Bombay Regulation IV of 1827 and the "Law of the Defendant" Rule in Muslim Law Cases
- Umang
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Among the provincial statutes governing the application of Mahomedan law in colonial India, Bombay Regulation IV of 1827 stands in a class of its own — for what it does not say. The Bengal, Agra and Assam Civil Courts Act, 1887, though silent on custom, at least expressly directed that Mahomedan law governed Mahomedans in matters of succession, marriage and religious usage. The Madras Civil Courts Act, 1873 named personal law and custom as co-equal rules. The Punjab Laws Act, 1872 placed custom first.
Section 26 of the Bombay Regulation mentions not a single topic of Mahomedan law. Not succession. Not inheritance. Not marriage. Not dower. The section does not say "apply the Mahomedan law to Mahomedans." It does not identify any community by name. It sets out a general four-tier hierarchy for the trial of suits — and Mahomedan personal law reaches Mahomedan litigants only through the third tier of that hierarchy, as "the law of the defendant."
That indirection is not accidental. It is a precise reflection of the diverse, commercially sophisticated, legally plural society of the Bombay Presidency — where Muslim communities ranged from the thoroughly classical to the wholly Hinduised, where custom was entrenched, and where the colonial courts needed a framework broad enough to accommodate all of them. This article examines how that framework operated, what consequences it produced, and how the Muslim Personal Law (Shariat) Application Act, 1937 transformed it.
The Framework: How Mahomedan Law Reached Indian Courts
Before the Regulation itself can be examined, the general framework must be fixed. Mahomedan law is applied by courts in India to Mahomedans not in all matters, but in some matters only. The rules of Mahomedan law applicable in India fall into three categories: those expressly directed by the Legislature to be applied; those applied as a matter of justice, equity and good conscience; and those not applied at all — such as Mahomedan criminal law and the Mahomedan law of evidence.
The practical consequence of this taxonomy is decisive. Rules expressly directed to be applied must be applied even if a court finds them at variance with its own sense of equity. Rules applied only under the conscience standard may be withheld if the court considers them actually contrary to justice and good conscience. Section 26 of the Bombay Regulation provided neither an express mandate for the Mahomedan law nor the conscience standard as the primary basis. It provided a defendant's-law route — and the consequences of that choice played out across generations of litigation.
Section 26: Text and the Four-Tier Hierarchy
Section 26 of the Bombay Regulation IV of 1827 directed that the law to be observed in the trial of suits shall be:
Acts of Parliament and Regulations of Government applicable to the case;
in the absence of such Acts and Regulations, the usage of the country in which the suit arose;
if none such appears, the law of the defendant; and
in the absence of specific law and usage, justice, equity and good conscience alone.
This is the complete text of the governing provision. Four tiers. No enumerated subject-matters. No reference to succession, inheritance, marriage or religious usage. No mention of Mahomedans, Hindus or any other community. The section is entirely neutral in its terms.
Acts of Parliament and Regulations of Government
The first tier placed statutory law at the apex. Where Acts of Parliament or the Governor's Regulations specifically governed the subject-matter of the dispute, those enactments applied without qualification. Legislative enactments that altered or abolished rules of Mahomedan law — such as the Indian Contract Act, 1872 in the domain of commercial contracts — operated at this level to displace the personal law entirely.
Usage of the Country
The second tier placed the usage of the country above the personal law of the defendant. In this respect, the Bombay Regulation differed markedly from the Madras Civil Courts Act, which placed personal law and custom on the same footing, and from the Bengal, Agra and Assam Civil Courts Act, which (in its text) placed personal law first. In the Bombay mufassal, if a usage of the country governed the dispute, the court was directed to apply that usage rather than the defendant's personal law.
But this statutory priority was qualified significantly by the courts.
Law of the Defendant
The third tier — "the law of the defendant" — was the conduit through which Mahomedan personal law reached Muslim litigants in the Bombay mufassal. Where no statutory provision applied, and where no usage of the country governed the matter, the court applied the personal law of the defendant. Since, in an ordinary suit between two Mahomedans, the defendant's personal law is the Mahomedan law, that law governed. This is confirmed by the Privy Council's recognition of the position in Musa Miya v. Kadar Bux (1928) 55 I.A. 171, 52 Bom. — that the Mahomedan law applied to Mahomedans in the mufassal of Bombay is applied presumably as the law of the defendant.
Justice, Equity and Good Conscience
The residuary fourth tier operated where no statutory law, no usage, and no identifiable personal law of the defendant governed the dispute. The content of this standard — as Lord Hobhouse articulated in Waghela v. Sheikh Masludin (1887) 14 I.A. 89, 96 — was generally interpreted to mean the rules of English law if found applicable to Indian society and circumstances.
The Foundational Anomaly: No Express Reference to Mahomedan Law
The most doctrinally significant feature of Section 26 is the complete absence of any reference to Mahomedan law. The Bengal, Agra and Assam Civil Courts Act said: apply the Mahomedan law. The Madras Civil Courts Act said: apply the Mahomedan law or custom having the force of law. The Punjab Laws Act said: apply applicable custom first, then the Mahomedan law. Section 26 of the Bombay Regulation said none of these things.
This means that in the Bombay mufassal, Mahomedan law operated not as a rule of decision named by the Legislature, but as an incident of the defendant's identity. A Mahomedan defendant brought his personal law into the suit as the law applicable to him — not because a statute directed it, but because the statute directed courts to apply the defendant's law, and the Mahomedan law happened to be his. The distinction is not merely academic. It had practical implications for the status of the rule: whether it was the kind of expressly directed rule that courts had to apply regardless of their own assessment of its fairness, or a rule of a softer juridical character.
The courts in the Bombay mufassal applied the Mahomedan law to Muslim litigants across a wide range of matters — succession, inheritance, marriage, dower — not because the Regulation said so explicitly, but by treating the Mahomedan law as the applicable "law of the defendant" in each case.
The Paradox of Usage Before Personal Law
The Bombay Regulation placed "usage of the country" before "law of the defendant" in the hierarchy. On its face, this meant that if a usage of the country governed the dispute, it displaced the defendant's personal law. This might appear to give usage a primacy over personal law in the Bombay mufassal similar to, or even greater than, its position under the Punjab Laws Act.
No Presumption in Favour of Custom
In practice, however, the Bombay courts held that the statutory placing of usage before law
of the defendant carried no presumption in favour of custom. Usage had to be proved. It had to be established that the matter was governed by custom and not by personal law. The Bombay mufassal courts required the party relying on usage to demonstrate it affirmatively, by evidence of specific instances or community practice. (Abdul Hussein v. Sona Dero (1918) 45 Cal. 450, 45 I.A. 10.)
This position is counterintuitive: usage appears first in the statutory text, but personal law is the presumptive rule of decision in the courts' actual practice. The explanation lies in the structure of litigation itself. When both parties are Mahomedans, there is nothing on the face of the dispute to put the court on notice that a local usage governs. The parties and the dispute are identified; the defendant's law is identified; the usage, if any, must be separately pleaded and proved. The person asserting that usage displaces personal law bears the burden throughout.
The Bombay courts, in other words, read the statutory hierarchy in a way that made personal law the default and usage the exception, even though the text appeared to reverse that priority.
Religious Usage and the Graveyard Injunction
The same Regulation, however, was capable of giving effect to religious usages of a different kind — not usages displacing personal law in matters of succession or inheritance, but usages governing community practices in religious matters. The Hon'ble High Court of Bombay, in Ramrao v. Rastumkhan (1901) 26 Bom. 198, gave effect to a usage prevailing in the State for Mahomedan residents to perform rites and ceremonies at the graves of deceased Mahomedans.
When a graveyard was purchased by a new owner who sought to obstruct those ceremonies, the court granted an injunction at the suit of the Mahomedan residents of Dharwar restraining him. The usage of performing religious observances at graves was treated as a usage of the country within the meaning of Section 26 — one that survived the transfer of ownership of the land.
Gifts in the Bombay Mufassal: The Defendant's Law Route
The Bombay Regulation's "law of the defendant" formulation produced an important consequence for the Mahomedan law of gifts in the mufassal. The Mahomedan law of gifts was expressly applied in the Bombay mufassal as the law of the defendant — a position different from that in the Madras mufassal (where gifts were handled under the justice-equity-conscience clause) and from the Bengal territories (where they were not expressly applied at all).
This distinction mattered when the Transfer of Property Act, 1882 was extended to the Bombay territories. Section 123 of the Transfer of Property Act requires that a gift of immovable property be made by a registered instrument. Section 129 of the same Act, however, saves any rule of Mahomedan law from the operation of Chapter VII of the Act. The question arose: did Section 129 save the Mahomedan law of gifts in territories where that law was applied as the law of the parties or of the defendant — or did it only save it where it was an expressly enacted rule?
The Rangoon High Court, in a Full Bench decision, held that Section 129 could not save the Mahomedan law of gifts in Burma, where that law was applied only as a rule of justice, equity and good conscience rather than as a rule of Mahomedan law proper. (Ma Asha v. B.K. Haldar (1936) 14 Rang. 439.) In the Bombay mufassal, by contrast, the Mahomedan law was applied as the law of the defendant — a basis more securely within the phrase "any rule of Mahomedan law" in Section 129 than the conscience standard. Section 129 of the Transfer of Property Act therefore saved Mahomedan gift law in the Bombay mufassal from the registration requirement of Section 123. An oral gift by a Mahomedan in favour of his wife in lieu of her dower was valid without registration.
The West Indian Muslim Communities: A Spectrum of Custom
The most distinctive — and jurisprudentially most complex — consequence of Section 26 of the Bombay Regulation lay in its interaction with the Muslim communities of Western India. The Bombay Presidency contained, within its Muslim population, a range of communities whose relationship to classical Mahomedan law was highly varied. Several of the most prominent had, over generations, retained the Hindu law of their pre-conversion ancestors as a customary law.
Khojas: Hindu Law by Custom
The Khojas are a trading community, originally Hindus, who converted to Islam several centuries ago. In the absence of proof of special usage to the contrary, Khojas in the Bombay State were governed in matters of succession and inheritance, not by the Mahomedan, but by the Hindu law. (Hirbai v. Gorbai (1875) 12 Bom. H.C. 294.) The Bombay High Court established this as the rule: the Khoja community's Hindu law of succession was their custom, and it displaced the Mahomedan law that would otherwise apply as the law of the defendant.
If any member of the community sought to apply a usage of succession different from the Hindu law, the burden lay upon him to prove that special usage. (Abdulrahim v. Halimabai (1915) 43 I.A. 35, 39.)
The practical result was striking: a community professing Islam governed in property matters by the law of a religion it had formally abandoned centuries earlier. This was not a product of any legislative intent — it was a consequence of the "usage of the country" operating in the second tier of the Bombay Regulation, displacing the Mahomedan law that would otherwise have come in through the third tier.
In matrimonial matters, the position was different. Cutchi Memon girls, for example, were governed by Mahomedan law in marital questions, and a Cutchi Memon girl was a free agent in matrimonial matters. (Abdul Razak v. Adam Usman (1935) 37 Bom. L.R. 603.) The customary Hindu law governed only succession and inheritance — not marriage.
Cutchi Memons: From Hindu Custom to Progressive Codification
The Cutchi Memons present the most legislatively elaborated example of the gradual movement from custom to personal law. Like the Khojas, they were originally Hindus who became converts about four hundred years ago and retained the Hindu law of inheritance and succession as a customary law. (Hirbai v. Gorbai (1875) 12 Bom. H.C. 294.) The custom was so well established that if any member set up a usage of succession opposed to the Hindu law of succession, the burden lay on him to prove it. (Abdulrahim v. Halimabai (1915) 43 I.A. 35, 39.) Where Cutchi Memons migrated from India and settled among Mahomedans — as in Mombasa — the courts readily assumed they had adopted the Mahomedan custom of succession in their new environment.
Cutchi Memons Acts: A Parallel Legislative Journey
The Cutchi Memon community's transition to Mahomedan personal law was achieved
through a series of legislative steps entirely separate from the Shariat Act. The Cutchi Memons Act XLVI of 1920 (as amended in 1923) allowed any Cutchi Memon to make a statutory declaration to be governed by the Mahomedan law in matters of succession and inheritance. On such declaration, the declarant, together with all his minor children and descendants, would thenceforth be governed by the Mahomedan law. The Act was "persuasive" rather than "coercive" — it offered an option, not a command.
The Shariat Act, 1937 then applied the Mahomedan law to Cutchi Memons in respect of intestate succession, but left testamentary power (the power to dispose of more than one-third of one's property by will) unaltered for those who had not made the statutory declaration. Finally, the Cutchi Memons Act X of 1938, which came into force on 1st November 1938, applied the Mahomedan law to all Cutchi Memons in matters of both testate and intestate succession — making their position identical to that of all other Mahomedans. Under this three-stage progression — 1920, 1937, 1938 — the Cutchi Memon community moved from comprehensive customary Hindu law to comprehensive Mahomedan personal law.
One subtlety remains: the Cutchi Memons Act 1920, in repealing the customary law, may not have been within the competence of the Indian Legislature so far as it affected succession to agricultural land in the Governors' Provinces. The Federal Court of India had held (in In re Hindu Women's Right to Property Act (1941) F.C.R. 12) that Central legislation affecting agricultural land in the Provinces was beyond the Centre's competence. The repeal of the 1920 Act's successor provision by the Cutchi Memons (Amendment) Act XXV of 1942 did not resolve this, with the result that for agricultural land, the 1920 Act may still have remained in force for some purposes.
Halai Memons: Geography as Determinant of Law
The Halai Memons illustrate how geography, rather than community identity alone, governed the applicable law under the Bombay Regulation's flexible framework. Halai Memons domiciled in Bombay were governed in all respects by the Mahomedan law — the city of Bombay's close integration with the broader Muslim commercial world had effectively displaced any residual Hindu customary law. (Khojas and Memons' Case (1847) Perry's O.C. 110, 115.)
Halai Memons of Porbandar in Kathiawar, however, followed Hindu law and not Mahomedan law in matters of succession and inheritance — a position established by evidence of local custom among them. The same community name, the same religion, but different laws — depending entirely on where the family had settled and what usage had taken root.
Sunni Bohras of Gujarat and Molesalam Girasias of Broach
Sunni Bohra Mahomedans of Gujarat and the Molesalam Girasias of Broach were originally Hindus who converted to Mohammedanism and are governed by custom in certain matters. (Bai Baiji v. Bai Santok (1894) 20 Bom. 53; Fatesangji v. Harisangji (1894) 20 Bom. 181.) They were governed by the Shariat Act, 1937 in the same way as the Khojas — the Act abolished their customary succession law except as to agricultural land. However, in matters where no declaration had been made under Section 3 of the Shariat Act (covering wills, legacies and adoption), they retained their customary position.
Dawoodi and Sulaimani Bohras
At the opposite end of the spectrum, the Dawoodi and Sulaimani Bohras — Shia Ismaili communities — were governed by Mahomedan (Shia) law in all matters as a matter of historical record, without any customary Hindu law overlay. (Perry's O.C. 110, 115.) These communities never presented the personal-law-versus-custom tension that characterised the Khoja and Memon litigation.
Converts and the Rule of Conscious Adoption
A general principle operated across all these communities: rigid logical rules of personal law applied to individual conversions — a convert changes not only his religion but his personal law. (Mittar Sen Singh v. Maqbul Hasan Khan (1930) 57 I.A. 313.) But in the case of community conversions, the converts may retain a portion of their personal law according to their social habits and surroundings.
They retain their personal law unless they consciously adopt another. (Fidahusein v. Monghibai (1936) 38 Bom. L.R. 397, 400.) The Bombay Regulation's framework, by placing usage of the country before law of the defendant, gave juridical space for exactly this kind of retention — and the Khoja, Memon and Sunni Bohra litigation filled that space for a century.
Sind: The Regulation's Extended Reach
Bombay Regulation IV of 1827 did not confine its operation to the Bombay mufassal proper. Before the Government of India Act, 1935 created Sind as a separate province, Sind was part of the Bombay Presidency and the Regulation applied to it. The Orders in Council of 3rd March 1936 (numbered 1936 No. 164 and No. 165) did not affect any change as regards Mahomedan law on Sind's separation. Sind then became subject to the Shariat Act, 1937 after its enactment — following the same trajectory as the Bombay mufassal, but as a distinct province.
The Shariat Act, 1937: Section 26's Sub Modo Repeal
Section 6 of the Muslim Personal Law (Shariat) Application Act, 1937 expressly named Section 26 of the Bombay Regulation IV of 1827 among the provisions repealed insofar as they are inconsistent with the provisions of this Act. This partial, conditional repeal had a specific target: the "usage of the country" tier of the Regulation, which had permitted custom to displace the Mahomedan law in the second tier of the hierarchy.
After 7th October 1937, Section 2 of the Shariat Act directed that in cases where the parties are Muslims, the Muslim Personal Law shall govern — "notwithstanding any custom or usage to the contrary" — across all the enumerated subject-matters: intestate succession, special property of females, marriage, dissolution of marriage, maintenance, dower, guardianship, gifts, trusts and wakfs. The usage-of-the-country route was thereby blocked, specifically in relation to those subjects.
After the Shariat Act, evidence of usage of the country is inadmissible to prove a custom contrary to the Mahomedan law, unless it is in respect of agricultural land or other matter outside the Act. The personal law — which had previously entered the Bombay mufassal only through the third tier — now entered through the overriding mandate of the Shariat Act itself, as a directly applicable rule of law.
The Dramatic Impact on the Khoja and Memon Communities
The Shariat Act's impact on the Bombay Presidency was more dramatic than anywhere else in India — because the communities with the most entrenched non-Mahomedan customs were concentrated there. The Khojas, Cutchi Memons, Halai Memons, Sunni Bohras of Gujarat and Molesalam Girasias of Broach were all affected.
Their Hindu law of succession — maintained as "usage of the country" for centuries — was abolished in respect of non-agricultural property and, for some of these communities, for agricultural land as well (through the Cutchi Memons Act 1938, subject to the competence questions noted above).
The Shariat Act's own language in the intestate succession context was emphatic: in Western India, the Act was designed to abolish the customary law of succession according to Hindu law for Khojas, Cutchi Memons, Halai Memons, Sunni Bohras and Molesalam Girasias. That enumeration was not coincidental — it tracked precisely the communities whose custom had been established and recognised by Bombay courts operating under the Regulation for a century.
Agricultural Land: The Surviving Pocket
The Shariat Act's agricultural land exception preserved the pre-1937 position — including the "usage of the country" route under the Bombay Regulation — for questions of succession to agricultural land. In those residual questions, the four-tier hierarchy of Section 26 continued to operate: if a usage of the country covering agricultural succession was established, it could still displace the Mahomedan personal law. The burden of proof remained on the party asserting the usage, and the usage had to be shown to have the force of law — ancient, consistent, and recognised by the community.
Current Position for Practitioners
For advocates and courts in Maharashtra and Gujarat (the successor States of the former Bombay Presidency) dealing with Muslim personal law today, the framework rests on Section 26 of the Bombay Regulation IV of 1827 as the underlying statutory authority — read subject to the Shariat Act, 1937.
Several practical propositions emerge. First, in relation to the subject-matters specified in Section 2 of the Shariat Act, the Muslim Personal Law governs as a directly applicable rule — the "usage of the country" and "law of the defendant" tiers of the Regulation are effectively superseded for those subjects.
Second, questions of succession to agricultural land continue to be governed by Section 26's hierarchy, and usage evidence remains admissible for such questions. Third, the Mahomedan law of gifts, which was applied in the Bombay mufassal as the law of the defendant and was saved by Section 129 of the Transfer of Property Act, is now an expressly directed rule under Section 2 of the Shariat Act — no longer dependent on the defendant-law route.
Fourth, testamentary power — specifically whether a Muslim can freely dispose of more than one-third of his estate — remains governed by the Mahomedan personal law, subject to the community-specific provisions of the Cutchi Memons Act, 1938 and the Shariat Act. Fifth, for the Khoja community, testamentary construction (other than trusts and wakfs) continues under Hindu law — the Shariat Act did not affect the rules governing the construction of a Khoja will, only the rules governing its creation and revocation in so far as they relate to the one-third limit and wakf provisions. (Ashraf Alli v. Mahomed Alli (1946) 48 Bom. L.R. 642.)
Conclusion
Bombay Regulation IV of 1827, Section 26 is, in the taxonomy of provincial personal-law statutes, the provision that operated least directly. The Bengal, Agra and Assam Civil Courts Act said "apply the Mahomedan law"; the Madras Civil Courts Act said "apply the Mahomedan law or custom"; the Punjab Laws Act said "apply custom first, then the Mahomedan law." Section 26 of the Bombay Regulation said none of these things — it simply directed courts to apply the law of the defendant, and the Mahomedan law reached Mahomedan litigants by that oblique but effective route.
The consequence of that indirection was a legal system better adapted than any of the other provincial frameworks to the plurality of Muslim community practice in Western India. The Khojas, Cutchi Memons, Halai Memons and their fellow communities — communities that had retained Hindu succession law as usage of the country for centuries — could be accommodated within Section 26 without legislative contortion. The same section applied Mahomedan law to a Mahomedan defendant in a straightforward succession dispute, applied Hindu succession custom to a Khoja defendant in a succession dispute, and applied a usage of religious ceremony to a dispute about access to a Muslim graveyard — all by the same four-tier framework.
That flexibility was also the framework's limitation. A rule reaching the court only as "the law of the defendant" does not carry the authority of an expressly directed legislative mandate. The Shariat Act of 1937 replaced that indirect authority with a direct one — overriding usage of the country in the Shariat Act's subject-matters, converting the Muslim Personal Law from a rule reached through the third tier of a general hierarchy into a rule commanded by the Legislature in terms that left no room for customary displacement.
The transition was nowhere more consequential than in the Bombay Presidency, where the accumulated weight of a century of Hindu-law custom among Muslim communities — validated by the Bombay Regulation's usage tier — was dismantled in a single legislative act.
Frequently Asked Questions
Q: Did Bombay Regulation IV of 1827, Section 26 expressly apply Mahomedan law to Mahomedans?
No. Section 26 does not mention Mahomedan law, or any community, by name. It sets out a general four-tier hierarchy — Acts of Parliament and Regulations, usage of the country, law of the defendant, justice and conscience. The Mahomedan law reached Mahomedan litigants in the Bombay mufassal only through the third tier: as the "law of the defendant" in suits where the defendant was Mahomedan. This makes the Bombay Regulation uniquely indirect among all the provincial personal-law statutes.
Q: Why did "usage of the country" appear before "law of the defendant" if there was no presumption in favour of custom?
Despite being placed second in the statutory hierarchy — above the defendant's personal law — usage of the country carried no presumption in its favour in actual litigation. It had to be proved affirmatively by the party asserting it. The courts treated personal law as the operative default: once a Mahomedan defendant appeared, his personal law was the applicable rule, unless the opposing party established a usage that displaced it. The statutory priority of usage was thus qualified significantly by the courts' allocation of the burden of proof.
Q: How were the Khojas and Cutchi Memons governed before the Shariat Act, 1937?
In the absence of proof of special usage to the contrary, both Khojas and Cutchi Memons were governed in matters of succession and inheritance by the Hindu law, maintained as a customary law from the time of their pre-Islamic ancestors. In matrimonial matters, Mahomedan law applied to both communities. After the Shariat Act of 1937 — and, for the Cutchi Memons, through their own separate statutory progression culminating in the Cutchi Memons Act, 1938 — both communities became subject to the Mahomedan law in matters of succession and inheritance (except, arguably, for agricultural land).
Q: How did the Shariat Act, 1937 affect Section 26 of the Bombay Regulation?
Section 6 of the Shariat Act expressly repealed Section 26 of the Bombay Regulation insofar as it was inconsistent with the Shariat Act — a sub modo repeal. The inconsistency lay in the "usage of the country" tier: Section 26 had permitted usage to override the defendant's personal law, whereas Section 2 of the Shariat Act directed that the Muslim Personal Law governed "notwithstanding any custom or usage to the contrary." After 7th October 1937, usage evidence became inadmissible to prove a custom contrary to the Mahomedan law in the Shariat Act's subject-areas, except in relation to agricultural land.
Q: What is the significance of Section 129 of the Transfer of Property Act for Mahomedan gifts in the Bombay mufassal?
Section 129 of the Transfer of Property Act, 1882 saves any rule of Mahomedan law from the registration and formal requirements of the Transfer of Property Act's Chapter VII (which governs gifts). In the Bombay mufassal, Mahomedan gift law was applied as the law of the defendant — a basis more securely within "any rule of Mahomedan law" than the conscience-standard basis used in other territories. Section 129 therefore operated to save Mahomedan gift law in the Bombay mufassal, meaning an oral gift by a Mahomedan to his wife in lieu of dower was valid without registration. The Shariat Act, 1937 subsequently made gifts an expressly directed subject of the Muslim Personal Law, removing the earlier uncertainty.
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