The case centred on whether the deceased, Sardar Dyal Singh, was considered a Hindu under the relevant Act. This determination was crucial for inheritance rights.

Rani Bhagwan Kaur (Appellant) In her argument, she maintained that Sardar Dyal Singh, originally of Sikh faith, did not qualify as Hindu under the Act. Additionally, she asserted that even if classified as Hindu, his conversion to the Brahmo Samaj, a reformist movement, nullified his status as such.

Observation:The Hon’ble Court observed that there shall not be any attempt here to lay down a general definition of what is meant by the term “Hindu”. To make it accurate and at the same time sufficiently comprehensive as well as distinctive is extremely difficult. The Hindu religion is marvellously catholic and elastic. It is easier to say who are not Hindus, and practically the separation of Hindus from non-Hindus is not a matter of so much difficulty. The people know the differences well and can easily tell who Hindus are and who are not.

The court ruled in favour of JC Bose, deciding that:

• • Sikhs were included within the definition of “Hindu” for legal purposes
• • Following a reformist movement like Brahmo Samaj didn’t disqualify someone from being a Hindu.