Author: Manish, student of St Joseph College Of Law, Bangalore
Abstract
This paper studies different types of abandoned property in India and how the law deals with them. Abandoned property in India falls into three main categories evacuee property, enemy property, and escheat or bona vacantia. Evacuee property is property that was left behind by people who moved to Pakistan after Partition in 1947. Enemy property is property that belonged to nationals of Pakistan and China, which was taken over by the State after the wars of 1962 and 1965. Escheat refers to property left behind by a person who dies without any legal heir and without a will, which then passes to the State under Article 296 of the Constitution. This paper looks at the laws that govern each of these three categories, mainly the Administration of Evacuee Property Act, 1950, the Enemy Property Act, 1968, and Article 296 of the Constitution. It also looks at important court cases such as Azimunnissa v. Deputy Custodian, Union of India v. Raja Mohammad Amir Mohammad Khan, State of Rajasthan v. Lord Northbrook, and Pierce Leslie & Co. Ltd. v. Violet Ouchterlony Wapshare, and what these cases tell us about how the law has developed over time. The paper also studies whether a person who has been living on such property for a long time can claim ownership through adverse possession under the Limitation Act, 1963. The paper finds that while the State has strong powers over all three categories, the law is fragmented and a single comprehensive law is needed.
Keywords: Abandoned Property, Enemy Property, Evacuee Property, Escheat, Bona Vacantia, Adverse Possession, limitation Act, Article 296
1. introduction
abandoned property simple means the property which has been left behind where there is no owner for the property, and where the owner is untraceable. This became a serious issue after the partition in 1947. During the partition large number of people moved out of the country leaving behind their property such as land, and other assets. Due to which the government stepped in and look after such property, which later was called as evacuee property. There was also a another similar but a different problem where the war with Pakistan and china in 1965 and 1962, the persons of those countries where considered enemy of the country, hence the property which belonged to them were termed as “enemy property” where such property was taken over by the state. Another instance where the property left behind by person who do not have any legal heris or dies without any will, there is a doctrine which states that “no property is left without ownership” this is known as escheat property, also known as bona Vaccinate. These different kinds of abandoned property may look similar in nature because, end of the day, the state takes control of such property, such property which once belonged to an individual. There are different laws established for each kind of property depending on the nature of the property. This paper studies the historical background of each category, the legal framework that governs it, and the major judicial decisions that have shaped the law. It also studies a question that often comes up in practice: can a person who has been living on such property for many years claim ownership through adverse possession? The paper tries to answer this question separately for evacuee property, enemy property and escheated property, since the answer is not the same for all three.
2. Historical background of abandoned property.
2.1 Abandoned Property During Partition
Millions of people crossed the new bordered, in august 1947, India was partitioned, here many people left behind their land, houses, shops and many more, due to having no time to sell or to transfer such property. The properties stayed where they were without anyone there to manage it.
The government came with an idea to create a system to protect such property from encroachment and misuse. Such property was termed as evacuee property.
2.2 Development of Evacuee Property Laws
Post partition, the property which belonged to the people who migrated from India to Pakistan, mass number of property were left behind this created a serious administrative issue and legal challenges for the newly independent state. To administrate the issue, the government established a law pertaining to such property. The law enacted is known as the “Administration of Evacuee Property Act, 1950” which gives powers to the Custodian of Evacuee Property to take possession of, manage, and protect properties left behind by persons who had migrated to Pakistan. Over time, these laws evolved to facilitate the rehabilitation of displaced persons through the redistribution of evacuee properties.
2.3 Emergence of Enemy Property Legislation
Another issue which arose after the war between Pakistan and china. People who took the nationality of china and Pakistan or who were treated as enemy of the state had property in India. This property had first been dealt with under the Defence of India Rules. Parliament then passed the Enemy Property Act, 1968 which created the office of the Custodian of Enemy Property for India and provided that such property would continue to vest in the Custodian. After the enactment of the Act, there were many questions, such as. What would happen if the owner of the property dies, what would happen if there is no owner, what if the owner was an enemy, but his legal heirs were Indians, or any other country citizen who is not an enemy. A famous case law UOI v Raja Mohammed Amir Mohammad Khan. Stated that the office of the Custodian can have temporary possession of the property only until it belonged to an enemy. And once it devotes upon an Indian citizen then the enemy property must be returned. Hence, India today manages thousands of enemy properties across the country, most of which are linked to persons who moved to Pakistan after Partition or after the 1965 war and the India china war, in 1962.
2.4 Doctrine of Escheat and Bona Vacantia
Doctrine of escheat also known as “escheat” in French, is an doctrine which was established in the English feudal law, where the land without an owner would revert back to the crown, lets say a person dies without any heirs, without any will. Such property will not have an owner. Then when the person is no more in existence, all his property will be transferred to the crown.However, it is interesting to note that the doctrine of escheat was not unknown to India. The Ancient lawgiver Manu has written in Manusawhita(Chapter IX, Verse 189): the verse states that, the king has all the rights to the property if the person leaves behind the property without any heirs, but this is not applicable to Brahminical property. Property which belonged to the Brahmins. During the era of British rule the doctrine of escheat was established by the privy council in the early 1860, the council declared that the doctrine is a part of the India law. The doctrine was established In this case law, “The Collector of Masulipatam v. Cataly Vencata Narrainapah” here a property located in Masulipatam which had no legal heirs, the question in this case was whether the property without heirs could remain ownerless. The privy Council held that, the state is the ultimate owner of the property which has no heirs. Hence the law states that, the state will only interfere when there is a genuine and complete failure of heirs.
2.5 Constitutional Recognition of State Claims Over Ownerless Property
The constitution of India, gives constitutional backing with the help of Article 296. This Article states that property in India which would otherwise pass to the State by escheat, lapse or as bona vacant for want of a rightful owner, shall vest in the Union if the property is situated in a Union Territory, and in the State concerned if it is situated within a State, subject to any trust that may already affect such property. Several States, including Rajasthan, Telangana, Odisa, Goa, and Andhra Pradesh have also passed their own escheat laws.
3. Legal Framework Governing Abandoned Property
3.1 Adminstration of Evacuee Property Act, 1950
Evacuee Property Act, 1950 was established with one main purpose, to manage properties left behind by people who migrated to Pakistan after Partition. This act also gives powers to the Custodian to take possession, manage, and administer such properties which are declared as evacuee property. These powers were intended to address the large number of properties left behind by persons who migrated to Pakistan following Partition. This act also laid down a procedure for declaring Evacuee property, under section 7 (1) The Custodian may declare property as evacuee property after issuing notice to interested persons and holding an inquiry. Once a notice is issued, the property cannot be transferred or charged without the Custodian’s leave until a final decision is made. The Custodian must publish all declared evacuee properties in the Official Gazette or through other prescribed means. This Act also ensures that no one uses the law in any unlawful manner, this Act ensures that If the Custodian wrongly declares your property as evacuee property under certain specific grounds, you have the right to challenge that decision by appealing to a specially nominated District Judge. The government appoints these judges and defines their areas of jurisdiction.
3.2 Enemy Property Act
Enemy Property Act 1968, is an Act which was established to manage properties of enemy nationals. To provide for the continued vesting and administration of enemy property in India. This Act appoints a Custodian who is responsible for the management, this Act also defines the term Enemy property. The custodian has powers such as to manage, lease, sell, recover rents, initiate legal proceedings, to investigate and remove unauthorised occupants from enemy property. This Act also sets a restriction on transfers, it states that the owner of the Enemy property cannot sell, gift it, mortgage it or lease it, even if they end up doing so, such transfer will be void. Since the Enemy property cannot be sold by the Owner, it can be sold by the Custodian, only if the permission is granted by the central Government. This Act also ensures that no person’s property is wrongfully taken away, then he has the right to approach the court. Section 18 (c) gives the power to appeal court decisions.
3.3 Article 296 of the Constitution of India
Article 296 of the Indian Constitution talks about the doctrine of Escheat, Bona Vacantia. The Doctrine of Escheat is a common law principle under which property returns back to the State when a person dies without leaving any heirs and without a valid will. Bona Vacantia deals with property which has no lawful owner. In such circumstances, since there is no successor to inherit the property, ownership passes to the State as the ultimate owner. In India, the doctrine is constitutionally recognised under Article 296 of the Constitution of India, which provides that property that would otherwise pass to the State by escheat, lapse, or bona vacant shall vest in the Union or the State Government, depending on where the property is situated. This Article was placed in the constitution to ensure that no property is ownerless. This also helped in dividing the authority of the property, by specifying if it belongs to a state or union territory. This article gives power to take ownership of the property when there is no legal heir and when no person has a lawful claim. This also gives powers to manage, take possession, lease it , sell it and utilise it for the welfare of public. For the state to claim such property the state must conduct an inquiry, the absence of lawful heirs must be established, and legitimate claimants must be given an opportunity to prove their rights.
3.4 Transfer of Property Act and Related Statutes
Administration of Evacuee Property Act, 1950 , Enemy property Act, and Article 296. Despite having their own legal framworks the foundation of transferring such property remains the same. Transfer of property Act deals with all forms of transfers of immovable property regardless of them being enemy, evacuee or escheat or Bona vacanatia. In simple words the Transfer of Property Act, 1882 contains the normal rules for transferring property through: sale, mortgage, lease, gift, exchange etc When evacuee property, enemy property, or escheated property comes under government control, special laws govern that stage. However, if the government later sells or transfers that property, the actual transfer is generally governed by the ordinary rules of the Transfer of Property Act.
3.5 Limitation Act
The Limitation Act, 1963 plays an important role in governing court proceedings in relation to immovable property. This act precribes a time limit which allows the true owner to initiate legal proceedings to recover possession of his abandoned property within the set time frame. Under the Schedule to the Act, suits for possession of immovable property based on title must generally be filed within twelve years, while suits by or on behalf of the Government are governed by a thirty-year limitation period. A key provision is Section 27 of the Act, which provides that upon expiry of the prescribed limitation period, the right to recover property is extinguished. This principle is significant in relation to abandoned and unclaimed properties, as it forms the legal foundation for the doctrine of adverse possession.
3.6 Adverse possession
Adverse possession is a legal doctrine. This doctrine orginated from the Ancient Babylon in Mesopotamia, known as the code of Hammurabi, under this code law 30 mentions that “if a chieftain or a man leaves his, house, garden and field and someone else takes possession of his house, garden and field and uses it for three years; if the first owner returns and claims his house, garden, and field, it shall not be given to him, but he who has taken possession of it and used it shall continue to use it”. It was further developed in the Roman era where the doctrine developed through the concepts of usucapio and emphasised, which allowed ownership to be acquired through long and continuous possession. Roman law emphasised bona fides (good faith) and iusta cause (just cause), requiring the possessor to have a legitimate basis for possession. The Romans viewed prolonged inaction by the true owner as a form of constructive abandonment, enabling the possessor to acquire ownership of what was treated as res nulls (ownerless property). In India limitation Act was introduced in 1859 by the British. Today the current limitation Act was enacted in 1963 by the parliament. The scope of this act was the ensure there was certainty of ownership, productive use of land, and to encourage vigilance. So when a person leaves his property behind and another person enters such property and openly claims possession without the owners permission. And the owner takes no legal action, then such possession will be valid under the eyes of law. For the possession to be valid there are conditions which have to be met. In the case of Ravinder Kaur Grewal vs Manjit Kaur, where the plaintiff and his predecessors had been in possession of such land for generations and generations despite not being the orginal owners of the property. The issue in this case was whether such possession was valid, and if he can protect his adverse possession title. So the supreme court held that a person who has acquired title through adverse possession cannot only use it as a defence but can also file a suit to protect or enforce that title. The Court clarified that once the statutory period of 12 years is completed and all requirements of adverse possession are satisfied, the original owner’s rights are extinguished under Section 27 of the Limitation Act, 1963, and ownership may vest in the adverse possessor.
4. Judicial development
4.1 Judicial Approach Towards Evacuee Property
Azimunissa And Others vs The Deputy Custodian, Evacuee … on 26 October, 1960. Khatoon Bibi, one of the co-sharers, went to Karachi in 1947. She was declared an evacuee, hence her property was vested in the Custodian under the Administration of Evacuee Property Act, 1950. Other family members (including Bashir Ahmad and Nasir Ahmad) were also declared evacuees, making the property a composite property (shared between evacuees and non-evacuees). Since non evacuee co sharers were unwilling to buy out the evacuee shares, the Competent Officer ordered the property to be sold at public auction. It was sold in 1956 for ₹16,05,000. Here the issue Was if the property correctly classified as composite property? Were earlier vestings under ordinances valid? Did Section 10 of the Evacuee Interest (Separation) Act, 1951 violate Articles 19(1)(f) and 31 of the Constitution (right to property)? The Supreme Court held that even if earlier ordinances were defective, the 1960 Amendment retroactively validated them. The property was rightly treated as composite, since evacuee and non-evacuee interests coexisted. Section 10 was constitutional, sale was the only practical way to separate interests in an indivisible property like a sugar mill. Hence the decision in Azimunnissa v Deputy Custodian, Evacuee Property is significant because it affirmed the validity of the statutory framework governing evacuee property. The Supreme Court recognised that where evacuee and non-evacuee interests coexisted in the same property, such property could be treated as composite property under the Evacuee Interest (Separation) Act, 1951. The Court further upheld the power of the State to manage, separate and dispose of evacuee interests where necessary. By validating earlier vesting provisions and recognising the authority of the Custodian, the judgment strengthened the legal framework created to administer property left behind by persons who migrated to Pakistan after Partition. This decision therefore played an important role in the development of evacuee property law in India.
4.2 Judicial Interpretation of Enemy Property
The most important early case on enemy property is Union of India v. Raja Mohammad Amir Mohammad Khan, decided by the Supreme Court in 2005. In that case, the Court held that property vested with the Custodian as enemy property should be handed over to the son of the original owner, since the son was an Indian citizen who had never left India and could not himself be treated as an enemy. This judgment created a gap, because it allowed Indian-citizen heirs of enemy subjects to claim back enemy property. Parliament responded by passing the Enemy Property (Amendment and Validation) Act, 2017, which expressly provides that enemy property continues to vest in the Custodian even where the legal heirs are Indian citizens, and that this rule applies retrospectively. Courts examining cases after 2017 have largely upheld this amendment and the bar on civil court jurisdiction that came with it.
4.3 Judicial development of Doctrine of Escheat
Indian courts have over time explained when and how the State can take over property under the doctrine of escheat. The most important case on this is State of Rajasthan v. Lord Northbrook. In this case, Raja Sardar Singh died in 1987 without any children. The State of Rajasthan tried to take over his property, claiming that there was no heir left to inherit it. The Supreme Court held that the State had acted wrongly because it had not conducted a proper enquiry into whether any heir existed before trying to take over the property. The Court made it clear that the State can only take property under escheat when it has strong proof that there is no heir and no Will left behind by the deceased. The case was finally concluded in 2025, when the Supreme Court held that since Raja Sardar Singh had in fact left behind a valid Will, the State had no right to take over the property at all. This case establishes that escheat is a last resort the State cannot simply take over property without first doing a thorough and proper enquiry.
4.4 Judicial Treatment of Bona Vacantia
The Supreme Court explained the concept of bona vacantia in Pierce Leslie & Co. Ltd. v. Violet Ouchterlony Wapshare. In this case, a company had been dissolved and the question arose as to who would own the property that was left behind after the company ceased to exist. The Court held that when there is no rightful owner left to claim property, the Government has the right to take it over, either by escheat or as bona vacantia. The Court made it clear that this right of the Government has been recognised in India for a long time and is an incident of sovereignty meaning it flows directly from the fact that the State is the ultimate owner of all property within its territory when no private owner exists. The constitutional basis for this is Article 296, which provides that in the absence of a rightful owner, the sovereign, which is now the State or Union, becomes the owner. This case therefore confirms that bona vacantia is not a punishment it is simply the law ensuring that no property in India is ever left permanently without an owner.
4.5 Rights of Heirs and Successors in Abandoned Property
Across all three categories, the courts have shown concern for protecting genuine claimants. The Evacuee Property Act allows restoration of wrongly declared property to its true owner. In the enemy property context, the dispute in the Raja Mohammad Amir Mohammad Khan case was essentially about whether an Indian citizen heir could inherit, and Parliament has since clarified that he or she cannot, once the property has validly vested as enemy property. In escheat cases, the existence of even one valid heir, or a valid Will naming a beneficiary, is enough to defeat the State’s claim altogether, as the Lord Northbrook litigation finally confirmed.
4.6 Adverse Possession Claims Over Abandoned Property
The Limitation Act, 1963 sets a time limit within which a person must go to court to claim his rights over property. The time limits are not written in the main body of the Act but are placed in a Schedule at the end of it. This Schedule is a table listing different types of suits and the time allowed for each. Each item in this table is called an Article. Under Article 65 of the Schedule, a person must file a suit to recover possession of immovable property within twelve years from the date the other person’s possession becomes adverse to him. Under Article 112, the Government gets a longer period of thirty years to file such a suit. Once either of these periods expires without any action being taken, Section 27 of the Act extinguishes the true owner’s right to the property entirely not just his right to sue, but his ownership itself. This is the legal basis of adverse possession in India.
This framework is important in the context of abandoned property because evacuee property, enemy property and escheated property are all types of property that have been left without an active private owner for long periods, raising the question of whether a person in long possession of such property can claim ownership through adverse possession.
5. Analysis of Major Legal Issues
5.1 Determination of Ownership
Deciding who actually owns a piece of abandoned property is often the hardest part of these cases. Partition-era records are old, incomplete, or were prepared in a hurry, and many original owners or their families are now spread across different countries. This makes it difficult for the Custodian, or for the courts, to be fully confident that a property is genuinely without an owner before taking it over.
5.2 Conflict Between State Claims and Private Rights
There is a constant tension between the State’s interest in securing and using abandoned property, and the constitutional right to property recognised under Article 300A of the Constitution. The wide powers given to Custodians, and the bar on civil court jurisdiction found in both the Evacuee Property Act and the Enemy Property Act, mean that private claimants often have very limited remedies if they believe their property has been wrongly taken.
5.3 Challenges in Identifying Legal Successors
In escheat cases especially, courts have repeatedly stressed that the State must prove a complete failure of heirs anywhere in the world before it can claim the property. This is an extremely difficult burden to discharge in practice, since it requires tracing family relationships that may stretch across several countries and several generations.
5.4 Constitutional Concerns and Property Rights
The 2017 amendment to the Enemy Property Act, which applies retrospectively and removes the right of Indian-citizen heirs to inherit enemy property, has been criticised by some commentators as harsh on families who believed they held valid title. This raises a genuine constitutional question about how far retrospective legislation can go in cutting off property rights that were earlier recognised by a court.
5.5 Practical Difficulties in Administration
With several thousand enemy properties and a very large number of evacuee and escheat cases spread across India, the practical task of managing, valuing and disposing of such property is enormous. Encroachment, outdated records, and slow-moving litigation all add to the difficulty, and many properties remain in an unresolved legal limbo for decades, as the Lord Northbrook dispute, which lasted almost forty years, clearly illustrates.
6. Findings and Discussion
This study shows that even though evacuee property, enemy property and escheated property are often grouped together as “abandoned property,” they are actually quite different in law. Evacuee property came from people who left for Pakistan after Partition and is managed under the Administration of Evacuee Property Act, 1950. Enemy property came from people who took the nationality of Pakistan or China after the wars, and is managed under the Enemy Property Act, 1968. Escheated property and bona vacantia arise when a person dies without any heirs or a will, and is covered by Article 296 of the Constitution. In all three cases, the State gets very strong powers once the property is taken over. The Custodian can manage, lease or sell the property, and civil courts are mostly kept out. However, the courts have insisted that proper notice, inquiry and a chance to be heard must be given before any property is declared abandoned. Cases like Azimunnissa, Raja Mohammad Amir Mohammad Khan, Lord Northbrook and Pierce Leslie show this balance. The study also finds that adverse possession does not work the same way for all three. For evacuee and enemy property, once the property is with the Custodian, a private person cannot claim ownership by long possession. For escheated property, a person may still claim adverse possession against the original owner before the State formally takes over. The main point is that these three types of property should not be treated as one. Each has its own history and its own purpose. The law leans heavily in favour of the State, but the courts try to protect honest claimants through fair procedure. The 2017 amendment to the Enemy Property Act is strict because it takes away rights even from Indian heirs, and this may be questioned under Article 300A in future. A clearer law on adverse possession against abandoned property, and stronger procedural safeguards, would make this area of law more fair and certain.
7. Suggestions
7.1 Enactment of a Comprehensive Abandoned Property Law
India would benefit from a single, modern law that sets out common definitions and common procedures for evacuee property, enemy property and escheat, while still allowing for the specific features of each category.
7.2 Uniform Guidelines for State Authorities
Custodians and Collectors handling different categories of abandoned property across different States should follow uniform guidelines, so that similar cases are not decided differently simply because they arise in different States.
7.3 Strengthening Record Management Systems
Digitising and centralising old Partition-era and escheat related land records would make it far easier to verify ownership claims quickly and to reduce the scope for fraudulent claims on either side.
7.4 Clarification of Adverse Possession Principles
The law should clearly state whether, and to what extent, adverse possession can run against property that has validly vested in a Custodian or in the State as escheated property, instead of leaving this to be worked out case by case through litigation.
7.5 Improved Mechanisms for Tracing Legal Heirs
Given how heavily the burden of proving a failure of heirs falls on the State in escheat cases, the government should set up dedicated mechanisms, including cooperation with foreign missions, to trace possible heirs before initiating escheat proceedings.
7.6 Judicial Guidelines for Future Disputes
Higher courts could usefully lay down a clear, step-by-step framework for lower courts and tribunals to follow in abandoned property disputes, covering the order in which ownership, heirship and adverse possession questions should be examined.
Conclusion
Abandoned property in India covers three separate legal categories evacuee property, enemy property, and escheat each with its own statute and its own body of case law. What they share is one common outcome: when private ownership fails, the State steps in. The legal framework in this area has developed largely through judicial intervention rather than comprehensive legislation. Courts through cases such as Union of India v. Raja Mohammad Amir Mohammad Khan, State of Rajasthan v. Lord Northbrook, and Pierce Leslie & Co. Ltd. v. Violet Ouchterlony Wapshare have consistently tried to balance the State’s interest in securing ownerless property against the rights of genuine private claimants. The question of adverse possession remains unsettled. While the Limitation Act provides a clear framework on paper, the statutory bars on civil court jurisdiction under the Evacuee Property Act and the Enemy Property Act make it difficult to apply in practice. The law as it stands is fragmented and, particularly after the 2017 Amendment to the Enemy Property Act, leans heavily in favour of the State at the cost of private rights. A single comprehensive law covering all categories of abandoned property, with clear procedural safeguards and a uniform approach to adverse possession, remains the most important reform this area of law needs.
References
Books
Buckland WW, A Text-Book of Roman Law from Augustus to Justinian (3rd edn, Cambridge University Press 1963).
Nicholas B, An Introduction to Roman Law (Oxford University Press 1962).
King LW (trans), The Code of Hammurabi (1910).
Buhler G (trans), The Laws of Manu (Oxford University Press, Sacred Books of the East vol 25, 1886).
Legislation
Administration of Evacuee Property Act 1950.
Enemy Property Act 1968.
Enemy Property (Amendment and Validation) Act 2017.
Limitation Act 1963.
Transfer of Property Act 1882.
Rajasthan Escheats Regulation Act 1956.
Constitution of India, art 296.
Constitution of India, art 300A.
Cases
Evacuee Property
Azimunnissa v Deputy Custodian, Evacuee Property AIR 1961 SC 365.
MB Namazi v Deputy Custodian of Evacuee Property AIR 1951 Mad
(Madras High Court, 16 February 1951) <https://indiankanoon.org/doc/771559/> accessed 20 April 2026.
Jaswant Singh v Custodian, Evacuee Property (Punjab and Haryana High Court, 16 July 1982) <https://indiankanoon.org/doc/215664/> accessed 20 April 2026.
Enemy Property
Union of India v Raja Mohammad Amir Mohammad Khan (2005) 8 SCC 696.
Escheat and Bona Vacantia
State of Rajasthan v Lord Northbrook Civil Appeal No 6677 of 2019 (Supreme Court of India, 28 August 2019).
Pierce Leslie & Co Ltd v Violet Ouchterlony Wapshare AIR 1969 SC 843.
Adverse Possession
Ravinder Kaur Grewal v Manjit Kaur (2019) 8 SCC 729.
PT Munichikkanna Reddy v Revamma (2007) 6 SCC 59.
Karnataka Board of Wakf v Government of India (2004) 10 SCC 779.
State of Haryana v Mukesh Kumar (2011) 10 SCC 404.
Angadi Chandranna v Shankar (Supreme Court of India, 22 April 2025) <https://indiankanoon.org/doc/100648729/> accessed 20 April 2026.
Journal Articles
‘Doctrine of Adverse Possession’ (2024) Pondicherry Law Law Review <https://pllr.iledu.in/wp-content/uploads/2024/01/V1I13.pdf> accessed 20 April 2026.
‘Adverse Possession in India’ (JAJ Jharkhand, June 2023) <https://jajharkhand.in/wp-content/uploads/2023/06/column-003_13062023.pdf> accessed 20 April 2026.
Online Sources
Malvika Bakshi, ‘Enemy Property in India: An Overview’ (Fox Mandal, 2024) <https://foxmandal.in/enemy-property-in-india-an-overview/> accessed 20 April 2026.
Shruti Desai, ‘Ownerless Property and State Claims: Bona Vacantia, Escheat, and Evacuee Property in India and Beyond’ (shrutidesai.in, 2024) <https://shrutidesai.in/ownerless-property-and-state-claims-bona-vacantia-escheat-and-evacuee-property-in-india-and-beyond/> accessed 20 April 2026.
Ahlawat Associates, ‘Adverse Possession Law in India’ (ahlawatassociates.com) <https://www.ahlawatassociates.com/adverse-possession> accessed 20 April 2026.
Daksh Pandit, ‘Law on Adverse Possession’ (dakshpandit.com) <https://dakshpandit.com/law-on-adverse-possession/> accessed 20 April 2026.
‘Doctrine of Escheat’ (iPleaders, 2021) <https://blog.ipleaders.in/all-you-need-to-know-about-the-doctrine-of-escheat/> accessed 20 April 2026.
‘Doctrine of Escheat’ (Shankar IAS Parliament) <https://www.shankariasparliament.com/current-affairs/doctrine-of-escheat> accessed 20 April 2026.
‘Article 296 of the Constitution of India’ (GK Today) <https://www.gktoday.in/article-296/> accessed 20 April 2026.
‘Manusmriti Chapter IX Verse 189’ (Wisdom Lib) <https://www.wisdomlib.org/hinduism/book/manusmriti-with-the-commentary-of-medhatithi/d/doc201569.html> accessed 20 April 2026.
‘Rajasthan Escheats Regulation Act 1956’ (LegitQuest) <https://www.legitquest.com/act/rajasthan-escheats-regulation-act-1956/3977> accessed 20 April 2026.
Enemy Property Act 1968 (India Code) <https://www.indiacode.nic.in/bitstream/123456789/1582/1/196834.pdf> accessed 20 April 2026.
Primary Historical Sources
Selected Works of Jawaharlal Nehru, Second Series, Vol 24 (Nehru Memorial Museum and Library 1984) 463–465.
