Global Perspectives On Uniform Civil Code - Comparative Analysis On Legal Uniformity And Cultural Pluralism
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GLOBAL PERSPECTIVES ON UNIFORM CIVIL CODE:
COMPARATIVE ANALYSIS ON LEGAL UNIFORMITY AND
CULTURAL PLURALISM
Jeya Bharathi Sivakumar, Christ (deemed to be university) Delhi NCR
1. ABSTRACT
The Uniform Civil Code (UCC) seeks to replace religion-based personal laws with a uniform code applicable to matters of marriage, divorce, inheritance, and adoption. Article 44 of the Indian Constitution calls for a UCC, but its enactment has been controversial given India's diversity. However, specific states have passed a unified legal code, including Goa, which has adopted the Portuguese Civil Code, and Uttarakhand, which passed a UCC in 2024. This research paper studies the historical background, implementation challenges, and impact of UCC implementation by surveying the Goa UCC and Uttarakhand UCC and considering models of legal unification globally.
Additionally, this research studies civil codes successfully implemented in countries across the globe, including France and Tunisia, which have successful legal unification while ensuring gender equality, legal certainty, and social cohesion. Reviewing these international experiences assists in developing a comprehensive assessment of best practices and important policy tools that are required for a uniform civil code to be fully functional. By evaluating the legislative framework, judicial interpretation, and socio-political related responses, this study will compare the Goa and Uttarakhand UCC as a case study of a model to build from an everlasting UCC nationwide.
2. INTRODUCTION
The Uniform Civil Code (UCC) is an important but controversial legal reform in India to replace personal laws based on religion with the uniform legal regime for civil matters like marriage and divorce, inheritance, and adoption. The UCC is envisaged under Article 44 of the Indian Constitution to promote the ideals of equality, justice, and integration of the nation but its legal, social, and political implications remain contentious in India's heterogeneous socioreligious milieu. A UCC has not been established across the country, but certain states such as Goa (the Portuguese Civil Code) and Uttarakhand which has been established a UCC in 2024 have enacted the uniform legal regime under their own law. Wide legal unification of legal regimes is not limited to India.
Several countries of the world have succeeded in establishing complete civil codes, applicable equally to all citizens, which has established certainty in their law as well as legal equality among citizens. Countries such as France and Tunisia have established successful civil codes that can lead to useful lessons regarding best practice, challenges, and policy options for governing law in a standard manner. By considering international models and their implications together with an analysis regarding existing Indian law, we can determine possible aspects of feasibility, benefits, and challenges in the establishment of a UCC nationwide. This research study examines the development, enactment, and outcomes of the Goa and Uttarakhand UCCs, while also comparing the initiatives to worldwide best practices in countries including France and Tunisia.
The study explores the legal, social and political implications of a One Nation, One Law policy and if uniformity can exist alongside India’s pluralistic and multicultural traditions in a UCC. The study includes discussion of the issues of gender justice and constitutional challenges, as well as the notion of governance instrumental in shaping a contemporary and inclusive legal system.
3. STATEMENT OF PROBLEM
Debates about the implementation of Uniform Civil Code (UCC) in India are often saturated in conflicting framings of constitutional aims of equality to the religious and cultural diversity of the country. Article 44 of the Indian Constitution encourages a UCC, yet implementation suffers challenges based on religious liberty, political backlashes, and pluralistic personal laws that are formed in complex societies. France and Tunisia, among others, have implemented
secular legal regimes that uniformly regulate personal law, but the historical, political, and religious context differs widely from India. France has a strict secularist regime, which is an absolute separation of religion and law, while Tunisia also incorporates Islamic laws in a modernized legal regime. These ideas present some parallels and contrasts with the legal and social structures of India. This research aims to understand the barriers of UCC application in India, and how France and Tunisia have constructed their personal laws, and if ideas from those countries can contribute to the Indian case. The endeavor will find if a contextual or phased implementation of UCC is available in India, in relation to its own religious, social and constitutional context.
4. RESEARCH OBJECTIVES
The purpose of this study is to explore the challenges faced in adopting the Uniform Civil Code (UCC) in India, that arise from legal, social, political, and religious issues. The research aims to identify the global concept of UCC through examining the legal regimes of countries namely, France and Tunisia which have successfully implemented uniform personal laws. Through juxtaposing and contrasting the UCC frameworks of these countries, the study will reveal relevant similarities and differences relating to the legal, social, and historic backdrop each country faces. Furthermore, the idea of secularism will be examined to help discern how personal laws in France and Tunisia differ in context from India's pluralistic legal system.
An important goal will be to investigate the possibilities of implementing UCC in India by drawing from international experiences and identifying how success can be adapted in the context of India's diverse society. Lastly, the study will identify alternative options to implement UCC in India, ranging from slow reform, selective codification, or a combination of both approaches that reconcile uniformity with diversity.
5. LITERATURE REVIEW
a. UNIFORM CIVIL CODE: A DETAILED ANALYSIS1 Review: This article talks about the scope and importance of the uniform civil code. The author states that the uniform civil code aims to replace personal laws with uniform laws for every
1 Understanding uniform civil code: its need and challenge, penacclaims,(2020)
religion, and it will regulate marriage, succession, divorce, and maintenance with uniformity regardless of religion. The main concern of the uniform civil code, according to the author, is that it will raise the conflict between the majority and the minority. The author discussed the concept with historical analysis, advantages and disadvantages, contemporary development, and the judiciary role in the uniform civil code. The UCC can be implemented, Dr. Ambedkar states that the UCC can be implemented if the state shows a mutual interest in implementing the one law throughout the nation without any discrimination or oppression toward minorities. Gap: further study is required to analyze the matter in a geographical and socio economic context. And there is a need for public awareness in this matter. And there should be guidelines for practicing the UCC. b.
UNDERSTANDING UNIFORM CIVIL CODE: ITS NEED AND CHALLENGES2 Review: In this article, the author explores the difficulties that may be faced by implementing the UCC. Both supporters and opponents of the UCC have their respective points of view in this matter. The supporters of the UCC state that gender equality will be mandated in the UCC as it upholds gender justice and national integrity. While the opponents of the UCC state that there is discrimination against a particular religion and religious freedom will be a question if the UCC is implemented and the constitution of India guarantees religious freedom, it will create controversy. And harmonious construction is needed between the UCC and the directive principle of state of policy.
This paper explores the basic needs and concepts of the UCC and also analyzes the arguments from both sides, such as religious freedom versus gender equality. It also discusses the contemplative context and historical evolution of the UCC, it also states about the struggles of Bharatiya Nyay Sanhita to implement the UCC and significant constitutional changes such as 370 and the construction of the Ram Temple. There was a law commission under Justice B. S. Chauhan, which collected public opinion and political views on the UCC in 2016, it suggests that UCC is neither necessary nor desirable, states like Uttarakhand and Gujarat have set up the panel to implement the UCC. Gap: There is a lack of empirical studies examining the actual impact of personal laws on women and national integration, and how a UCC would specifically address these issues.
2 Understanding Uniform Civil Code: Its needs and challenges, Russian law journals (2023)
c. UNIFORM CIVIL CODE IN INDIA: IMPACT ON ITS IMPLEMENTATION. 3 Review: The paper discusses the essentials of the Uniform Civil Code in India, and there is an urge to replace personal laws with the uniform law and common rule for every citizen. As personal laws cover areas like marriage, divorce, inheritance, adoption, succession, and maintenance and are for public law. It covers the challenges of implementing the UCC,its advantages and disadvantages. This paper also provided a detailed understanding of UCC and the historical background behind it. This also critically analysed the contemporary developments. It seeks to unify all the personal laws into one set to uphold secularism, and it will promote equality. The directive principles of the constitution advocate for a UCC But it also mandates not to make any implementation. which might lead to ongoing debate.
The actual ideology behind UCC is to eliminate the discrimination based on religions, but it needs political harmony for implementation. UCC will strengthen secularism, and the disparities of religious groups might decrease. And as well as the extensions of central family law to Jammu and Kashmir after the revocation of article 370 and more work to implement the UCC nationwide as well as in jammu and kashmir. Gap: There should be a detailed discussion on political challenges and all the dynamics involved in implementing the UCC. d. GENDER JUSTICE IN INDIA: OUTLOOK ON THE UNIFORM CIVIL CODE4 This paper provides an overview of the UCC, the historical background and role of gender equality in the UCC through significant case laws. It aims to create a national civil law that treats all the citizens equally without a discrimination on the basis of religion as well as gender.
This paper urges to end the debate which has been surrounding the UCC for more than three decades, mainly in securing the rights of the women and it also emphasises that all citizens should have equal rights and laws irrespective of marriage, succession, maintenance and inheritance regardless of religion. It also causes conflict with India's pluralistic traditions and also for preserving the rights of the minorities. Practicing their own religion will be questioned and they can't practice their own religion freely and the article 44 lacks the constitutional enforceability, the judiciary recognised the UCC as a step towards national unity. The 3 Uniform Civil Code in India: Impact On Its Implementation, Journal of law and legal research Development (2024)
4 Gender Justice in India: Outlook on the Uniform Civil Code, CURATED VOICES,(2021)
connection between gender equality remains uncertain. The fundamental right of the minorities may be infringed through this as India being a secular country it always gives freedom to practice their own religion in their own way without the state intervening which will be questionable if they implement the UCC. The judiciary is a carrier for the society toward social change, but still the judiciary is welcoming the UCC which aligns with modernity and societal change for the citizen, advancing gender equality. The author says that the success of the UCC will depend upon how they implement it by not infringing on the fundamental right and not causing any hurt towards the minority communities. The push of uniform law undermines India's cultural growth and communal harmony, which is rooted in diversity and multiculturalism.
This paper suggests that rather focusing on the UCC, India should prioritizing substantive legislative efforts to advance women’s rights. Gap: There is a need of empirical research how the UCC can be implemented and there is no any suggestions e. UNIFORM CIVIL CODE FOR GENDER JUSTICE 5 The Constitution of India ensures that the citizens cannot be discriminated against regardless of religion, caste, sex or place of birth are equal before the law. Even Though the constitution provides equality and justice for the women in india. Who make up nearly half of the population, but still facing the gender based discrimination rooted in tradition, religion and culture. These social structures have the history which discriminated the women, there is compulsion of their equality and there is also struggle behind it.
Regardless of gender equality and the various provisions aimed at achieving it, there are always challenges, particularly behind the personal laws. The directive principles of state policy stimulate the state to implement the policy to promote equality in society, which includes gender equality. Some of the Directive principles relate to gender equality and non-discrimination against religion and gender. Article 44, which calls for a UCC across India, has not been enforced. The UCC proposes replacing religion-based on personal laws with a common set of rules governing marriage, divorce, inheritance and other civil matters, which are currently by patriarchal ideologies and often disadvantages women.
5 Uniform Civil Code for Gender Justice, Journal of humanities and social science (2020)
Gap: The reasons behind the government's reluctance to reform Muslim personal laws, beyond concerns about religious freedom, are not thoroughly explored. f. SECULARISM AND RELIGIOUS FREEDOM IN INDIA: AN OVERVIEW6 The abstract provides a detailed explanation of the concept of secularism in India, the key teams in this abstract talk about the distinction of Indian secularism, which emphasizes the importance of equal respect of all religions which is contrast in western countries where state and religion are separate. If you see the origins of secularism it can be traced back to its origin in Europe to its development in India. There have been different theories of secularism which are being discussed which highlights the Indian Constituion's unique approaches to religious freedom, citizenship and state's engagement with religion.
The Indian model of secularism also known as political or contextual secularism maintains a principal distance from all religions and intervenes when religious practices conflict with state goals but this abstract also addresses critiques of Indian secularism particularly by scholars like Ashish Nandy and T. N Madan, who argue that the concept is flawed in the Indian context due to the deeply religious nature of Indian society. The case of Shah Bano is cited as an example of the tension between religious freedom and individual rights, underscoring the need to reform. Summarizing the above paragraph that highlights the ongoing debate around secularism in India, emphasizing the complexities and the need for a balanced approach that respects religious freedom while protecting individual rights.
Gap: In-depth comparative studies between Indian secularism and Western models of secularism, particularly regarding how each model handles religious freedom and state intervention, are underexplored.
RESEARCH METHODOLOGY:
This research uses a doctrinal research methodology, fundamentally based on a thorough assessment of legal doctrines, precedents, statutes, and constitutional provisions associated with the Uniform Civil Code (UCC). It contains a qualitative assessment of both primary and secondary legal materials including constitutional provisions, legislative enactments, case laws, reports of law commissions, and government policies.
6 Secularism and religious freedom in India: An overview, , IJCRT.ORG (2021)
This research will closely investigate the personal laws in India and compare them with UCC models in France and Tunisia using a comparative legal analysis, including a review of statutory laws, judgments, and legal doctrines to see how personal law has been enacted within the frameworks of uniform personal laws, while accommodating religious and cultural factors. Secondary remark sources, like books, journal articles, government reports and commentaries will be utilized to examine the historical development, obstacles and feasibility of the UCC in India. In addition, a review of international human rights instruments and the legal frameworks of personal laws in various other jurisdictions will be taken into consideration to gain an understanding of the international approach to uniformity in this area.
As the discussion is purely doctrinal in nature, and therefore does not utilize any empirical methods, such as field surveys, or interviews. Instead, it seeks to perform a thorough legal analysis using critical interpretation of laws, policies and judicial decisions. The results of this study will contribute to the ongoing discussions of UCC in India through a coherent legal perspective supported with comparative analysis and doctrinal reasoning. The doctrinal methodology is well positioned to be effective for this study, because it investigates legal principles, statutes, and case law, which are both central to understanding the UCC in India, as well as the global contexts. To clarify, as UCC is chiefly a legal and constitutional matter, doctrinal methodology permits detailed legal analysis, without requiring primary data.
DISCUSSION:
The Uniform Civil Code (UCC) in India has been a matter of great concern legally and politically, involving a difficulty of balancing secularism, religious freedom, and gender justice. Article 44 of the Indian Constitution charges the State with the responsibility of implementing a UCC, but issues including religious sensitivities, political opposition, and practical implications continue to hinder the implementation of the UCC in India. Countries like France and Tunisia have implemented uniform personal laws, though, and offer valuable lessons for India. Legal and Constitutional Issues in the Implementation of the UCC in India One of the biggest barriers to the UCC's implementation in India is constitutional protection of religious freedom from Article 25 and Article 26, which give different communities permission to follow their own personal laws.
The judiciary has been the most important actor in reforming personal laws, especially with issues of gender equality and social justice in mind. Shah Bano Case,
Mohd. Ahmed Khan v. Shah Bano Begum7, 1985 The Supreme Court ruled that a Muslim woman had the right to apply for maintenance under Section 125 of the Criminal Procedure Code (CrPC), with a strong note emphasizing that constitutional rights should have precedence over personal laws. Despite reviving UCC discussions, this case also led to the passage of a new law in response - the Muslim Women (Protection of Rights on Divorce) Act, 1986 - which diluted the Court's ruling. Sarla Mudgal v. Union of India (1995)8 The Court held that Hindu men cannot convert to Islam just to enter into a second marriage and reaffirmed that a UCC is necessary to prevent personal laws from being abused for such conversions. Shayara Bano v.
Union of India (2017)9 (Triple Talaq Case) – The Supreme Court seized the occasion to declare instant triple talaq unconstitutional and reinforced the case for the adoption of uniform personal laws for gender justice. While we may be able to find remedy via judicial activism, the establishment of a UCC cannot be established simply by the court’s actions; personal laws are tightly woven into the cloth of religious identity, and it will take political resolve, then legislative action, to achieve a UCC. Advanced Practice like the UCC regulation in France and Tunisia With the conditions described above, India can draw comparatives from the usage of uniform personal laws in France and Tunisia while addressing questions of the beliefs of secularism and cultural identity.
France (Laïcité Model) In France, Laïcité is the action or policy of separating religion from civic or governmental affairs. As a result, religious laws are not a consideration in civil or public law. Thus, Uniform Civil Laws governing the legal processes of marriage, divorce, inheritance, and family law apply to all citizens in France, some of which are still Al-Mahri (where legacy is given to wives) to honor drip laws. The 1905 French law for the Separation of Church and State, in fact, supports this notion of a uniform civil law, with a clear understanding, at least to the level of public law, that religion is consistent with norms governing people in personal life and, that is a personal affair, where courts will not intervene, at least for any religious customs if a claimant is simple using religion to excuse their person.
Even though India, France, and Tunisia have distinct legal systems and cultural backgrounds, there are some commonalities in their engagement with personal laws and subsequent legal reforms. They attempted to balance individual freedoms, gender justice, and uniformity of law - although the three countries have adopted different models to accomplish that idea and these
7 Mohd. Ahmed Khan vs Shah Bano Begum And Ors (1985 AIR 945)
commonality. A commonality between the three countries is the constitutional emphasis of equality and secularism. India - through Article 44 of the Directive Principles of State Policy - envisages a Uniform Civil Code to provide uniformity of law while also maintaining secular values. In France, the principles of Laïcité - "strict secularism" - completely separates religion from civil law, so that personal laws apply equally to all citizens regardless of their religion. Tunisia, although there is some influence of Islamic traditions and laws, has enshrined some progressive reforms expanding personal laws based on gender egalitarianism and modernity within the legal framework. Judicial intervention in the formation of personal laws is another key commonality.
Landmark cases in India Shah Bano (1985), Sarla Mudgal (1995), and Shayara Bano (2017) were all pivotal in advancing gender justice and challenging religious stratification in personal laws. The French judiciary has consistently upheld state secularism to ensure religious beliefs do not supplant national law. Tunisia has similarly made legal changes to its legal system to reinterpret Islamic law as it pertains to equal marriage, divorce, and polygamy in a way that affirms that more progressive legal changes can occur within, rather than in opposition to, a religious framework. As all three examples illustrate, there has also been social resistance, political pressure, and opposition to introducing legal changes relating to personal laws.
In India, UCC is an extremely politically sensitive issue, facing formidable opposition from religious communities that fear losing their customs altogether. France, regardless of maintaining a strict secular legal system, has faced debates around religion and identity, around laws prioritizing religious symbols and practices. Tunisia faced social resistance from conservative segments of society when introducing family law reforms, though the nation managed to make legal changes incrementally, without complete repudiation of Islamic law. India, France, and Tunisia operate under their particular legal arrangements, they all face the same essential challenge- balancing legal uniformity with cultural and religious pluralism.
The Tunisian model stands out as an example that occupies a middle ground between the rigidity of French secularism and the pluralism of India, allowing for the possibility of implementing UCC in a practicable way through a phased, and contextually relevant, implementation in India. The legal challenges to the UCC in Uttarakhand mainly relate to its constitutional validity and a number of writ petitions have been submitted before the Nainital High Court questioning whether the provisions of the UCC violate fundamental rights granted through the Constitution of India. Key Legal Issues Violations to Freedom of Religion (Articles
25 & 26) The Petitioners argue that the UCC restricts personal laws and religious customs
especially with respect to the minority communities.
Provisions, including the abolition of polygamy, defining marriage and inheritance laws uniformly for all communities, infringe religious customs and personal laws that are guaranteed under Article 25 (Freedom of Religion) and Article 26 (Right to Manage Religious Affairs). Right to Privacy (Article 21) The compulsory requirement for couples in a live-in relationship to register that relationship has been challenged as infringing individual privacy rights. Critics are arguing that when couples may be required to provide information to the State regarding their relationship violates an individual's right to privacy which has been determined a fundamental right through the Puttaswamy v. Union of India10(2017). The Supreme Court has always held that adults have the autonomy to cohabit, free from any interference from the state has been pronounced in Lata Singh v.
State of UP (200611) and S. Khushboo v. Kanniammal (2010)12. The UCC's stipulation that live-in relationships must be registered violates this body of law by impeding one's liberty and forcing couples into the ambit of civil law. The state argues that registration serves to protect women in live-in relationships from being abandoned or defrauded by their partners. However, legal experts contend that such a provision is antiadvocacy for women, and may deter their ability to seek some form of protection if it means they may be legally or socially obliged to acknowledge their residency status. In many scenarios, women in abusive/at risk live-in relationships will prioritize anonymity over official registration, depriving them of protection or exposing them to additional layers of risk.
Legal Precedent and Conflicting LawCourts have previously held that live-in relationships are legal relationships, and partners have the same rights to protection under domestic violence laws (Protection of Women from Domestic Violence Act, 2005). The Uttarakhand UCC requiring registration may violate this factor and will likely lead to litigation in the courts with a stay order from the judiciary. The Goa Uniform Civil Code is frequently referred to as a successful implementation of a UCC in India, which offers a uniform set of civil laws governing marriage, divorce, succession, and property rights to each resident of Goa, regardless of their religion. The laws were established in Goa as part of the Portuguese Civil Code of 1867 and continued to be in practice after Goa gained independence from Portuguese colonization in 1961.
Main Components of Goa’s UCC Uniform civil marriage and divorce laws are Marriage is considered a civil contract and the provisions for divorce are uniform across all communities. A husband and wife own property acquired after marriage together (a community of property
system). A share of property will be reserved for legal heirs to ensure equitable distribution. Polygamy is prohibited for Hindus and Christians, but is permitted for Muslims under specific conditions, revealing partial uniformity in civil laws. Similarities with Uttarakhand’s UCC are Uniform Marriage and Divorce Laws, Both UCCs aim to consolidate into one law applicable to everyone in the state.Equality of Property Rights, Uttarakhand’s UCC also seeks to provide equal rights of inheritance and succession to both men and women.State Implementation of it: Similar to Goa, Uttarakhand has also enacted a UCC limited to the state jurisdiction, providing us an opportunity to ask and question the operation of a state UCC within the federal structure of India.
FINDINGS:
The study demonstrates that implementing a Uniform Civil Code (UCC) in India poses substantial complications due to the nation’s unique religious and cultural pluralism. The locus of legal complications involves the conflict of personal laws and constitutional provisions relating to freedom of religion (Article 25) and equality (Article 14). The political opposition and social pressures from diverse religious and regional constituencies also prevent the implementation of a UCC at a national level. The case of Uttarakhand’s UCC reveals both promise and complexity. It might be a historic milestone granting uniformity, but legal risks arise in the case of mandatory registration of live-in relationships infringing upon the right to privacy in Article 21.
In addition, the exemption of Scheduled Tribes (STs) from the operation of the UCC contradicts a principle of equal legal treatment, thus calling into question the degree of genuine uniformity. The study also indicates that international examples of UCCs in France and Tunisia are illuminating: However, France politically embraces a stricter secular legal regime, and Tunisia has been successful in modernizing its personal laws while keeping some degree of Islamic legal orientation. Overall, this comparative analysis indicates that India’s UCC needs to devise a phased and nuanced approach to implementation, making sense of constitutional principles, legal uniformity, and social acceptance.
SUGGESTIONS/RECOMMENDATIONS
For the successful introduction of a Uniform Civil Code (UCC) in India, it is advisable to approach it gradually and inclusively. Rather than introducing a universal law outright, the UCC should be rolled out in stages, beginning with components that have a broader societal consensus, such as equal rights in inheritance and marriage laws. Involving religious leaders,
legal scholars, and civil society representative organizations in discussions on the concerns will enhance and boost societal acceptance. Clarity on the constitutional safeguards is also important; the UCC must articulate and defend fundamental rights regardless of religious freedom. By considering the legal challenges to Uttarakhand's UCC, clarity from the Supreme Court regarding the constitutional scope of personal laws is needed to prevent interminable litigation and uncertainty. Referring to France and Tunisia as examples of others with lawful myths of UCC adopted policies, India must find balance, and the UCC must ensure strict legal conformity without the obligation to assimilate local cultural differences. In addition, public awareness campaigns to educate citizens on the common good of a UCC and to consider obstacles for public approval may be useful.
Finally, it may be helpful to establish a permissive arrangement on how states will adapt UCC provisions based on local sociocultural contexts. This too helped build consensus in the common good.
CONCLUSION:
The question of whether there can be a Uniform Civil Code (UCC) in India is a multifaceted and developing question considering legal uniformity versus cultural and religious diversity. The Uttarakhand UCC is a significant milestone, but considering the obstacles and issues along the way, such as constitutional questions and social resistance, indicates the necessity for a carefully designed approach. The experience of Goa's UCC, and examples from other countries (such as France and Tunisia), have illustrated that a slow, inclusive and more completely consulted approach is essential in achieving wider acceptance.
The success of a national UCC depends on providing gender equality and ensuring the respect for fundamental rights of various communities based on social values attached to those rights, particularly where responses to reform come from a position of vulnerability to legal rights. Rather than imposing a framework, the law needs to be reformed gradually to account for context and adaptation/compliance to the UCC to ensure that any legal reforms align with constitutional law in the context of India's pluralistic society. In the end, the UCC should not solely be about legal uniformity but rather about an equitable and just legal system that elaborates upon the spirit of the Constitution, and allows for people belonging to socially disadvantaged communities to live in peace for the better of society at large.
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