL, https://ijirl.com/wp-content/uploads/2022/07/AN-ANALYSIS-OF-THE-CHRONOLOGICAL-JOURNEY-OF-UNIFORM-CIVIL-CODE.pdf (on the objection of Mohammad Ismail, seconded by Naziruddin Ahmad, that inserting Article 44 would amount to ‘tinkering’ with personal laws ‘which people have observed for generation and ages’); see also An Anatomy of the Uniform Civil Code: This is How Article 44 was Passed in the Constituent Assembly, The Siasat Daily (archived) (on the same exchange, moved as an amendment to Draft Article 35 by Mohammed Ismail Sahib and seconded by Naziruddin Ahmad).

[21]Constituent Assembly Debate on Uniform Civil Code, BYJU’S (Dec. 14, 2022), https://byjus.com/free-ias-prep/constituent-assembly-debate-on-uniform-civil-code/ (on Dr B.R. Ambedkar’s assurance to Muslim members that Article 44 created only a ‘power’, not an ‘obligation’, and his suggestion that the members should ‘not read too much into Article 44’).

[22]Debating Uniform Civil Code: The Making of Article 44 in the Constituent Assembly of India, 9(3) Indian Law Review (2025), https://www.tandfonline.com/doi/full/10.1080/24730580.2025.2570575 (describing the placement of the Uniform Civil Code within the non-justiciable Directive Principles as ‘a compromise between legal uniformity and pluralist accommodation’).

[23]Law Commission of India, Consultation Paper on Reform of Family Law (31 August 2018) 2, concluding that a Uniform Civil Code ‘is neither necessary nor desirable at this stage.’

[24]Constitution of India, sch. 7, List III (Concurrent List), entry 5.

[25]Constitution of India, art. 254(2).

[26]NCERT Drops References to Babri Masjid, Gujarat Riots, Hindutva in Political Science Textbooks, Careers360 (Apr. 5, 2024), https://news.careers360.com/ncert-drops-references-babri-masjid-gujarat-riots-hindutva-ayodhya-demolition-class-11-12-political-science-textbooks.

[27]No Delhi Sultanate, Mughals in Books: A Look at Past NCERT Syllabus Changes, Business Standard (Apr. 28, 2025), https://www.business-standard.com/india-news/ncert-revises-class-7-history-syllabus-no-mughals-or-delhi-sultans-cbse-125042801049_1.html.

[28]NCERT Textbook Revision Draws Flak Again, This Time On Secularism And Omission Of Babri Masjid, Outlook (June 19, 2024), https://www.outlookindia.com/national/ncert-textbook-revision-draws-flak-again-this-time-on-secularism-and-omission-of-babri-masjid (quoting NCERT director Dinesh Prasad Saklani’s statement that ‘all changes in textbooks are based on evidence and facts’ and are not an attempt to ‘saffronise’ the curriculum).

[29]STFI Deplores Changes in NCERT Books, Peoples Democracy (Sept. 7, 2025), https://peoplesdemocracy.in/2025/0907_pd/stfi-deplores-changes-ncert-books (School Teachers’ Federation of India resolution condemning NCERT textbook revisions between 2020 and 2025 as ‘ideologically driven’ and warning that the changes ‘pose a grave threat to the constitutional values of secularism, equality, and diversity’).

[30]NEET 2024: Congress Leader Jairam Ramesh Criticizes NCERT in Grace Marks Controversy, Careers360 (June 2024), https://news.careers360.com/neet-2024-congress-leader-jairam-ramesh-criticizes-ncert-grace-marks-controversy (recording Congress leader Jairam Ramesh’s allegation that NCERT ‘has been functioning as an RSS affiliate since 2014’).

[31]See supra note 23.