Succession of an NRI's Indian assets remains governed by Indian personal law -- the Hindu Succession Act 1956 or Indian Succession Act 1925 as applicable -- regardless of Singapore residence, while Singapore-situated assets fall under Singapore's own Intestate Succession Act or Wills Act (or, for Muslims, the Administration of Muslim Law Act's faraid rules), making separate, carefully drafted wills for each jurisdiction the standard recommended approach.
Indian assets follow Indian personal law, regardless of Singapore residence
An NRI living in Singapore does not escape Indian succession law for assets located in India. The Hindu
Succession Act, 1956 continues to govern intestate succession for Hindus, Buddhists, Jains, and Sikhs, and the
Indian Succession Act, 1925 governs Christians, Parsis, and others not covered by a separate personal law --
based on the deceased's religion and personal law, not their country of residence. This is the same principle
that applies to NRIs in any other country.
Singapore's own succession framework
For non-Muslims domiciled in Singapore, intestate succession is governed by Singapore's Intestate Succession
Act, with a defined distribution scheme -- for example, a surviving spouse with children shares the estate
equally between the spouse (half) and children (the other half), while a spouse with no children and surviving
parents shares the estate with those parents. Singapore follows the English common-law tradition of broad
testamentary freedom for non-Muslims -- there is no general forced-heirship regime, though the Inheritance
(Family Provision) Act allows a dependant left without reasonable provision to apply to court for relief, a
narrower remedy than civil-law forced heirship. For Muslims domiciled in Singapore, succession instead follows
the Administration of Muslim Law Act's faraid (Islamic inheritance) rules, applied through the Syariah Court --
a Muslim testator can generally bequeath only up to one-third of the net estate by will, with the rest
distributed per faraid shares among the surviving heirs.
Why NRIs in Singapore are generally advised to keep separate wills
A common, sensible approach is a separate will for Singapore-situated assets and a separate will for Indian
assets, each governed by and drafted for its own jurisdiction, with care taken that a revocation clause in one
will does not inadvertently revoke the other. This reflects a broader conflict-of-laws principle: succession to
immovable property generally follows the law of the country where the property is located (lex situs) -- so
Indian real estate follows Indian succession law regardless of the deceased's Singapore domicile -- while
succession to movable property often follows the law of the deceased's domicile, making domicile status
genuinely significant for long-settled NRIs. Probate or letters of administration obtained in one country
generally do not automatically operate in the other, so separate proceedings are typically needed wherever
assets are actually located.
If I'm a Hindu NRI settled in Singapore, does Singapore law govern my Indian property when I die?
No -- succession of Indian immovable property generally follows Indian law (the lex situs principle), and
for a Hindu, the Hindu Succession Act, 1956 governs intestate succession regardless of where you were living
at the time of death.
Do I need one will or two if I have assets in both Singapore and India?
Most estate planners recommend two separate wills -- one for Singapore-situated assets under Singapore law,
one for Indian assets under the applicable Indian personal law -- carefully drafted so that revoking or
amending one does not accidentally revoke the other.
Is there forced heirship in Singapore that would override my will?
Generally no for non-Muslims -- Singapore follows the common-law tradition of broad testamentary freedom,
subject only to the narrower Inheritance (Family Provision) Act remedy for dependants left without reasonable
provision. Muslims domiciled in Singapore are a different case, since faraid (Islamic inheritance) rules under
the Administration of Muslim Law Act generally limit a will to at most one-third of the net estate.
