Asked by a reader in Toronto

My father died abroad leaving property in India. Which country's law decides who inherits?

Answered by Advocate Sharan Jain··NRI Succession & Inheritance

Legal Shorts · 79 words

Start with the kind of property and the succession law that applies to your father. Section 5 of the Indian Succession Act separates Indian immovable property from movable property by reference to domicile. But section 4 excludes Hindu, Muslim, Buddhist, Sikh and Jain succession from that Part, so the rule cannot simply be applied to every NRI estate. Gather the title papers, family details, will and residence history. Dying abroad alone does not identify the law governing every asset.

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This is one of the few questions where the honest answer really is that it depends, and where saying so is not evasion. The governing law can depend on the nature and location of the asset, the deceased's domicile and the applicable succession regime. The Indian Succession Act contains a split between immovables and movables, but its own exclusions must be checked before that rule is used.

The split

For estates within Part II of the Indian Succession Act, 1925, section 5 states the rule in two sentences. Succession to the immovable property in India of a deceased person is regulated by the law of India, wherever such person may have had his domicile at the time of his death. Succession to the movable property of a deceased person is regulated by the law of the country in which he had his domicile at the time of his death. The Act adds that a person can have only one domicile for the purpose of succession to his movables.

Within that Part, Indian immovable property follows Indian law and movable succession follows the law of domicile. The asset's own statutory scheme and the exclusions below still need checking before deciding who receives it.

The Act's own domicile rules do not apply to everyone.
The Part of the Indian Succession Act that contains those domicile provisions says in terms that it does not apply if the deceased was a Hindu, Muhammadan, Buddhist, Sikh or Jaina. For those communities the personal law statutes govern instead, and the courts reach the immovable property answer by the same underlying principle rather than by that section. The result for Indian land is the same. The route matters when someone quotes the section at you, and it matters for movables, where the position is more contested than a confident answer would suggest.

Domicile is not residence, and not citizenship

This is where most families guess wrongly. The Act treats a new domicile as acquired by taking up a fixed habitation in a country which is not that of the domicile of origin, and its own illustrations show that intention does the work. A person who goes abroad on an engagement for a fixed number of years intending to return does not acquire a domicile there, however long the stay. A person who goes to wind up an affair and intends to return does not acquire one either, however long the residence lasts. The same person who later changes his mind and takes up his fixed habitation there does acquire one. The Act also says expressly that a person is not deemed to have taken up a fixed habitation in India merely by residing here in government service or in the exercise of a profession.

The consequence for your father is practical. Thirty years in Toronto, a Canadian passport, a house and a family there will usually point one way. A stated intention to retire to Bengaluru, a home kept here, and Indian bank accounts maintained throughout can point the other. Domicile is a finding a court makes on evidence, and it is worth assembling that evidence early, while the people who can speak to his intentions are still available.

If he left a will

The will governs, subject to the limits of the law that applies to each asset. The practical work is proving it here and then acting on it, and our guide on how an NRI will for Indian assets is made and used covers what makes that easy or hard.

If he did not

Then the Indian immovable property is distributed under the personal law that applied to him. For a Hindu that is the Hindu Succession Act, 1956, which applies by religion and not by citizenship or residence, so a Canadian passport does not take the estate out of it. Daughters and sons stand equally among the Class I heirs, and a daughter of a coparcener has been a coparcener in her own right by birth since the 2005 amendment. Our guide on the daughter's coparcenary rights after the 2005 amendment works that through.

What you will actually be asked for

Ask each Indian institution which claim documents it requires under the rules governing the asset. A court grant is not compulsory for every bank claim, and the documents accepted can depend on nomination, a will and any dispute. Our guide comparing a succession certificate, a legal heir certificate and probate sets out which instrument opens which door.

  1. List the assets by situs and by nature. Indian immovable, Indian movable, foreign immovable, foreign movable. The list is the analysis.
  2. Gather the domicile evidence now. Immigration history, tax residence, property, family, stated intentions, correspondence, the terms of any employment.
  3. Establish the personal law that applied to him, because for Indian assets it usually matters more than his address did.
  4. Take advice before anyone signs a family settlement. A settlement signed on a wrong assumption about the governing law is very hard to unwind.

Sources

The law this answer relies on, so you can read it yourself.

  1. 1.Indian Succession Act, 1925: sections 4-5, scope and domicile rules. Read the source
  2. 2.Hindu Succession Act, 1956: sections 2, 5 and 8. Read the source
  3. 3.Section 5, Indian Succession Act, 1925. Succession to immovable property in India is regulated by the law of India wherever the deceased was domiciled, and succession to movable property by the law of the country of his domicile at death. Read the source
  4. 4.Section 6, Indian Succession Act, 1925. A person can have only one domicile for the purpose of succession to his movable property. Read the source
  5. 5.Section 10, Indian Succession Act, 1925. Acquisition of a new domicile by taking up a fixed habitation in a country other than that of the domicile of origin, with the Explanation and the illustrations on intention. Read the source
  6. 6.Section 4, Indian Succession Act, 1925. Application of Part II, which does not apply if the deceased was a Hindu, Muhammadan, Buddhist, Sikh or Jaina. Read the source
  7. 7.Section 2, Hindu Succession Act, 1956. Application of the Act by religion, with no condition as to citizenship, residence or domicile. Read the source
  8. 8.Section 8, Hindu Succession Act, 1956. General rules of succession in the case of males, devolving first upon the Class I heirs in the Schedule. Read the source

The short answer's sources were checked on 12 September 2026. Statutes and judgments can change, so check the current position before you act on anything here.

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Go deeper on this

This answer is the short version. These guides cover the same ground in full, with the procedure, the timelines and the leading cases.

SJ

Answered by

Advocate Sharan Jain

Advocate based in Bangalore, practising before the Karnataka High Court and District, Sessions, Consumer and Family courts. Answers public legal questions to make Indian law more accessible.

This answer is general information on Indian law as at August 7, 2026, published for public education. It is not legal advice, it does not take account of your facts, and reading it does not create an advocate-client relationship. Law changes and every case turns on its own circumstances. Please consult a qualified advocate about your own matter.

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