Customary Succession Among Oraons: Supreme Court Interprets Ghardamad Custom and Nephew's Inheritance

Case Snapshot

• Case Name: Bejla Oraon v. Kali Das Oraon & Ors.

• Citation: 2026 INSC 672

• Bench: Justice Sanjay Karol and Justice Nongmeikapam Kotiswar Singh

• Date of Judgment: July 9, 2026

• Area of Law: Civil Law, Tribal Customary Law, Succession, Evidence

Judgment in Brief

The Supreme Court allowed the appeal and set aside the concurrent findings of the Trial Court, First Appellate Court, and High Court, which had dismissed the plaintiff's suit claiming inheritance to ancestral property. The Court held that the defendants failed to prove the existence and applicability of the customary law under which a ghardamad (son-in-law) could inherit property from his father-in-law or uncle-in-law. The Court relied on authoritative sources on Oraon customary law, particularly the work of S.C. Roy, to hold that in the absence of a ghardamad or any other male heir directly related to the landowner, the nearest male agnate (nephew) inherits the property. The Court found that the defendants' witnesses were internally inconsistent and failed to establish the custom to the satisfaction of the Court's conscience.

Relevant Facts

• The dispute arose over the inheritance of ancestral property belonging to one Sukhu Oraon, who had three sons: Dhungru, Ledura, and Bhoula.

• The plaintiff (Bejla Oraon) was the grandson of Sukhu through his son Dhungru.

• The defendants claimed title through Budhain (daughter of Bhoula) and her husband Punai, who was allegedly taken as a ghardamad (son-in-law) by Ledura (the plaintiff's uncle).

• The parties are Oraons, a tribal community governed by customary law.

• The Trial Court and

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