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White Black Legal – International Law Journal · ISSN 2581-8503
OWNERSHIP RIGHTS OF AN UNBORN CHILD IN PROPERTY: AN ANALYTICAL STUDY OF LEGALITY WITH REFERENCE TO SECTION 13 OF THE TRANSFER OF PROPERTY ACT, 1882
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Abstract
OWNERSHIP
RIGHTS OF AN UNBORN CHILD IN PROPERTY: AN ANALYTICAL STUDY OF LEGALITY WITH
REFERENCE TO SECTION 13 OF THE TRANSFER OF PROPERTY ACT, 1882
ABSTRACT
This paper is a comprehensive
analysis of ownership rights of an unborn child in a property, especially
referring Section 13 of Transfer of Property Act, 1882. The provision allows
transfers to be made to benefit persons who did not exist at the time of the
transfer and is a balance between recognition of unborn rights and the rule
against perpetuities. The paper examines the legislative intent of Section 13
and its historical background, drawing on the principles and theories of Roman
law, English equity and indigenous Indian law, and placing it in the context of
the general legislation of property in colonial India. It starts with the
statutory conditions for transfers to unborn persons with special focus on the
need to create a prior life interest and to have absolute ownership upon
vesting. It then examines the jurisprudential basis of the provision, noting
the quasi-personal status that has been given to unborn children and the
conditionalness of their rights. Judicial interpretation is critically analyzed,
e.g. Tagore's case v. Tagore, Raja Bajrang Bahadur Singh v. Thakurain Bakhtraj
Kuer, highlighting the role of judiciary in upholding legislature intent and
avoiding perpetuity. Along with this doctrinal discussion of contingent and
vested interests, the paper considers the ethical and policy dimensions of
protecting future generations and the difficulties of enforcement in the form
of guardianship and trusteeship. It critically examines the positive and
negative aspects of Section 13, highlighting that it has been effective in
protecting unborn rights, but also identifying its inflexibility in
contemporary times, especially in the context of advances in reproductive
technologies, surrogacy, and estate planning.
Keywords: Unborn
child, property rights, Section 13, Transfer of Property Act, rule against
perpetuity, contingent interest, absolute ownership, succession, guardianship,
comparative jurisprudence.
INTRODUCTION
Historically, jurists, legislators
and scholars of private law have been puzzled by the question of whether unborn
children can have an ownership interest in property. The question is not only
theoretical but very practical, because it involves the succession, the
inheritance, guardianship and all legal philosophy about personhood. This
debate has a statutory basis in Indian jurisprudence under the Transfer of
Property Act, 1882 (hereinafter “TPA”) under which transfer of property for the
benefit of unborn persons have been explicitly provided. The provision is
simple, yet complex in terms of the nature of ownership, the time limits of
legal personality and the balance between the intent of the legislation and
judicial interpretation.
Property law, being a part of private
law, is essentially about the management, transfer and safeguarding of rights
over real and intangible property. Ownership, in the classical sense, is the
most complete right that individuals can have over a thing, which includes the
rights to possess, use, enjoy, and dispose of it. However, the notion of
ownership is not either-or, but is subject to social, moral and legal factors.
In the case of ownership of an unborn child, the law is faced with the problem
of the rights of a non-existent entity. This paradox is not peculiar to Indian
law, but is seen in the Roman law where there is a maxim, nasciturus pro iam
nato habetur, quotiens de commodis eius agitur (“the unborn is treated as born
when his interests are being served”).[2]
The principle is reflected in section
13 of the TPA which allows the transfer of a property for the benefit of unborn
persons under certain conditions. The provisions contained in the transfer of
property state that the transfer cannot be made directly to an unborn person,
but it can be made by creating a prior interest in favor of a living person,
with the remainder to vest in the unborn on their birth.[3]
In the provision, the unborn child's interest is dependent on its eventual
birth, while the need for protecting future rights is met through the prior
interest creation on behalf of a living person. It has been criticized,
however, that the requirement of a prior life interest is too restrictive,
especially when the transferor is trying to benefit the unborn directly, rather
than through some intermediacy.
The concept of legal personality
provides the jurisprudential basis for an interpretation of Section 13. The law
traditionally understands that persons are entitled to rights and subjects to
duties; and the issue of whether an unborn child is a “person” has been
discussed at various levels in various jurisdictions. The unborn is not a
person in the strict sense of the word, but it is given a quasi-personality
status for certain purposes, including inheritance, guardianship, and transfer
of property, only if the child is born alive.[4]
In all the cases before the Supreme Court of India relating to succession and
guardianship, it has consistently held that the unborn child's rights are
contingent but they must still be protected.[5]
It is also important to note that
Section 13 has a history. The Transfer of Property Act was passed in 1882
because of the codification of property laws in India in colonial times. Before
the advent of codification, the transfer of property was regulated by a
combination of customary law, Hindu personal law, Muslim personal law and
English common law principle. The framers of the Act aimed to reconcile these
conflicting influences and added clarity and predictability. The provision has
been influenced by English equity law which accorded rights to unborn
beneficiaries of trusts as well as by the Hindu law which allowed transfers for
the benefit of future generations.[6]
Section 13 has also developed over
time because of judicial interpretation. The case Tagore v. Tagore (1872) was
decided before the TPA came into existence and has served to illustrate the
restrictions on testamentary freedom and the conflict between the individual
and legislation. Later cases have expanded the reach of Section 13, to the
effect that transfers of unborn persons are allowed but must follow the
statutory requirement for a life interest. Additionally, courts have made it
clear that the unborn child's interest is contingent rather than vested,
meaning that it does not accrue until the child is born, thus avoiding
speculative claims.[7]
Contrasting jurisprudence provides
useful insights of Indian position. As mentioned above, in Roman law the unborn
was considered to have certain rights for the benefit of the unborn. English
common law, through the doctrine of trusts, allowed property to be held for
unborn beneficiaries, subject to the rule against perpetuities.[8]
In civil law jurisdictions such as France and Germany, the unborn is recognized
as having conditional rights, particularly in matters of succession.[9]
The United States, through its property and succession laws, similarly
acknowledges the rights of unborn children, often through the mechanism of
guardianship or trusteeship. These comparative perspectives highlight the
universality of the issue and the diverse solutions adopted by different legal
systems.[10]
The doctrinal aspect brings up a
number of analytical questions regarding the recognition of unborn rights. One
of the issues is whether the unborn child is a “person” under property law.
Second, the distinction between contingent and vested interests becomes
important, given that there are medical and reproductive technologies that have
advanced to the point where recognition of a contingent interest can also be
regarded as vested.[11]
A contingent interest is one that is subject to an event in the future, such as
an unborn child, while a vested interest would be an immediate and absolute
interest. Under the law, contingent recognition is only undertaken with
caution, which also leaves uncertainty for beneficiaries. Third, there are real
world issues to address in the implementation of such rights, including the
problem of guardians or trustees acting in the best interests of the unborn.
The protection of unborn rights is often complicated by problems with
fraudulent transfers, mismanagement and disputes among heirs.[12]
The recognition of unborn rights has
social and moral significance as a policy consideration. It allows for the
continuity of the property; prevents the loss of the property to future
generations and ensures fairness. But the constraints of Section 13 – such as
having a prior life interest – could work against these goals. Furthermore,
changes in science and technology, such as assisted reproduction, surrogacy and
genetic interventions, have added new layers to the debate, and traditional
doctrines need to be revisited.[13]
LEGISLATIVE
INTENT BEHIND SECTION 13 OF THE TRANSFER OF PROPERTY ACT, 1882
The Transfer of Property Act, 1882 (TPA) was a
significant piece of legislation in colonial India aimed at providing clarity
and uniformity in the transfer of properties. Its provisions include, among
others, a special one relating to transfers for the benefit of the unborn,
which is the case in Section 13. In the context of the legislative goal to
balance the requirement to transfer between “living persons” with the moral and
social obligation to protect the interests of future generations, the key question
is whether they are distinct or complementary.[14]
The question is whether they are separate or overlapping goals in balancing the
requirement to transfer between “living persons” with the moral and social
obligation to protect the interests of future generations. The framers of the
statute felt that it would be necessary to achieve a compromise between the
individual's freedom of disposition and the public policy issues of the rule
against perpetuities, certainty of ownership, and circulation of property in
society.[15]
In the past, the property law in India was based on a
combination of the Hindu and Muslim personal laws, customs and English common
law. The drafters of the TPA had to consider the various traditions on the
rights of unborn heirs and ancestry and adapt their provision to be both
culturally meaningful and legally acceptable.[16]
There are three basic goals of the legislative intent
of Section 13. It wished first, to acknowledge all unborn children as future
rights holders of the land transfer, making for continuity of family ownership
and for future generation. The second purpose was to offer a definite method of
such transfers, requiring that a life interest be established in favor of a
living person, the remainder to go to the unborn child on his birth.[17]
Third, Section 13 was designed to uphold the principle of the rule against
perpetuities which is a fundamental legal principle in England and was
incorporated into Section 14 of the TPA. The requirement that the unborn
child's right would be absolute and not just a life interest guaranteed that
property would not be permanently "entangled" in the contingent
claims of the unborn child.[18]
The legislative purposes have always been supported by
judicial interpretation. Tagore v. Tagore (1872) was a precedent case prior to
the TPA and the Privy Council ruled that it was not possible to transfer
property in a way that was contrary to the rules of inheritance under the
Hindus.[19]
This case pointed to the risks of allowing testamentary freedom without
restrictions and led to the drafting of Section 13. The Supreme Court of India
in two later cases, namely, Raja Bajrang Bahadur Singh v. Thakurain Bakhtraj
Kuer (1953) and Gourishankar v. Shantibai (1959), has interpreted the right to
absolute interest and not limited or life interest for the benefit of the
unborn beneficiaries, thereby reinforcing the intention of the legislature to
prevent perpetuity.[20]
Other provisions in the TPA are relevant to the
interpretation of Section 13 and help to shed further light on the legislative
purpose. Under Section 5, definitions of transfers do not include a transfer to
an unborn child. Except in the case of transfers for unborn beneficiaries,
there is an exception in Section 13. With Section 13, the rule against
perpetuities is incorporated into Section 14. Together, these provisions form a
complete system, meeting the criteria for vesting and contingent interests, and
for vesting of interest on birth, which is necessary to strike a balance
between the right to recognize unborn rights and the need for certainty and
circulation of property.[21]
At the policy level, the purpose and objective of
Section 13 is to modernize Indian property law, and to respect indigenous law
and policy. The legislature aimed at protecting both the unborn beneficiary as
well as the public interest in the circulation of property, by demanding absolute
vesting in the unborn. The provision is underpinned by a dual focus to
individual and social interests, making it pragmatic.[22]
There has been a substantial amount of critical
investigation of Section 13 by modern scholarship. In today's world, however,
the strictness of Section 13 has been subject of criticism, given the
advancements in reproductive technologies, surrogacy and estate planning. The
reason is that, although the intent of the legislators was correct at the time,
it may not be sufficient for current realities and require changes to the
provision.[23]
DETAILED
ANALYSIS OF SECTION 13, TRANSFER OF PROPERTY ACT, 1882:
The Transfer of Property Act, 1882 (TPA) was passed to
codify and rationalize the property law in India, bringing together various
influences of Hindu and Muslim personal laws, customary law and English common
law. A few of its elements include a unique provision which recognizes the
rights of unborns in regard to the transfer of property, which is found in
Section 13. This section is restrictive and protective and reflects the purpose
of the legislature to ensure that the rights of unborn children are considered
and protected, while at the same time ensuring property transactions are not
perpetually hindered by uncertainty and/or perpetuity.[24]
Three key issues in the analysis of Section 13 are: (i) the conditions of
transfer to unborn persons; (ii) the need for a prior life interest in order to
vest; and (iii) legal consequences of transfers.
The
conditions under which the transfer of ownership to unborn persons is
permitted.
The first requirement under section 13 is the transfer
must be made for the benefit of a person who was not present at the time of the
transfer. This is in line with the statutory recognition of unborn children as
potential beneficiaries, even though they are not defined as “persons” as per
section 5 of the TPA, where transfers are restricted to between living persons.[25]
This is done by providing an exception that, although transfers to unborn
persons cannot happen, transfers may be made in respect of contingent transfers
to secure the rights of unborn persons. As part of the condition, transfers are
not speculative or indefinite but are only made when the child is born.
It is a protection clause to ensure that the property
will always be under the stewardship of a living person until the unborn child
is born.[26]
It avoids property being left in a legal limbo and continuity of ownership. The
previous interest serves as a link between the transferor and the yet-to-be
born interest.
The third requirement is that the interest given to
the unborn child must include the entire interest of the transferor.[27]
Here, absolute ownership, and not a limited or life interest, must be given to
the unborn child. The idea is that it will stop perpetuity, that is, tying
property to contingent claims indefinitely. The legislature's intent in
providing for absolute vesting was to encourage movement of property and to
discourage the encumbrances on alienation.
These conditions have been further confirmed by
judicial interpretation. In the case of Raja Bajrang Bahadur Singh v Thakurain
Bakhtraj Kuer, 1953, the Supreme Court had ruled that the interests of unborn
persons are absolute, not limited interests, thus confirming the intention of
the legislature in the first place.[28]
In the case of Gourishankar v Shantibai, 1959, the Madhya Pradesh High Court
had ruled that the interest of unborn persons is subject to the condition of
live birth and this is a cautious approach of the legislature in the first
place.[29]
The
obligation to have had a prior life interest prior to vesting.
A condition of having a prior life interest is key to
Section 13. This provision is intended to serve several purposes: First, the
property must be transferred to a living person and then it passes to the
unborn at the time of their birth.[30]
First, it allows the rights of the unborn child to be under the control of a
living beneficiary until the time that the rights become “actual”. This ensures
that property does not become "abandoned" and ensures legal
certainty. Secondly, it is a way to protect the property: the previous
"beneficiary" becomes the custodian of the property, holding it until
the unborn child can hold rights. Thirdly, it is consistent with the principle
against perpetuities, which would prohibit attaching property to contingent
claims that would last forever.
The burdensome nature of the requirement of prior life
interest has been condemned, especially in situations where the transferor
wants to benefit the unborn directly.[31]
The intent of the legislation, however, was to forestall speculation in
transfer of property and to keep it in the hands of a living person until the
unborn child's rights could be vested. This is the conservative attitude of the
drafters, who wanted to accommodate recognition of unborn rights without
uncertainty or non-calculability of property.
Comparative jurisprudence can provide some insights
into this requirement. The comparative perspective sets the background for the
requirement in English law and the so-called doctrine of trusts, through which
the unborn child's rights are protected, as well as in other civil law
jurisdictions such as France and Germany.
The
legal consequences of such transfers.
The interest is contingent until birth, which means
that the interest in the child does not come into existence until he or she is
born alive. If the child is not born, then the interest does not exist and the
property goes back to the transferor or previous beneficiary. This demonstrates
the conservative attitude of the legislature, which wanted to stop any
speculations and guarantee certainty of ownership.[32]
The need for absolute ownership means that the unborn
child will have all rights in the property including rights of possession,
rights of use, rights of enjoyment and rights to dispose of the property. This
will prevent perpetuity and encourage the circulation of the property. It is
also in keeping with the principle of fairness which states that unborn
children should not be put at a disadvantage in succession and inheritance.
Such transfers have been interpreted by the judiciary.
In Tagore v. Tagore (1872) the Privy Council ruled that any transfer to some
unborn would have to be made in accordance with the statutory requirements, a
decision which shaped the wording of Section 13 which ensured the compliance of
such transfers with the rules of succession under the Hindu law. These
interpretations have the advantage of not only reinforcing the intent of the
legislature, but also that they ensure transfers under Section 13 are valid and
enforceable.[33]
On a policy level, respect for the right to life of
unborn children weighed against certainty and circulation of property is
considered the intent of the legislature in Section 13. The provision
safeguards the unborn child and stops perpetuity and speculative claims. It
also fits in with the larger issues of the TPA to modernize Indian property law
and to integrate the various influences.
Critical
Evaluation
Section 13 is important but is limited. The need for a
prior life interest is limiting and could jeopardize testamentary freedom.
Using live birth means that there is uncertainty and can lead to a loss of
advantage for families when the birth is stillborn or miscarried. The rigidity
of the provision has also been called into question in the light of
improvements in reproductive technology, surrogacy and estate planning, with
scholars arguing for some reform of this provision.[34]
The other argument is that there would need to be uniformity in the law, and
clarity, as the provision is not harmonized with succession law.
Despite the restrictions, Section 13 reflects the
foresight of the framers of the Constitution in weighing individual liberty
against the collective good of society. It recognizes the unborn rights and
simultaneously prevents perpetuity, which is essential for the current as well
as future generations to benefit from property law. It is still a guiding
principle of the property law in India today and will help pave the way for
future changes to the law.
CONCLUSION
The analysis of the right of ownership of unborn child
in property under the Transfer of Property Act, 1882, in relation to section 13
is an intriguing study of the interplay of law, intent and interpretation. The
heart of the matter is that Section 13 is grounded upon the notion that
property can be transferred only between people, but the law must also address
the moral and social obligation to care for the interests of those who were yet
unborn. The provision is not just a mere exception to the rule, but a
well-designed mechanism that recognizes the foresight of the framers in
weighing the individual with the interests of society.
From a detailed analysis it is concluded that the
purpose of Section 13 was threefold – to recognize the rights of the unborn, to
give an unambiguous statutory means for such transfers and to prevent
perpetuity. The legislature wanted to create fairness and certainty by making
sure that there was a prior life interest for transfers to the unborn, and that
the unborn would be given absolute ownership at birth. This arrangement will
avoid the indefinite binding of a property to contingent claims and also safeguard
the future interests of the unborn child.
The basis of Section 13 is jurisprudence of legal
personality. The unborn is not a “person”, for the purposes of the law,
however, it has a quasi-personality. This is recognition in the form of a
conditional right, based on the event of live birth, but nevertheless still
indicative of the law's intent to provide protection beyond the present moment.
The provision thus reflects the old Roman doctrine that "the unborn is
considered born when it can be considered of benefit to mankind," which
has been echoed in different jurisdictions and over the course of history.
Judicial interpretation has always helped to clarify
the intent of the legislature. Tagore v. Tagore and Raja Bajrang Bahadur Singh
v. Thakurain Bakhtraj Kuer are landmark cases which clarified that unborn
beneficiaries must be given absolute interest and not limited interest or life
interest, thus preventing perpetuity. Courts have made clear that the unborn
child's rights are contingent, but nevertheless, deserving of protection, and
that transfers are both valid and enforceable pursuant to Section 13. The
interpretations in these cases show the judiciary's responsibility for
maintaining the delicate balance that the legislature had in mind.
In a comparative context, Section 13 is in line with
international law. The right of unborn children is recognized by civil law
systems like France and Germany, and by English equity, as well as Roman law.
The principle of universalism confirms the moral and legal value of this
principle. The Indian provision is however unique because it does require
absolute ownership, an attitude which is unusually rigorous towards perpetuity
and alienation.
While Section 13 is a tool with promise, it has its
drawbacks. The requirement of prior life interest has been faulted as too
restrictive, especially with respect to transfers to direct the benefits to the
unborn. Use of live birth introduces uncertainty and can be disadvantageous for
families of stillbirths and miscarriages. Furthermore, the rigidity of the
provision might not be appropriate in today's context, particularly given
recent developments in reproductive technologies, surrogacy and estate planning.
These developments cast doubt on the idea of family and inheritance as they
have been understood in the past, and they require the rethinking of the
statute.
The policy implications of Section 13 are important.
The unborn rights clause ensures continuity of property within families and
also protects future generations. Also, it eliminated perpetuity and encourages
circulation of property by requiring full ownership and life interest. It is an
approach of the legislature that is pragmatic, in that it is based on a balance
between individual autonomy and societal interests. But in the present day,
provisions can be subject to reform to reflect the changing realities. Some
scholars have proposed that direct transfers to unborn persons should be
allowed, with protections, and that the disposition of property should be
consistent and clear with succession law.
Finally, it may be concluded that Section 13 of the
Transfer of Property Act, 1882, is an outstanding piece of legislative wisdom,
a clear sign of foresight and a mark of the wisdom and practicality of that
section of the act. It institutionalizes the rights to the unborn children and
protects the public policy from perpetuity. The conditions it imposes are
carefully balanced between recognition of unborn rights and prevention of
speculative claims: they are: prior life interest; absolute ownership; contingent
vesting. These aims have been consistently upheld by judicial interpretation,
and the provision works as intended.
However, the timeless relevance is contingent on
adaption to contemporary contexts. The new conception of assisted reproduction,
the new family and the new ideas about inheritance have given a new reason to
review the old beliefs. One possibility for reforming Section 13 is to provide
increased flexibility while maintaining the protection against perpetuity. A
means of reforming Section 13 would be to provide increased flexibility, while
keeping the protection against perpetuity. This reform should not violate the
framers' intent, but it should continue their vision into the modern day.
To conclude, Section 13 of the Transfer of Property
Act, 1882, evidences the strength of the law to reconcile metaphysics with
necessity. It reflects the commitment of the legislature to safeguarding unborn
rights and certainty and circulation of property. The advantages are its
clarity and foresight; its weaknesses call for reform. The provisions of
Section 13 of the Indian Constitution have been a prominent feature of Indian
jurisprudence, as the law must be alive not just to the living, but also the unborn.
[1] Associate Professor of Law, Tantia
University, Sri Ganganagar.
[2]
Digest of Justinian, Book I, Title V.
[3] Transfer of Property Act, No. 4 of
1882, § 13 (India).
[4] M.P. Jain, Indian Constitutional
Law 112 (8th ed. 2018).
[5] Kusum v. State of Maharashtra,
(2000) 6 SCC 129.
[6] B.B. Mitra, The Transfer of
Property Act 221 (12th ed. 2015).
[7] Tagore v. Tagore, (1872) 9 Beng LR 377 (PC).
[8] J.H. Baker, An Introduction to
English Legal History 312 (5th ed. 2019).
[9] Code Civil [C. civ.] art. 725
(Fr.); Bürgerliches Gesetzbuch [BGB] § 1923 (Ger.).
[10] Restatement (Third) of Property:
Wills and Other Donative Transfers § 25 (Am. Law Inst. 2003).
[11] P. Ishwara Bhat, Property Law in
India 145 (2016).
[12] Avtar Singh, Law of Property 98
(2017).
[13] R.K. Sinha, Transfer of Property
Act 134 (2019).
[14] Transfer of Property Act, No. 4 of
1882, § 13 (India).
[15] M.P. Jain, Indian Constitutional
Law 112 (8th ed. 2018).
[16] J.H. Baker, An Introduction to
English Legal History 312 (5th ed. 2019).
[17] Digest of Justinian, Book I, Title
V.
[18] Avtar Singh, Law of Property 98
(2017).
[19]
Tagore v. Tagore, (1872) 9 Beng LR 377 (PC).
[20] Raja Bajrang Bahadur Singh v.
Thakurain Bakhtraj Kuer, AIR 1953 SC 7.
[21] B.B. Mitra, The Transfer of
Property Act 221 (12th ed. 2015).
[22] P. Ishwara Bhat, Property Law in
India 145 (2016).
[23] S. Krishnan, “Unborn Rights and
Reproductive Technologies,” 42 Indian Bar Review 67 (2021).
[24] Transfer of Property Act, No. 4 of
1882, § 13 (India).
[25] Id. § 5.
[26] Avtar Singh, Law of Property 98
(2017).
[27] R.K. Sinha, Transfer of Property
Act 134 (2019).
[28] Raja Bajrang Bahadur Singh v.
Thakurain Bakhtraj Kuer, AIR 1953 SC 7.
[29] Gourishankar v. Shantibai, AIR
1959 MP 240.
[30] B.B. Mitra, The Transfer of
Property Act 221 (12th ed. 2015).
[31] P. Ishwara Bhat, Property Law in
India 145 (2016).
[32] Bürgerliches Gesetzbuch [BGB] §
1923 (Ger.).
[33] Tagore v. Tagore, (1872) 9 Beng LR
377 (PC).
[34] S. Krishnan, “Unborn Rights and
Reproductive Technologies,” 42 Indian Bar Review 67, 72 (2021).
How to Cite This Article
DR. KAPTAN CHAND, OWNERSHIP RIGHTS OF AN UNBORN CHILD IN PROPERTY: AN ANALYTICAL STUDY OF LEGALITY WITH REFERENCE TO SECTION 13 OF THE TRANSFER OF PROPERTY ACT, 1882., White Black Legal – International Law Journal, ISSN: 2581-8503, Vol. 4, Issue 1, September 2026, pp. 527-540, DOI Link: https://www.doi-ds.org/doilink/09.2026-69873974/OWNERSHIP RIGHTS OF AN UNBORN CHILD IN PROPERTY: A. Available at: https://www.whiteblacklegal.co.in/public/details/ownership-rights-of-an-unborn-child-in-property-an-analytical-study-of-legality-with-reference-to-section-13-of-the-transfer-of-property-act-1882
Author & Publication Record
Authors: DR. KAPTAN CHAND
Registration ID: 107077 | Published Paper ID: WBL7077
Year: Sep- 2026 | Volume: 4 | Issue: 1
Approved ISSN: 2581-8503 | Country: Delhi, India
Page No.: 527-540
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