Determination of Applicable Personal Law at the Opening of Succession:

The personal law governing succession to an estate is determined as on the date of death of the tenure-holder/decedent (when succession opens). Personal law is not frozen or static as of the date of enactment of a tenure/land reform statute. The statutory trigger point ("dies") in present tense dictates that the status and rights of the holder must be tested on the exact date of demise. Subsequent statutory expansions of personal law prior to death govern the rights and character of the estate held by the decedent at death. (Sultan Singh Vs. The Financial Commissioner | 2026 INSC 1107)