In Pavini Shukla v. Union of India, the Supreme Court suggested implementing a Uniform Civil Code (UCC) to remove gender bias in personal laws. A UCC would replace religion-based personal laws with one common law for all citizens. Article 44 of the Constitution, a Directive Principle, asks the State to secure a UCC. Marriage, divorce, adoption and succession fall in the Concurrent List of the Seventh Schedule, so both the Centre and States can legislate on them. Uttarakhand is the first State in independent India to implement a UCC, while Goa follows the Portuguese Civil Code of 1867. The 21st Law Commission (2018) had said a nationwide UCC was not necessary at that stage.