Indian law still governs Indian-situs assets
An NRI's residence in Oman does not change which Indian law governs their assets located in India.
The Hindu Succession Act, 1956 applies to Hindus, Sikhs, Jains and Buddhists, and the Indian Succession
Act, 1925 applies to Christians, Parsis and other communities not covered by a separate personal law;
Muslims are separately governed by Muslim personal law for succession in India. Immovable property in
India is governed by Indian law by virtue of its location, irrespective of the NRI's Oman residence,
and Indian courts retain jurisdiction to grant probate or letters of administration over that property
regardless of the deceased's domicile at death. Movable Indian assets -- bank deposits, demat holdings,
mutual funds, and insurance payouts -- are likewise administered under Indian succession law and
procedure, even where the claiming heir applies from Oman and needs supporting documents attested
through the Indian Embassy in Muscat first.
Oman's Personal Status Law and non-Muslim wills
Oman's succession framework is primarily governed by Sharia principles under the Personal Status
Law, Royal Decree 32/1997, with fixed, forced-heirship shares applying for Muslims -- meaning specific
portions of a Muslim decedent's Oman estate pass automatically to specified categories of heirs
(spouse, children, parents, and others depending on the surviving family) rather than being freely
disposable by will. Non-Muslim expatriates can generally make wills recognized under Oman's court
system to distribute their Oman-situs estate according to their own wishes rather than Sharia
forced-heirship rules, typically requiring a witnessed will and a certified Arabic translation before it
can be relied upon in Omani proceedings. Unlike Dubai's DIFC, Oman does not appear to maintain a
dedicated common-law wills registry -- NRIs should confirm current requirements, including any
notarization or court-deposit process for the will, with an Oman-qualified lawyer before drafting an
Oman-specific will, rather than assuming a Gulf-wide standard process applies uniformly.
The standard planning recommendation
As with other Gulf jurisdictions, the well-supported recommendation for NRIs holding assets in both
India and Oman is to execute separate, jurisdiction-specific wills -- one for India-situs assets under
Indian law, and an Oman-specific will (in Arabic or with certified translation) for Oman-situs assets
-- drafted so that neither inadvertently revokes the other, since a will covering only one jurisdiction
can otherwise leave the other estate to default Sharia rules or complicate administration. It is also
worth keeping an accessible, updated record of Oman-held bank accounts, property, and business interests
for family members in India, since practical difficulty in locating and proving entitlement to
Oman-held assets is often a bigger obstacle for NRI heirs than the underlying law itself.
