Overview The Supreme Court observed that the procedural rules under the Act, 1937 have not been uniformly framed by all States and Union Territories (UTs). A bench headed by Justice Sanjay Karol and Justice Augustine George Masih directed a comprehensive status report. Key Developments The Court noted non‑implementation of Section 4 across the country. Standing counsel for all States/UTs must gather factual data on rule‑making and submit it to Additional Solicitor General Archana Pathak Dave . The compiled report will be placed before the Court on the next hearing scheduled for 18 March 2026 . The underlying civil appeal (Civil Appeal No(s). 2637/2012) challenges a 2011 Delhi High Court judgment that invalidated a 1992 will of Mst. Nawab Begum on procedural grounds. Important Facts Under Section 3 , a declaration must be made to a designated authority. However, Section 4 remains unframed in several jurisdictions, creating a statutory vacuum. The Delhi High Court had rejected the appellant’s claim because the will lacked a Section 3 declaration and did not meet the evidentiary standards of the Indian Succession Act, 1925 . The Supreme Court highlighted that the inability to make a Section 3 declaration stemmed from the missing Section 4 rules, not from the appellant’s omission. UPSC Relevance This case illustrates the interplay between personal law legislation and constitutional principles of uniformity and equality before law. Aspirants should note: How personal law operates alongside secular statutes. The role of the judiciary in ensuring states comply with statutory mandates. The importance of procedural rule‑making by State Governments for the effective enforcement of central legislation. Way Forward Following the Court’s directive, each State/UT is expected to: Draft and notify rules under Section 4 specifying the authority for Section 3 declarations. Submit the status report to the Additional Solicitor General within the stipulated timeline. Facilitate the filing of declarations so that Muslims wishing to be governed by Shariat law can do so without procedural hindrance. Until uniform rules are in place, litigants may continue to face challenges in invoking Shariat law, potentially leading to further judicial scrutiny and policy debates on the harmonisation of personal laws with constitutional mandates.