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Supreme Court of India 2019-09-13 allowed

JOSE PAULO COUTINHO vs MARIA LUIZA VALENTINA PEREIRA

Bench: 2 — Deepak Gupta, Aniruddha Bose

In Brief

A Goan domicile (JMP) purchased property in Bombay and bequeathed it to his youngest daughter through a Will that was probated. His other daughters sought to include this property in inventory proceedings under Goan law. The Supreme Court held that the Portuguese Civil Code, 1867—though of foreign origin—became Indian law after Goa's conquest and incorporation into India. The Court rejected arguments that private international law principles applied. It held that the Portuguese Civil Code, as a special and local law, governs succession of all property owned by Goan domiciles wherever situated in India, requiring all assets to be treated as one unit. The grant of probate does not determine inheritance rights, which remain governed by substantive succession law. The Court allowed the appeal and directed inclusion of the Bombay property in inventory proceedings.

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Succession Law Family Law Conflict of Laws Personal Law Property Law Constitutional Law Goan Law Portuguese Civil Code Probate and Administration Statutory Interpretation Domicile

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